OJK Circular No. 34/SEOJK.07/2025 on Business Plans for Digital Financial Asset Trading Operators

To the Esteemed Board of Directors of Digital Financial Asset Trading Operators, in place.

COPY OF CIRCULAR OF THE FINANCIAL SERVICES AUTHORITY OF THE REPUBLIC OF INDONESIA NUMBER 34/SEOJK.07/2025 CONCERNING BUSINESS PLANS FOR DIGITAL FINANCIAL ASSET TRADING OPERATORS

In connection with the mandate of Article 76 paragraph (8) of Financial Services Authority Regulation Number 27 of 2024 concerning Digital Financial Asset Trading Operators Including Crypto Assets (State Gazette of the Republic of Indonesia Year 2024 Number 38/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 106/OJK) as amended by Financial Services Authority Regulation Number 23 of 2025 concerning Amendments to Financial Services Authority Regulation Number 27 of 2024 concerning Digital Financial Asset Trading Operators Including Crypto Assets (State Gazette of the Republic of Indonesia Year 2025 Number 33/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 162/OJK), it is necessary to regulate further provisions regarding the business plans of Digital Financial Asset Trading Operators as follows:

I. GENERAL PROVISIONS In this Financial Services Authority Circular, the following terms are defined as:

1. Digital Financial Asset is a financial asset stored or represented digitally, including crypto assets.
2. Crypto Asset is a digital representation of value that can be stored and transferred using technology that allows the use of distributed ledgers such as blockchain to verify its transactions and ensure the security and validity of the stored information, not guaranteed by a central authority such as a central bank but issued by a private party, can be transacted, stored, and transferred or assigned electronically, and can be in the form of digital coins, tokens, or other asset representations including backed crypto-assets and unbacked crypto-assets.
3. Digital Financial Asset Exchange including Crypto Assets, hereinafter referred to as Exchange, is a business entity that organizes and provides systems and/or facilities to facilitate activities related to Digital Financial Asset trading including Crypto Assets and/or provides Digital Financial Asset trading reports.
4. Digital Financial Asset Trading Clearing, Guarantee, and Settlement Institution including Crypto Assets, hereinafter referred to as Clearing, Guarantee, and Settlement Institution, is a business entity that provides Digital Financial Asset trading transaction settlement services and guarantees Digital Financial Asset trading transaction settlement.
5. Digital Financial Asset Custodian including Crypto Assets, hereinafter referred to as Custodian, is a business entity that has obtained a business license from the Financial Services Authority to manage Digital Financial Asset storage in order to store, maintain, supervise, and/or deliver Digital Financial Assets.
6. Digital Financial Asset Trader, hereinafter referred to as Trader, is a business entity that conducts Digital Financial Asset trading, either on its own behalf and/or facilitates consumers.
7. Digital Financial Asset Trading Operator is an Exchange, Clearing, Guarantee, and Settlement Institution, Custodian, Trader, and other parties designated by the Financial Services Authority.
8. Business Plan is a written document describing the development plan and business activities of the Digital Financial Asset Trading Operator for a period of 1 (one) year, including plans to improve business performance and strategies to realize these plans in accordance with established targets and timelines, while still considering the fulfillment of risk management and prudential principles.
9. Board of Directors is the organ of the Digital Financial Asset Trading Operator that is fully authorized and responsible for the management of the Digital Financial Asset Trading Operator for the benefit of the company, in accordance with the aims and objectives of the Digital Financial Asset Trading Operator and represents the Digital Financial Asset Trading Operator, both in and out of court in accordance with the provisions of the articles of association.
10. Board of Commissioners is the organ of the Digital Financial Asset Trading Operator tasked with general and/or specific supervision in accordance with the articles of association and providing advice to the Board of Directors.
11. Report on the Realization of the Business Plan is a report on the implementation of the Business Plan by the Board of Directors and the results of the Board of Commissioners' supervision of the implementation of the Business Plan.

II. BUSINESS PLANS FOR DIGITAL FINANCIAL ASSET TRADING OPERATORS

1. The Business Plan of a Digital Financial Asset Trading Operator must contain at least: a. establishment of the Digital Financial Asset Trading Operator's objectives to be achieved within a period of 1 (one) year, covering:

1. executive summary;
2. business activity plan;
3. funding plan;
4. investment plan;
5. capital plan;
6. management change plan;
7. organizational development plan;
8. human resource fulfillment and development plan;
9. information technology development and maintenance plan; and
10. other information (if any); b. strategy for achieving the Digital Financial Asset Trading Operator's objectives, covering:
11. analysis of the Digital Financial Asset Trading Operator's position;
12. management policy;
13. management strategy; and
14. other information (if any); c. financial projections for 1 (one) year ahead, covering:
15. projected financial statements;
16. projected ratios and certain items; and
17. other information (if any).

2. The Business Plan of a Trader, in addition to complying with the provisions as referred to in point 1, must contain at least: a. products, activities, and services to be offered; b. target number of consumers; c. target trading value and volume; and d. other information (if any).
3. The executive summary as referred to in point 1 letter a point 1) contains a brief explanation of the main points of the Business Plan presented concisely, which includes at least: a. vision, which is the goal the Digital Financial Asset Trading Operator wants to achieve, and mission, which is the method used to achieve the goal; b. policy direction, which is general information on the Digital Financial Asset Trading Operator's policy set by management in developing the Digital Financial Asset Trading Operator's business within a period of 1 (one) year; c. strategic steps to be taken by the Digital Financial Asset Trading Operator within a period of 1 (one) year; d. key financial indicators; and e. business targets, which are the focus of the Digital Financial Asset Trading Operator's activities, both quantitative and qualitative, within a period of 1 (one) year in accordance with the Digital Financial Asset Trading Operator's vision and mission.
4. The business activity plan as referred to in point 1 letter a point 2) contains an explanation of: a. business activities currently being carried out by the Digital Financial Asset Trading Operator; or b. plans for developing new business activities to be carried out by the Digital Financial Asset Trading Operator, which may include matters related to activities, products, and services, for 1 (one) year ahead.
5. The funding plan as referred to in point 1 letter a point 3) contains information related to the Digital Financial Asset Trading Operator's funding plan for the next 1 (one) year period.
6. The investment plan as referred to in point 1 letter a point 4) is the investment plan carried out by the Digital Financial Asset Trading Operator, including information on investment composition and investment results for the next 1 (one) year period.
7. The capital plan as referred to in point 1 letter a point 5) is the capital change plan for the next 1 (one) year period.
8. The management change plan as referred to in point 1 letter a point 6) is the plan for changes in the composition of the management of the Digital Financial Asset Trading Operator for the next 1 (one) year period.
9. The organizational development plan as referred to in point 1 letter a point 7) includes, among others, plans for the formation or change of work units and/or committees, adjusted to the capabilities, size, and business complexity of the Digital Financial Asset Trading Operator for the next 1 (one) year period.
10. The human resource development and fulfillment plan as referred to in point 1 letter a point 8) includes, among others, plans for human resource fulfillment, plans for education and training for human resources for the Board of Directors, Board of Commissioners, and employees, including cost plans and implementation of these activities, as well as plans for the utilization of foreign workers and/or outsourced personnel for the next 1 (one) year period.
11. The information technology development and maintenance plan as referred to in point 1 letter a point 9) is the information technology development and maintenance plan, including information on the costs of information technology development and maintenance, among others: a. information on information technology development and maintenance includes application name, description, type of development or maintenance, nature of development, provider, implementation target, and development or maintenance costs; b. reasons and/or considerations and impacts of the information technology development and maintenance plan; c. analysis of increase or decrease in risk and its mitigation in carrying out information technology development and/or maintenance; and d. strategy to realize the information technology development and maintenance plan.
12. Other information as referred to in point 1 letter a point 10) includes, among others, plans for network office development and/or changes, plans for cessation of business activities, products, or activities that have a material impact on financial performance.
13. Analysis of the Digital Financial Asset Trading Operator's position and management policy as referred to in point 1 letter b point 1) includes information on the Digital Financial Asset Trading Operator's position both nationally and globally, including information on problems and obstacles experienced by the Digital Financial Asset Trading Operator.
14. Management policy as referred to in point 1 letter b point 2) includes information on the Digital Financial Asset Trading Operator's policy set by management, among others: a. risk management and compliance policy; and b. merger, consolidation, and acquisition plans (if any).
15. Management strategy as referred to in point 1 letter b point 3) is a business development strategy that contains information on strategic steps to achieve business objectives and the Digital Financial Asset Trading Operator's established plans, as well as a summary of the strategies to be taken by the Digital Financial Asset Trading Operator in achieving the objectives as referred to in point 1 letter a.
16. Other information as referred to in point 1 letter b point 4) is information on the strategy for achieving the Digital Financial Asset Trading Operator's objectives other than the information as referred to in points 13, 14, and 15, including remuneration policy.
17. Projected financial statements as referred to in point 1 letter c point 1) contain information on the Digital Financial Asset Trading Operator's financial condition (actual position at the end of September of the Business Plan preparation year) and projections for the next 1 (one) year period along with the assumptions used.
18. Projected ratios and certain items as referred to in point 1 letter c point 2) contain financial ratios and other specific ratios (actual position at the end of September of the Business Plan preparation year) and projections for the next 1 (one) year period.
19. Other information as referred to in point 1 letter c point 3) is information related to the Digital Financial Asset Trading Operator's financial condition for the next 1 (one) year period other than the information as referred to in points 17 and 18.
20. Products, activities, and services to be offered as referred to in point 2 letter a is a description of the plan for organizing new products, activities, and/or services to be offered for the next 1 (one) year period.
21. Target number of consumers as referred to in point 2 letter b is the target number of consumers who have undergone the know your customer (KYC) process, which is set as a projection of consumer growth for the next 1 (one) year period.
22. Target trading value and volume as referred to in point 2 letter c is the estimated total transaction value (in rupiah) and trading volume for each product, activity, and service carried out by the Trader for the next 1 (one) year period.
23. Other information as referred to in point 2 letter d is information related to the Trader's business activity plan other than the information as referred to in points 20, 21, and 22.
24. Other parties designated by the Financial Services Authority as Digital Financial Asset Trading Operators shall submit a Business Plan containing at least: a. establishment of the objectives of other parties designated by the Financial Services Authority as Digital Financial Asset Trading Operators to be achieved within a period of 1 (one) year, at least:

1. executive summary as referred to in point 3;
2. business activity plan as referred to in point 4;
3. funding plan as referred to in point 5;
4. investment plan as referred to in point 6;
5. capital plan as referred to in point 7;
6. information technology development and maintenance plan as referred to in point 11; and
7. other information (if any) as referred to in point 12; b. strategy for achieving the objectives of other parties designated by the Financial Services Authority as Digital Financial Asset Trading Operators, covering:
8. management policy as referred to in point 14;
9. management strategy as referred to in point 15; and
10. other information (if any) as referred to in point 16; and c. financial projections for 1 (one) year ahead for other parties designated by the Financial Services Authority as Digital Financial Asset Trading Operators, covering:
11. projected financial statements as referred to in point 17;
12. projected ratios and certain items as referred to in point 18; and
13. other information (if any) as referred to in point 19.

25. The Business Plan as referred to in point 1 shall be prepared by fulfilling the elements of: a. strategic plan of the Digital Financial Asset Trading Operator; b. internal and external factors that may affect the continuity of the Digital Financial Asset Trading Operator's business activities; c. prudential principle; and d. application of risk management.
26. The preparation of the Business Plan refers to the guidelines for preparation and format as contained in the Appendix, which is an inseparable part of this Financial Services Authority Circular.

III. ADJUSTMENTS AND CHANGES TO BUSINESS PLANS

1. The Financial Services Authority may request the Digital Financial Asset Trading Operator to make adjustments to the Business Plan, in the event that the submitted Business Plan is deemed not to fully comply with the provisions related to Digital Financial Asset trading activities;
2. The Digital Financial Asset Trading Operator may make changes to the Business Plan in the event of external and internal factors that significantly affect the operational activities and/or affect the performance of the Digital Financial Asset Trading Operator.
3. External and internal factors as referred to in point 2, include, among others: a. external factors include economic conditions, government policies, competition with financial service institutions or other entities, and information technology developments; b. internal factors include financial condition, management and human resources, and other infrastructure capabilities including information technology; and/or c. external and internal factors as referred to in letter a and letter b are deemed by the Digital Financial Asset Trading Operator to have a material impact on operational activities and/or financial condition, which is reflected, among others, in the Digital Financial Asset Trading Operator's financial statements or in the event that it affects the Digital Financial Asset Trading Operator's financial performance.
4. The Digital Financial Asset Trading Operator may only make changes to the Business Plan as referred to in point 2 once, no later than the last working day of June of the current year, unless otherwise determined at the request of the Financial Services Authority.

IV. REPORTS ON THE REALIZATION OF BUSINESS PLANS FOR DIGITAL FINANCIAL ASSET TRADING OPERATORS

1. Reports on the Realization of the Business Plan shall be submitted by the Digital Financial Asset Trading Operator quarterly, namely for the positions of March, June, September, and December.
2. Reports on the Realization of the Business Plan shall contain at least an explanation of the achievement of the Business Plan, an explanation of deviations from the realization of the Business Plan, follow-up actions or efforts to be taken to improve the achievement of the Business Plan realization, financial ratios and certain items, and other information.
3. Reports on the Realization of the Business Plan shall be prepared by the Board of Directors and the Board of Commissioners.
4. Reports on the Realization of the Business Plan shall be signed by the Board of Directors and the Board of Commissioners in accordance with the articles of association of the Digital Financial Asset Trading Operator.
5. The results of the Board of Commissioners' supervision of the Business Plan shall be stated in the Report on the Realization of the Business Plan.
6. The preparation of the Report on the Realization of the Business Plan refers to the guidelines for preparation and format for each Digital Financial Asset Trading Operator as contained in the Appendix, which is an inseparable part of this Financial Services Authority Circular.

V. PROCEDURES FOR SUBMITTING BUSINESS PLANS, BUSINESS PLAN ADJUSTMENTS, BUSINESS PLAN CHANGES, AND REPORTS ON THE REALIZATION OF BUSINESS PLANS

1. The Digital Financial Asset Trading Operator shall submit the Business Plan to the Financial Services Authority no later than November 30 before the Business Plan year begins.
2. The Digital Financial Asset Trading Operator shall submit adjustments to the Business Plan to the Financial Services Authority no later than 15 (fifteen) working days after the date of the letter from the Financial Services Authority.
3. The Digital Financial Asset Trading Operator shall submit changes to the Business Plan to the Financial Services Authority no later than 30 (thirty) working days before the implementation of the said Business Plan.
4. The Digital Financial Asset Trading Operator shall submit the Report on the Realization of the Business Plan to the Financial Services Authority no later than 15 (fifteen) working days after the end of the reporting period.
5. If the deadline for submitting the Business Plan falls on a holiday, the deadline for submitting the Business Plan and the Report on the Realization of the Business Plan shall be the next first working day.
6. The submission of Business Plans, Business Plan adjustments, Business Plan changes, and Reports on the Realization of Business Plans shall be done online through the Financial Services Authority Reporting System.
7. In the event that the Financial Services Authority Reporting System as referred to in point 6 is not yet available or experiences technical disruption, the Digital Financial Asset Trading Operator shall submit Business Plans, Business Plan adjustments, Business Plan changes, and Reports on the Realization of Business Plans in the form of electronic documents via email to the address: a. mailingroomsumitro@ojk.go.id, if the Financial Services Authority Reporting System is not yet available; b. mailingroommrp@ojk.go.id, if the Financial Services Authority Reporting System experiences technical disruption; or c. other addresses determined by the Financial Services Authority.
8. The submission of Business Plans, Business Plan adjustments, Business Plan changes, and Reports on the Realization of Business Plans in the form of electronic documents via email as referred to in point 7 shall be addressed to: a. Head of the Department of Supervision of Financial Sector Technology Innovation, Digital Financial Assets and Crypto Assets, if the Financial Services Authority Reporting System is not yet available; or b. Head of the Data and Statistics Management Department with a copy to the Head of the Department of Supervision of Financial Sector Technology Innovation, Digital Financial Assets and Crypto Assets, if the Financial Services Authority Reporting System experiences technical disruption.
9. In the event that the Financial Services Authority's email as referred to in point 7 experiences technical disruption, the submission of Business Plans, Business Plan adjustments, Business Plan changes, and Reports on the Realization of Business Plans shall be submitted to the Financial Services Authority offline by: a. direct submission; or b. sending through a delivery service company.
10. The offline submission of Business Plans, Business Plan adjustments, Business Plan changes, and Reports on the Realization of Business Plans as referred to in point 9 shall be addressed to: a. Head of the Department of Supervision of Financial Sector Technology Innovation, Digital Financial Assets and Crypto Assets, Soemitro Djojohadikusumo Building, Jalan Lapangan Banteng Timur 2-4, Jakarta 10710, Indonesia, if the Financial Services Authority Reporting System is not yet available and email experiences technical disruption; or b. Head of the Data and Statistics Management Department, Menara Radius Prawiro Building 14th Floor, Bank Indonesia Office Complex, Jalan MH. Thamrin Number 2, Central Jakarta, 10350, with a copy to: Head of the Department of Supervision of Financial Sector Technology Innovation, Digital Financial Assets and Crypto Assets, Soemitro Djojohadikusumo Building, Jalan Lapangan Banteng Timur 2-4, Jakarta 10710, Indonesia, if the Financial Services Authority Reporting System experiences technical disruption and email experiences technical disruption.
11. The Digital Financial Asset Trading Operator is deemed to have submitted the Business Plan and the Report on the Realization of the Business Plan provided that: a. submission through the Financial Services Authority Reporting System is evidenced by a receipt from the Financial Services Authority Reporting System; b. submission via email is evidenced by a receipt from the Financial Services Authority's email; or c. offline submission is evidenced by:

1. a receipt from the Financial Services Authority if submitted directly to the OJK office; or
2. a timestamp from the expedition company if sent using an expedition service.

This copy is in accordance with the original Head of Development Directorate H

---

[RegAlert note: the English text above is a translation of the first 24,000 characters of a 155,022-character original (15% of the document). The remainder was not translated. The complete original-language text is stored with this document.]