Compliance and Legal Standing
This proposal sits entirely inside the Warehouse Receipt System regime. The marketplace adds one function that does not yet exist — price discovery and buyer access — without replacing any function already in operation.
Legal basis
Law Number 9 of 2006 on the Warehouse Receipt System, as amended by Law Number 9 of 2011.
The implementing regulations beneath it concerning the Registration Center, Warehouse Operators, Conformity Assessment Bodies, and the Warehouse Receipt Guarantee Agency.
Bappebti Regulation Number 7 of 2018 on Approval of Commodity Auction Market Operators, and Bappebti Regulation Number 3 of 2021 on Technical Provisions for Commodity Auction Markets with Immediate Delivery.
What is traded on the marketplace is a Warehouse Receipt valid under the law — not a new instrument, not a derivative product, and not a digital asset. Transfer of title remains subject to recording at the Registration Center.
System boundaries
To avoid overlapping authority and to preserve data integrity, the following boundaries are proposed to be fixed explicitly from the outset.
| Function | Sits with | Note |
|---|---|---|
| Source of truth for receipt data | Registration Center (KBI) | The marketplace only reads; it holds no copy that stands as proof |
| Receipt issuance | Licensed Warehouse Operator | Unchanged |
| Physical possession of the commodity | Warehouse Operator | The marketplace never takes custody |
| Settlement of funds | Clearing institution or holding bank | Funds never pass through a marketplace account |
| Recording transfer of title | Registration Center (KBI) | The marketplace only sends instructions and receives confirmation |
| Price discovery and buyer access | Marketplace | The new function being added |
| User verification | Marketplace | Subject to agreement |
| Supervision | Bappebti | Including full access rights over marketplace transaction data |
Roles and responsibilities
The proposed division of roles among the parties in the interconnection scheme.
| Party | Role | Principal responsibility |
|---|---|---|
| Bappebti | Supervisor and guide | Setting the compliance framework, approving the pilot scheme, ongoing supervision, resolving cross-party issues |
| PT Kliring Berjangka Indonesia | Registration Center and settlement | Recording receipts and transfers of title, providing the data interface, settling transactions, data integrity |
| PT BGR Logistik Indonesia | Warehouse Operator | Receiving, storing, and safeguarding commodities; issuing receipts; serving redemptions |
| PT Super System Technology | Marketplace operator | Building and running the platform, verifying users, matching supply and demand |
Limited pilot
For the first stage, a limited pilot is proposed on one commodity in one region, at controlled volume, under Bappebti's direct guidance and supervision.
The licensing standing of the marketplace is one of the matters on which Bappebti's direction is sought.