What this register is
A working list of the instruments that govern carbon pricing and carbon trading in Indonesia, with what each one actually requires and what it means if you are developing a project.
The framework is not a single statute. It is an umbrella presidential regulation, two laws that supply the fiscal and financial-market authority, a set of ministerial regulations that make it operable sector by sector, and the Paris Agreement rules that determine what can be sold abroad. They were issued over five years by five different institutions, and they do not always agree.
October 2025 was the break point. Perpres 110/2025 replaced the 2021 umbrella, cut the link between trading and NDC achievement, introduced a new unit registry, and reopened international sales. Anything written about the Indonesian carbon market before that date describes a system that no longer applies — which is most of what is available.
Entries are given with the Indonesian title as issued and the substance in English. Where the status of an instrument under the new umbrella is genuinely unresolved, it says so; the open questions are collected at the end rather than smoothed over.
02 · Presidential regulations
the umbrella, current and superseded
Perpres 110/2025
President10 Oct 2025In force — current umbrella
Peraturan Presiden Nomor 110 Tahun 2025 tentang Penyelenggaraan Instrumen Nilai Ekonomi Karbon dan Pengendalian Emisi Gas Rumah Kaca Nasional
Implementation of Carbon Economic Value Instruments and National Greenhouse Gas Emission Control. Signed by President Prabowo Subianto; replaces Perpres 98/2021.
What it requires
→Carbon trading may proceed without waiting for Indonesia to achieve its NDC targets — the previous linkage is cut.
→Two trading channels: GHG emission trading (quota against an allowable emissions limit) and GHG emission offset trading.
→Voluntary trading is recognised: business actors not categorised as Entities may sell units from mitigation actions through offset trading.
→A new Carbon Unit Registry System (Sistem Registri Unit Karbon, SRUK) becomes the centralised platform. All carbon trading must be registered in SRUK, and may also be recorded on the exchange.
→International sale of credits from Indonesian projects is permitted again, under stricter standards — lifting the effective four-year moratorium.
→Projects certified under recognised international standards are permitted, provided they also register on the Indonesian system.
For a project developer
This is the instrument to read first. Four things change your project economics: trading no longer waits on the NDC; the export route is open; a Verra or Gold Standard certification is now an asset rather than an obstruction, provided you also sit in the national registry; and the offset pathway is explicitly available to you even if you are not a capped Entity. The compliance sequence for a voluntary unit is fixed — submit the mitigation action design to the relevant ministry for recordation, obtain independent validation, implement, obtain independent verification, submit the verification report; the ministry then recommends issuance and the Minister of Environment issues the SPE-GRK.
The government signed Mutual Recognition Agreements during 2025 with Verra, Gold Standard, Plan Vivo and the Global Carbon Council. Confirm the current list and the terms of each before relying on one.
Perpres 98/2021
President29 Oct 2021Revoked by Perpres 110/2025
Peraturan Presiden Nomor 98 Tahun 2021 tentang Penyelenggaraan Nilai Ekonomi Karbon untuk Pencapaian Target Kontribusi yang Ditetapkan secara Nasional dan Pengendalian Emisi Gas Rumah Kaca dalam Pembangunan Nasional
The original NEK umbrella, signed immediately before COP26 in Glasgow.
What it requires
→Established NEK through three instruments: carbon trading, results-based payment, and a carbon levy.
→Set cap-and-trade and cap-and-tax mechanisms across six sectors — energy, waste, industrial processes and product use, agriculture, forestry, and others as technology develops.
→Required prior ministerial approval for any contractual arrangement transferring an emission reduction certificate into an international market.
For a project developer
Historical, but you still need it. Contracts, MRV arrangements and registry entries written between late 2021 and October 2025 were built on this text, and its approval requirement is the reason the export route was closed in practice. Read it to understand what the transitional provisions of Perpres 110/2025 are transitioning from.
03 · Ministerial regulations
how it operates, sector by sector
Permen LHK 21/2022
Ministry of Environment and Forestry2022In force — verify against Perpres 110/2025
Peraturan Menteri Lingkungan Hidup dan Kehutanan Nomor 21 Tahun 2022 tentang Tata Laksana Penerapan Nilai Ekonomi Karbon
Procedures for the Implementation of Carbon Economic Value.
What it requires
→Detailed the formation of the domestic and international carbon markets under the Perpres 98/2021 framework.
→Set the results-based payment mechanism through BPDLH, the environment fund management agency.
→Governed registration and recording in the national registry, SRN-PPI.
→Provided the operational route for carbon trading, including through the exchange.
For a project developer
The working manual for anyone who registered a project before late 2025 — SRN-PPI entry, MRV expectations and the certificate route all sit here. Its relationship to the new SRUK and to Perpres 110/2025 is the single most important thing to establish before you rely on any procedure in it.
Issued under the now-revoked Perpres 98/2021. Whether it has been amended, replaced or left standing needs confirming.
Permen LHK 7/2023
Ministry of Environment and Forestry2023In force
Peraturan Menteri Lingkungan Hidup dan Kehutanan Nomor 7 Tahun 2023 tentang Tata Cara Perdagangan Karbon Sektor Kehutanan
Procedures for Carbon Trading in the Forestry Sector.
What it requires
→Sets the trading procedure for forestry-sector carbon, the largest source of Indonesian supply.
→Requires validation and verification bodies to be accredited by KAN, the national accreditation committee, under ISO 14065, and registered with the ministry.
For a project developer
If your project is forest or peat, this is your operative regulation. The practical constraint is not the rule but the capacity behind it: roughly twelve accredited VVBs against a pipeline measured in hundreds as of mid-2026. Book verification capacity early and treat the VVB queue as a schedule risk on the critical path, not an administrative step.
Permen LHK 12/2024
Ministry of Environment and Forestry2024In force
Peraturan Menteri Lingkungan Hidup dan Kehutanan Nomor 12 Tahun 2024 tentang Penyelenggaraan Kontribusi yang Ditetapkan secara Nasional dalam Mitigasi Perubahan Iklim
Implementation of Nationally Determined Contributions in Climate Change Mitigation.
What it requires
→Mandates compatible data formats and reporting standards so that domestic and international registry systems can exchange data.
→Frames the alignment of SRN-PPI with global and Paris Agreement crediting mechanism registries, to prevent double counting.
For a project developer
Unglamorous and decisive. Your units cannot be internationally transferred unless the registry chain reconciles, and this is the regulation that sets the data discipline making that possible. Build your monitoring records to its formats from the start; retrofitting a dataset to a registry schema after verification is expensive.
Permen ESDM 16/2022
Ministry of Energy and Mineral Resources2022In force
Peraturan Menteri Energi dan Sumber Daya Mineral Nomor 16 Tahun 2022 tentang Tata Cara Penyelenggaraan Nilai Ekonomi Karbon Subsektor Pembangkit Tenaga Listrik
Procedures for Implementing Carbon Economic Value in the Power Generation Subsector.
What it requires
→Establishes the NEK mechanism for power plants, the first sector placed under an operating emissions cap.
→Sets the allocation, trading and reporting arrangements for generators within that cap.
For a project developer
The compliance market that gives the whole system a genuine buyer. Generators short of their cap must acquire units, and their cost of compliance is the practical ceiling on what any project can charge. If you are selling into the domestic market rather than exporting, this regulation determines your customer’s willingness to pay.
Permenko Marves 5/2022
Coordinating Ministry for Maritime Affairs and Investment2022In force — ministry since restructured
Peraturan Menteri Koordinator Bidang Kemaritiman dan Investasi Nomor 5 Tahun 2022 tentang Struktur dan Tata Kerja Komite Pengarah Penyelenggaraan Nilai Ekonomi Karbon
Structure and Working Arrangements of the Steering Committee for the Implementation of Carbon Economic Value.
What it requires
→Establishes the inter-ministerial steering committee for NEK and its working arrangements.
For a project developer
Institutional, not operational — but it tells you who arbitrates when environment, energy and finance read the framework differently, which in this system they do. Worth knowing before you escalate anything.
The coordinating ministry was restructured after 2024. Confirm which ministry now holds this mandate and whether the committee has been reconstituted.
06 · Needs checking
before this register is relied on
Implementing regulations under Perpres 110/2025
Which of the 2022–24 ministerial regulations survive the new umbrella, which have been amended, and what replaces the rest. Perpres 110/2025 is three months old at the time of writing and its implementing layer was still being issued.
The status of SRN-PPI alongside SRUK
Whether SRUK replaces the national registry for unit-level records or sits beside it, and what a project already recorded in SRN-PPI has to do to migrate.
Carbon tax commencement
Whether the UU 7/2021 carbon tax has commenced in full, at what rate, and across which sectors beyond coal-fired generation. Commencement was deferred from 2022 to 2025; the current position needs confirming with Kemenkeu.
PP 40/2025
Cited in connection with carbon tax implementation. Its title, scope and relationship to UU 7/2021 need verifying before it is listed as an operative instrument.
POJK 22/2023
Cited for securities-firm licensing of carbon intermediaries. Scope and current text to confirm.
Mutual Recognition Agreements
The current list of recognised international standards, the terms of each agreement, and what recognition obliges a project to do in the national system.
Ministerial mandates after restructuring
The environment ministry and the coordinating ministries were reorganised after 2024. Which body now issues and administers each instrument above.
Sectoral coverage beyond energy and forestry
Perpres 98/2021 named six sectors. Whether agriculture, waste and industrial process emissions have operative sectoral regulations, or remain covered only by the umbrella.
Draft and pending instruments
A draft ministerial regulation on NDC implementation was in circulation. Pending instruments are deliberately not listed here — a draft number cited as though it were law is worse than an acknowledged gap.
Regulation numbers and dates above are given as published by their issuing institutions and linked to the official text where the address is known. This register is a reading aid, not legal advice; for a transaction, read the instrument.