Reference

Indonesia Carbon Market Regulations

The instruments that govern carbon pricing and trading, what each one requires, and what it means for a project developer. Current to Perpres 110/2025.

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.

01 · Laws
the fiscal and financial-market authority
UU 7/2021 DPR / President29 Oct 2021In force
Undang-Undang Nomor 7 Tahun 2021 tentang Harmonisasi Peraturan Perpajakan
Law on the Harmonisation of Tax Regulations — the carbon tax cluster, Chapter VI, Article 13.
What it requires
A carbon tax on goods and activities producing carbon emissions, imposed to control greenhouse gas emissions in support of Indonesia’s NDC (Art. 13(1)).
The rate is set at or above the prevailing carbon market price (Art. 13(8)–(9)), which ties fiscal policy to the exchange rather than to a fixed schedule.
Initial application to coal-fired steam power plants at Rp 30 per kilogram of CO₂e.
For a project developer

This is the demand side of your market. Because the tax rate floors at the market price, a credible exchange price is what makes the tax bite — and a covered emitter facing the tax is a buyer for your units. Commencement was set for 1 April 2022, then deferred; treat the timetable, not the law, as the open question.

Enacted 2021; commencement deferred to 2025 on grounds of post-pandemic conditions and infrastructure readiness. Whether it has commenced in full needs checking against the current Kemenkeu position.

Official text, JDIH BPK →
UU 4/2023 DPR / President2023In force
Undang-Undang Nomor 4 Tahun 2023 tentang Pengembangan dan Penguatan Sektor Keuangan (P2SK)
Law on the Development and Strengthening of the Financial Sector.
What it requires
Carbon trading through a carbon exchange is classified as a financial transaction in the capital market sector.
OJK accordingly holds the authority to organise and supervise the domestic carbon market.
The carbon exchange is defined as a system that regulates carbon trading and records ownership of carbon units.
For a project developer

The consequence is jurisdictional and it matters: the moment your units reach the exchange they are a securities-law object, not only an environmental one. Intermediation, disclosure and licensing follow capital-market rules, which is why POJK 14/2023 exists at all.

Official text, JDIH BPK →
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.

Official text, JDIH BPK →
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.

Official text, JDIH BPK →
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.

Official text, JDIH BPK →
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.

Official text, JDIH BPK →
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.

Official text, JDIH BPK →
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.

Official text, JDIH BPK →
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.

04 · Financial services authority
the exchange and its intermediaries
POJK 14/2023 Financial Services Authority (OJK)2023In force
Peraturan Otoritas Jasa Keuangan Nomor 14 Tahun 2023 tentang Perdagangan Karbon melalui Bursa Karbon
Carbon Trading Through the Carbon Exchange.
What it requires
Designates OJK as the organiser and supervisor of the carbon exchange, and sets its licensing regime.
Requires a carbon exchange operator to hold Rp 100 billion in paid-up capital, none of it from borrowing.
Sets the mechanism for trading carbon units and the exchange’s integration with the national registry.
Brings brokerage and proprietary trading in carbon units within the securities-firm approval regime.
For a project developer

Read this as market infrastructure rather than project regulation. It determines who may stand between you and a buyer, and on what terms. The exchange records ownership and transfer — IDX Carbon in practice, connected directly to SRN-PPI and now SRUK — so your unit’s legal title and its registry entry have to agree. If you intend to intermediate rather than develop, OJK licensing is the long pole: practitioners report nine to fourteen months from incorporation to first trade, and the constraint is the OJK review, not company registration.

POJK 22/2023 is also cited in relation to securities-firm licensing for carbon intermediaries. Confirm its scope before relying on it.

Official text, OJK →
05 · International framework
what determines whether a unit can be exported
Paris Agreement, Article 6 UNFCCCRules finalised COP29, Nov 2024Operational
Persetujuan Paris, Pasal 6
Cooperative implementation — Article 6.2 bilateral transfers and the Article 6.4 Paris Agreement Crediting Mechanism.
What it requires
Article 6.2 permits trade in Internationally Transferred Mitigation Outcomes (ITMOs) between countries, with corresponding adjustments to prevent double counting.
Article 6.4 establishes a centralised crediting mechanism with its own methodologies and registry.
National registries must interconnect with the international and PACM registries.
CDM afforestation and reforestation projects could transfer into the new mechanism where requests were submitted by 31 December 2025 and the mechanism’s rules were met.
For a project developer

The export premium sits here, and so does the paperwork. An authorised ITMO commands a different price from an unauthorised voluntary credit, because the host country gives up the reduction against its own target. Indonesia is building the connective tissue — an Article 6 methodology panel and a national nesting framework — so a project designed today should be designed to be nestable and authorisable even if you intend to sell voluntary first. Verra said in July 2026 it expects to issue at least 20 million tonnes CO₂e from three Indonesian forestry projects under the updated rules, which is the clearest signal yet that the route works.

UNFCCC →
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.

Context

The Carbon Market

What a carbon market is, why an instrument that abates nothing itself is strategic — it decides where the reductions happen, and moves capital to the cheapest real abatement — and how far Indonesia has got in building one.

Read the context →