United Kingdom vs Indonesia
Crypto regulation comparison
United Kingdom
Indonesia
The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').
Cryptocurrency is legal in Indonesia and classified as a commodity (not currency). Bappebti regulated crypto since 2019, but authority transitioned to OJK (Financial Services Authority) in January 2025. Under PMK 50/2025 (effective August 2025), crypto transactions incur a 0.21% final income tax via domestic exchanges (1% via foreign platforms). VAT on crypto transfers was abolished as crypto was reclassified as digital financial assets.
Key Points
- FCA AML registration required for all crypto firms operating in the UK
- Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
- Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
- Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
- HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
Key Points
- Crypto regulated by OJK since January 2025, transitioned from Bappebti
- 0.21% final income tax on (PPh Art. 22) crypto transaction value for sales per PMK 50/2025
- VAT abolished under PMK 50/2025; reclassified as digital financial assets
- Only crypto assets approved and listed by Bappebti can be traded on licensed exchanges
- Indonesia launched a national crypto exchange (Bursa Kripto Indonesia) in 2023
Sources
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)