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Legal Updates

PADG 24/2026: Strengthening the Role of the Renminbi Clearing Bank in Indonesia–China Bilateral Transactions

18 August 2026
Nadia Nurul Ramadhanty, S.H.
Legal Updates
PADG 24/2026: Penguatan Peran Renminbi Clearing Bank dalam Transaksi Bilateral Indonesia – Tiongkok

Introduction

On 14 August 2026, Bank Indonesia (“BI”) issued Regulation of Members of the Board of Governors Number 24 of 2026 on Amendments to Regulation of Members of the Board of Governors Number 17 of 2025 on the Settlement of Bilateral Transactions between Indonesia and China Using Rupiah and Renminbi through Banks (“PADG 24/2026”). PADG 24/2026 was enacted to adjust the provisions concerning the settlement of bilateral transactions between Indonesia and China, particularly by strengthening the role of banks designated as Renminbi clearing operators (Renminbi Clearing Bank) in Indonesia.

PADG 24/2026 forms part of BI’s efforts to increase the use of local currencies in bilateral transactions in order to support the achievement and maintenance of Rupiah exchange rate stability. In addition, such regulation is intended to support the realization of a modern and advanced money market and foreign exchange market, including through strengthening the use of renminbi in various market transaction instruments and supporting a strong domestic renminbi clearing institutional framework..

Comparison

PADG 24/2026 amends and adds a number of provisions to PADG 17/2025, particularly concerning the mechanism for opening clearing accounts, strengthening the role of the Renminbi Clearing Bank, and operational obligations and administrative sanctions applicable to the operation of renminbi clearing. The comparison of the provisions between PADG 24/2026 and PADG 17/2025 may be described as follows:

Aspect

PADG 24/2026

PADG 17/2025

Opening of Clearing Accounts

In addition to opening a special Special Purpose Non-Resident Account CNY (“SNA CNY”) with a Chinese ACCD Bank, an Indonesian ACCD Bank is also required to open a Renminbi Clearing Account with the Renminbi Clearing Bank.

An ACCD Bank (Appointed Cross-Currency Dealer) is a bank designated to carry out the settlement of certain financial activities and transactions in connection with the implementation of Bilateral Rupiah and Renminbi Transactions.

An Indonesian ACCD Bank is only required to open a special SNA CNY with a Chinese ACCD Bank.

Role of the Clearing Operator (Renminbi Clearing Bank)

An Indonesian ACCD Bank may now legally act as a Renminbi Clearing Bank, subject to obtaining a written recommendation from Bank Indonesia and an official designation by the People's Bank of China.

Does not yet contain a specific legal framework concerning the appointment, designation, or operational role of an Indonesian ACCD Bank as a Renminbi Clearing Bank.

Operational Obligations & Administrative Sanctions

A Renminbi Clearing Bank is required to prepare a rule book, provide CNY/CNH liquidity, and comply with stringent reporting requirements, with sanctions ranging from a warning to suspension of foreign exchange market activities.

Only regulates periodic reporting obligations concerning bilateral transactions and financing positions, without specific provisions concerning the preparation of a clearing rule book and operational sanctions relating to the operation of clearing activities.

Key Provisions

  • Qualification and Designation of the Renminbi Clearing Bank

As stipulated through the insertion of Article 49A and Article 49B, an Indonesian ACCD Bank may act as a Renminbi Clearing Bank to support the development of the Money Market in CNY and/or CNH and the Foreign Exchange Market in CNY and/or CNH against IDR. In carrying out such role, an Indonesian ACCD Bank is required to obtain a recommendation from Bank Indonesia and a designation from the People’s Bank of China as a Renminbi Clearing Bank.

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  • Obligation to Prepare a Rule Book and Obtain Approval from the Board of Commissioners

As stipulated in Article 49J through Article 49L, a Renminbi Clearing Bank is required to prepare provisions and procedures (rule book) for the operation of the Renminbi Clearing Bank, which must at least contain provisions concerning participation, activities facilitated and/or serviced, operating fees, mechanisms and procedures for the implementation of clearing and settlement, and the implementation of risk management. In preparing such rule book, the Renminbi Clearing Bank is required to consult with Bank Indonesia by submitting a consultation request letter signed by at least 1 (one) member of the board of directors, together with the draft rule book. Following completion of the consultation process, the rule book must obtain the approval of at least 1 (one) member of the board of commissioners before being implemented for Renminbi Clearing Bank participants.

  • Liquidity Fulfilment and Activity Implementation Obligations

As stipulated in Article 49O and Article 49P, the Renminbi Clearing Bank has a role in supporting the development of the Money Market and Foreign Exchange Market by fulfilling CNY and/or CNH liquidity requirements, providing facilities and infrastructure for the operation of the Renminbi Clearing Bank, and providing instruments relating to placements and/or financing in CNY and/or CNH. In carrying out such activities, the Renminbi Clearing Bank is required to provide CNY and/or CNH liquidity to participants, ensure that activities are conducted in accordance with the established provisions and procedures (rule book), and fulfil other obligations stipulated by Bank Indonesia.

  • Expansion of the Reporting System and Incidental Reports

Through the amendment to Article 51 and the insertion of Article 55A, the reporting obligations of Indonesian ACCD Banks are expanded to include, among others, reports on the publication and display of CNY or CNH price quotations against IDR through information provider facilities, as well as, for Indonesian ACCD Banks acting as Renminbi Clearing Banks, reports on the implementation of Renminbi Clearing Bank activities submitted to the People’s Bank of China in Indonesian and other reports stipulated by Bank Indonesia. In addition, a Renminbi Clearing Bank is required to submit incidental reports to Bank Indonesia, including reports concerning the imposition of sanctions and/or evaluations by the People’s Bank of China no later than 5 (five) Days after the imposition of such sanctions and/or evaluations, as well as requests for or submission of incidental data and/or information no later than 20 (twenty) Days from the date of such request or submission. The Renminbi Clearing Bank is also required to submit other incidental reports within the deadlines stipulated by Bank Indonesia.

Transitional Provisions

Article II regulates the treatment of Indonesian ACCD Banks that have obtained a designation or recommendation as a Renminbi Clearing Bank prior to the entry into force of this Regulation of Members of the Board of Governors. An Indonesian ACCD Bank that has obtained a designation from the People’s Bank of China is designated as a Supporting Institution for the Money Market and Foreign Exchange Market (PUVA) and is required to inform Bank Indonesia of such designation and submit evidence of the designation no later than 14 (fourteen) Days after this Regulation of Members of the Board of Governors enters into force. Meanwhile, an Indonesian ACCD Bank that has obtained a recommendation from Bank Indonesia remains recognized as an Indonesian ACCD Bank that has obtained a recommendation as a Renminbi Clearing Bank, whereas a bank that has submitted an application for a recommendation but has not yet obtained such recommendation is required to comply with the application requirements as stipulated in this Regulation of Members of the Board of Governors.

In addition, the obligation to submit reports on the publication and display of CNY or CNH price quotations against IDR through information provider facilities takes effect on 2 November 2026, using data for the October 2026 period. The obligation to submit reports on the implementation of Renminbi Clearing Bank activities to the People’s Bank of China takes effect from the time the provisions and procedures (rule book) are implemented for Renminbi Clearing Bank participants, using data for the same month in which such rule book is implemented.

Closing

PADG 24/2026 strengthens the regulatory framework for the settlement of bilateral transactions between Indonesia and China through the development of the role of the Renminbi Clearing Bank in Indonesia. Such regulation not only provides a legal basis for Indonesian ACCD Banks to perform functions as Renminbi Clearing Banks, but also establishes requirements for designation, governance of clearing operations, liquidity provision obligations, and the strengthening of reporting and supervisory systems by Bank Indonesia.

With the strengthening of the institutional framework and operational obligations, Indonesian ACCD Banks acting as Renminbi Clearing Banks need to ensure compliance with all provisions stipulated in PADG 24/2026, including the preparation and implementation of the rule book, provision of liquidity, and fulfilment of reporting obligations to Bank Indonesia.

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