feat(jurisdiction): add Indonesia OJK and Singapore MAS cards

[mzf11125]

What are you adding?

• Vendor/Protocol
• Enterprise Use Case
• Update to existing content
• Jurisdiction

Description

Adds jurisdictions/id-OJK.md and jurisdictions/sg-MAS.md. The map currently covers Hong Kong and China in APAC and has no ASEAN coverage at all.

Indonesia

Supervision of crypto assets moved from the commodity futures regulator, Bappebti, to the financial services authority, OJK, effective 10 January 2025 under Government Regulation 49/2024, as mandated by the P2SK Law. The substantive change is reclassification: crypto is no longer a tradable commodity but a "digital financial asset" inside the financial services perimeter.

Current state, which has moved recently and is easy to get wrong:

• POJK 27/2024, as amended by POJK 23/2025 (issued January 2026), which closed the transition phase
• Law No. 4 of 2026, effective 17 June 2026, raising the taxonomy to primary law
• A draft OJK regulation on digital financial asset offerings is still pending

The reason this card belongs in a privacy map is a listing criterion. POJK 27/2024 requires traded assets to be traceable and bars assets whose features conceal ownership or transaction information. That is a direct, named restriction on privacy technology in a G20 market, and no other card in the folder documents a rule of that shape. Indonesia is permissive toward tokenised finance and explicitly restrictive toward on-chain confidentiality.

Crypto also remains prohibited as a payment instrument, since the Currency Law makes the rupiah sole legal tender.

Singapore

Permissive and heavily licensed. Digital payment token services sit under the Payment Services Act 2019, and since 30 June 2025 a separate DTSP regime under the Financial Services and Markets Act 2022 captures Singapore-incorporated firms serving customers wholly abroad. That regime commenced with no transition window.

One claim deliberately pulled back: the single-currency stablecoin framework was finalised as policy in August 2023, but the implementing legislation has not been introduced in Parliament, so the card records it as not yet in force rather than as law.

Scope

Both follow jurisdictions/_template.md. Cross-linked to each other and to the existing Hong Kong and China cards, which gives the map its first connected APAC cluster.

Checks

• CI_MODE=strict npm run validate passes with zero warnings against either file
• check-terms clean
• Vale clean on both

CHANGELOG entry added under [Unreleased], referencing this PR.

Checklist

• I've checked this doesn't duplicate existing content
• All links work
• Info is accurate

[mzf11125]

Fixed the changelog here @rymnc, ready for review

Posted in error

[mzf11125]

Hi @oskarth, thanks for the review. I noticed it was withdrawn and marked as posted in error. Could you share what prompted that?

While waiting to hear back, here is what I found on my end. POJK 23/2025 was signed 31 October 2025 and promulgated 10 November 2025, and expanded scope to derivatives, broadened the operator perimeter, and tightened capital, segregation, and supervision requirements. Separately, the regulation itself sets 9 January 2026 as the deadline for unlicensed derivative traders to transfer their activity to a licensed Trader, a 3 month window for exchange and clearing house rule adjustments, and up to 12 months for infrastructure and consumer fund adjustments. ADCO Law also describes POJK 23/2025 as confirming the conclusion of the transition phase from Bappebti to full OJK supervision.

So the card's January 2026 date is not invented, it maps to a real deadline inside POJK 23/2025, though the current wording conflates it with the November 2025 promulgation date. I plan to update the card to state both dates clearly once I understand why the review was pulled. Happy to fix whatever is needed.

Sources:

• Official POJK 23/2025 regulation text and dates (OJK, Indonesian original): https://ojk.go.id/id/regulasi/Pages/POJK-23-2025-Perubahan-POJK-27-Tahun-2024-tentang-Penyelenggaraan-Perdagangan-Aset-Keuangan-Digital-Termasuk-Aset-Kripto.aspx
• OJK IRU English summary of POJK 23/2025: https://iru.ojk.go.id/iru/WebSite/ArticleList/View/977_OJK_Regulation_Number_23_2025_concerning_Amendment_to_POJK_27_2024_concerning_Provision_of_Trading_of_Digital_Financial_Assets_Including_Crypto_Assets
• ADCO Law, on the transition from Bappebti to OJK: https://adcolaw.com/blog/the-direction-of-crypto-asset-regulation-in-indonesia-following-the-transfer-of-supervisory-authority-from-bappebti-to-the-ojk
• Conventus Law, on the OJK supervision transition: https://conventuslaw.com/report/indonesia-the-transition-of-crypto-assets-supervision-to-ojk-has-finally-begun
• Veritask, summary of POJK 23/2025 including the derivative trader deadline: https://veritask.ai/en/artikel/ekspansi-aset-kripto-dan-produk-derivatif-dalam-pojk-no-23-tahun-2025
• ABNR, on Law 4/2026 and the P2SK amendment: https://www.abnrlaw.com/en/news/indonesias-p2sk-law-amendment-what-law-42026-changes-for-crypto-and-digital-financial-assets
• ABNR, on the crypto derivatives framework under POJK 23/2025: https://www.abnrlaw.com/news/indonesia-greenlights-crypto-derivatives-a-look-at-the-new-ojk-framework

[oskarth]

Earlier review was posted by mistake, apologies for the confusion :) The substance stands, and you diagnosed it exactly: the sentence ties January 2026 to the wrong fact. Suggestions below keep both dates. Everything else checked out - will merge once these are in. Nice sourcing.

[oskarth]

Thanks!

[mzf11125]

No worries, @oskarth! Following up on my comment on X regarding a potential volunteer role to help expand ethsystems.org's footprint in Indonesia. I'd love to discuss this further with you on Telegram (@mzf11125) when you have a moment.