Organizers of transaction facilities ("Organizers") are now required to allocate training and education funds amounting to approximately 3.5% of their current annual budgets to electronic trading platform providers and 1% of their current annual budgets to brokerage companies based on the previous years gross salary expenditures. Annual reports must also be submitted that address the development of human resources. These two obligations will become effective in January 2026 and April 2027 respectively. In addition, the audit reporting obligation has been replaced with a requirement to submit reports on the implementation of risk management and governance, which are elements of system audits.

To enhance the effectiveness of monetary policy and financial system stability, Bank Indonesia ("BI") introduced Regulation No. 6 of 2024 (Regulation 6/2024) on the Money Market and Foreign Exchange Market (Pasar Uang dan Pasar Valuta Asing "PUVA"). Building upon this foundation, the BI Board of Governors subsequently stipulated Regulation No. 9 of 2025 on Supporting Institutions and Professions for PUVA (Regulation 9/2025). This regulation classifies entities into two categories: PUVA Supporting Institutions (e.g., banks and securities companies) and PUVA Supporting Professions (e.g., legal consultants and public accountants), each with specific registration and operational requirements.

In an effort to support Indonesias economic growth, Bank Indonesia ("BI") is now authorized to manage liquidity ("Liquidity Management"). Six forms of instruments and/or mechanisms will now be utilized by BI in order to ensure adequate Liquidity Management, including: 1) Minimum statutory reserve (Giro Wajib Minimum/GWM) arrangements; 2) Purchases or sales of state securities (Surat Berharga Negara/SBN) or other qualified securities through the secondary market; 3) Placements of funds in financial institutions for the purpose of money market development; 4) Purchases of short-term government bonds (Surat Utang Negara/SUN) through the primary market.

The Third Amendment has now introduced the possible use of Quick Response Codes, which can be used to facilitate payments ("QR Codes") in line with national standards ("QRIS") and which can be utilized with or without scanning features. This technology takes the form of technologies that utilize data communications ("Messaging"), including Near-Field Communication (NFC) technology.

In addition to the already mandatory application of Anti-Money-Laundering (Anti Pencucian Uang "APU") and Prevention of Terrorism Financing (Pencegahan Pendanaan Terorisme "PPT") efforts, business actors operating within the financial sector under the supervision of Bank Indonesia ("BI") ("Organizers") must also now apply measures that specifically relate to the Funding of the Proliferation of Weapons of Mass Destruction (Pencegahan Pendanaan Proliferasi Senjata Pemusnah Massal "PPSPM"). Organizers have been given a grace period of between six months and one year (depending on their classification) in order to bring their operations into line with the updated APU, PPT and PPSPM requirements.

The new framework of Regulation 22/2024 establishes a set of procedures for submissions of reports that specifically address the implementation of competency standardization in relation to payment systems (Standardisasi Kompetensi di Bidang Sistem Pembayaran/SK SP) for both banks and non-banking institutions. These reports include both periodic (i.e. quarterly and annual) and incidental reports. Any failure to meet the applicable reporting deadlines may result in the imposition of penalties such as written warnings, suspensions of business activities or revocations of licenses.

Regulation 18/2024 acts as an implementing Regulation for the organization of Alternative Dispute Resolution Institutions Operating Within the Financial Sector (Lembaga Alternatif Penyelesaian Sengketa Sektor Keuangan "LAPS-SK") and provides details on the organization, mechanism and technical aspect of LAPS-SK. This includes the establishment of LAPS-SK, membership, supervision, sanctions and various other aspects.

The applicable provisions and procedures for the organization of Central Counterparty institutions ("CCP") that relate to the clearing and settlement of money and/or foreign exchange market (Pasar Uang dan/atau Pasar Valuta Asing "PUVA") transactions ("Rule Book") outline a wide-array of aspects that range from general provisions up until the imposition of administrative sanctions. In this regard, the Rule Book outlines a total of 13 requirements that have to be met by parties that wish to become CCP members. Moreover, securing said membership requires relevant applicants to submit applications and required documents to PT Kliring Penjaminan Efek Indonesia (KPEI).

In addition to further clarifying the types of functions that may be carried out by Central Counterparties ("CCP"), Regulation 9/2024 newly requires said institutions to comply with applicable international principles and/or standards that specifically relate to the organization of CCP within one year of a given CCP securing its business permit from Bank Indonesia ("BI"). Moreover, Regulation 9/2024 newly outlines various responsibilities and obligations that must be borne by any CCP that act as agents for transaction actors after the commencement of the financial transaction ("Tri-Party Agents").

Foreign exchange market participants ("Participants") who are involved in derivative transactions can now utilize smart contracts, which should include the automated execution of rights and obligations and which should be properly documented. However, prior to employing any smart contracts, commercial banks ("Banks") must first consult with Bank Indonesia by submitting formal requests through e-mail. In addition, any Banks that choose to utilize said contracts will be required to maintain certain levels of governance, ensure the security and reliability of their systems, protect the confidentiality of data and guarantee central bank access to relevant information.