Advances in blockchain technology have given rise to various forms of digital assets, including crypto assets and tokenized assets representing particular rights and economic interests, thereby creating new challenges for Indonesia's civil-law system. This study examines whether Indonesian civil-law constructs can accommodate crypto-asset developments by comparing regulatory approaches in several jurisdictions. It employs normative legal research using statutory and conceptual approaches, supported by an analysis of legislation, doctrine, and legal literature. The findings show that the United States, Japan, and Singapore apply regulatory approaches based on the functions and economic characteristics of crypto assets, whereas Indonesia continues to regulate them only partially through Bappebti regulations and Law Number 4 of 2023 on Financial Sector Development and Strengthening, which focus on financial-sector supervision. Although Article 499 of the Indonesian Civil Code permits tokenized assets to be classified as intangible property, legal certainty is still lacking regarding their civil-law status, mechanisms for transferring rights, inheritance, and the protection of property rights. Accordingly, legislation at the level of an Act is needed to integrate civil law, financial-sector regulation, and the legal regimes governing underlying assets, thereby ensuring legal certainty while supporting digital-asset innovation in Indonesia.
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