New Forestry Carbon Trading Framework

Regulation

MOF Reg 6/2026

Issued

13 April 2026

Previous Regulation

MOEF Reg 7/2023

Sector

Forestry Carbon Trading

Why Does This Matter?

This regulation affects anyone involved in Indonesia's forestry carbon market, including:

•         Companies looking to purchase or develop carbon offsets from Indonesian forests

•         Forest concession holders, social forestry groups, and customary communities

•         Carbon project developers and intermediaries

•         International buyers

Aspect

PR 98/2021

PR 110/2025

Registry system

Uses only the SRN PPI, as the single national registry for NDC

Uses SRN PPI together with SRUK a dedicated carbon unit trading registry added under SRN

International trading

Provided two pathways: SPE and MRA (SPE + international registry)

Provided two pathways: Authorized (with corresponding adjustment) and Non-authorized (voluntary).

NDC linkage

Carbon trading through international markets does not reduce NDC achievement by 2030

Carbon trading can proceed without waiting for NDC achievement, effectively enabling a continuous exchange process

Cross-border rules

International trading may occur at any time without waiting for NDC target

The authorized pathway requires government approval through Corresponding Adjustmeny, while the voluntary pathway does not require Corresponding Adjustment.

Carbon body

Governance spread across ministries

Establishes the Steering Committee on Carbon Economic Value (Komite Pengarah Nilai Ekonomi Karbon), under the Coordinating Minister for Food Affairs.

Key Shift in a Nutshell

Under PR 98/2021: Trading required specific MRA-based pathways and was constrained by NDC timeline.

Under PR 110/2025:  Carbon trading is no longer linked to NDC timelines and the distinction now lies between Authorized and Voluntary transactions.

• Authorized transfers count toward the buying country's NDC and require Indonesian government approval
• Voluntary transfers offer greater flexibility as they do not require Corresponding Adjustment and are excluded from NDC accounting
• MOF Reg 6/2026 operationalizes this PR 110/2025 architecture specifically for the forestry sector.

Previous Regulation (MOEF Reg 7/2023)

Allowed TWO mechanisms:

1. Emissions Trading (cap-and-trade-style)

2. GHG Emissions Offsetting

New Regulation (MOF Reg 6/2026)

Allows ONLY ONE mechanism:

GHG Emissions Offsetting (Offset GHG Emissions)

New Registration Platform: SRUK Replaces SRN PPI

All forestry carbon projects must now be registered on the SRUK

• During the transition, registration continues through the Ministry of Forestry's internal system
• SRUK aligns with the broader NEK framework under PR 110/2025
• Projects must ensure documents are migrated to SRUK once it is operational
• Indonesia's national SRUK is set to go live by end of June 2026, with large-scale trading expected to begin July 2026. The government confirmed SRUK will ensure transparency and prevent double counting. 70 million tonnes of CO2 are ready to be traded.

Aspect

SPE GRK

Non-SPE GRK

Authorisation

Recommendation of MOF and subsequently request issuance to the Ministry of Environment (Article 11 and 18)

Approval from MOF

Application document

DRAM and recommendation for the issuance of SPE GRK carbon units

DPP and approval for the issuance of Non-SPE GRK carbon units

Additional requirements

Businesses applying for the above-outlined recommendations or approvals must also enclose relevant reports that address the following specific matters:

1. Validation of DRAM or DPP through an independent validation agency;
2. Implementation of climate change mitigation actions in accordance with the DRAM or DPP;
3. Verification of climate change mitigation action achievements through an independent verification agency;
4. Results of the verification of climate change mitigation action achievements; and
5. Relevant supporting data.

Submission platform

SRUK

Involvement of third-party

Business actors (excluding those that are being assisted by registered partners or assistants) may involve input from experts with experience in the Utilization of Forestry Carbon Environmental Services and/or technical personnel working in the Utilization of Forestry Carbon Environmental Services during the preparation of their DRAM and/or DPP.

Examination period

14 business days (once complete)

Validity period

Not regulated

6 months

No.

Type of Participant

1

PBPH holders and other forest utilization rights

2

Social forestry approval holders

3

Customary law communities (Masyarakat Hukum Adat) with legally recognized forest status

4

Private forest rights holders (Hutan Hak)

5

PB-PJL Karbon holders

Assistance Requirement

MOF Reg 6/2026 imposes an assistance requirement for certain participant categories, namely holders of Social Forestry Management Approvals, recognized customary law communities, and PB-PJL Karbon holders. These entities must be accompanied by registered facilitators or partners when participating in carbon trading activities. While the regulation does not comprehensively define the role of such facilitators, they are generally expected to provide technical and administrative support, including carbon measurement, project documentation, implementation planning, and market access.

Aspect

Voluntary Market

Corresponding Adjustment

SPE-GRK

Under PR 110/2025 stipulates that GHG emission offset trading that is not used for the fulfilment of the NDC and/or other international obligations, whether conducted under Article 6.4 of the Paris Agreement or through voluntary GHG emission offset trading does not require authorization and Corresponding Adjustment.

PR 110/2025 stipulates that the following transactions require authorization and Corresponding Adjustment:

(a)       internationally linked GHG emission trading;

(b)       GHG emission offset trading conducted under Articles 6.2 and 6.4 of the Paris Agreement; and

(c)       voluntary GHG emission offset trading conducted to fulfil other international obligations.

The Minister of Environment grants the authorization based on the recommendation of the relevant minister.

Non-SPE GRK

Under MOF Reg 21/2026 requires business actors applying for the issuance of non-SPE GRK by international standards to submit:

(a)        validation of the DPP by an independent validation body;

(b)        evidence of implementation of climate change mitigation actions in accordance with the DPP;

(c)         verification of mitigation achievement by an independent verification body;

(d)        verification reports; and

(e)        supporting data.

The MOF grants approval for the issuance of non-SPE GRK for a validity period of six months.

Under MOF Reg 21/2026 requires business actors conducting international carbon trading that requires authorization and Corresponding Adjustment to:

(a)    submit an application for recommendation to the MOF;

(b)    attach cooperation documents relating to the GHG emission offset transaction; and

(c)     applying authorization and Corresponding Adjustment from the Minister of Environment after obtaining the recommendation from the Minister.

In assessing the application, the MOF considers:

(a)    the amount of carbon units proposed for trading; and

(b)    Indonesia’s NDC achievement requirements

1

Permanent Production Forest including convertible production forest and/or utilization blocks of Protected Forest Areas

2

Utilization Zones/Blocks of Nature Conservation Areas and Hunting Parks

3

Customary Forests (Hutan Adat) — communities must have legally recognized customary status

4

Private Forests (Hutan Hak)

5

State land outside designated forest areas

6 (six) month adjustment period

Deadline: 13 October 2026.

All existing projects at any of the following stages must report and comply:

•        Validation stage

•        Implementation stage

•        Verification stage

•        Pre-transaction stage

•        Existing carbon unit holders

1 (one) year deadline for new roadmap

A new forestry sector carbon roadmap must be issued within 1 year of enactment.

In the meantime:

• May refer to MOEF Decree SK.1027/MENLHK/PHL/KUM.1/9/2023
• Registration continues through MOF’s internal system until SRUK is ready

Governance  |  January 2026

Proposal: A Dedicated National Carbon Body

Presidential Special Envoy for Trade Mari Elka Pangestu has proposed the creation of a dedicated Carbon Authority to coordinate NEK implementation, green investment, and cross-sector carbon policy. She noted that current governance structure is spread across multiple ministries under Coordinating Minister for Food Affairs. This may create inconsistency and investor uncertainty.

Global  |  January 2026

Indonesia Joins Coalition to Grow Carbon Markets

On 20 January 2026, Indonesia formally joined the Coalition to Grow Carbon Markets as its 11th government member, announced by Forestry Minister Raja Juli Antoni in London alongside the UK-Indonesia Strategic Partnership. The coalition aims to unlock over USD 50 billion in climate finance annually by 2030.

FINANCING & CARBON MARKETS | APRIL 2026

DevvStream Secures Exclusive PLN IP Solar Carbon Credit Partnership.

DevvStream Corp., a carbon management firm focused on monetizing environmental assets such as carbon credits, announced an exclusive agreement with PT PLN Indonesia Power, a sub-holding of PT PLN, to manage and commercialize carbon credits from PLN IP’s solar portfolio in Indonesia. The mandate covers 45 solar power plants and includes end-to-end services from validation and certification to registration and liquidation, under a revenue-sharing structure aligned with Indonesia’s clean energy transition.

Financial Regulation  |  April 2026

OJK Revising POJK 14/2023 Carbon Trading Rules

OJK Chair Friderica Widyasari Dewi confirmed OJK is revising POJK No. 14 of 2023 on Carbon Trading through the IDXCarbon, with the revised regulation targeted for completion by June 2026. The revision is co-developed with IDX and aligns with MOF Reg 6/2026 and PR 110/2025.

Market Entry Companies

• If you are new to Indonesia's forestry carbon market:
• Verify your eligibility — confirm which participant category you fall under
• Identify your land area — check whether your forest area qualifies under the new rules
• Determine your credit type — domestic (SPE GRK) or international (non-SPE GRK)?
• Engage a facilitator early — especially for social forestry or customary community categories
• Prepare DRAM or DPP — engage specialists familiar with Indonesian forestry carbon standards
• Plan for SRUK — ensure your document management can interface with SRUK from June 2026

Advanced Project Developers

If you have active or planned projects:

• Review your current project status — identify which transition window applies
• Update project documents — DRAM/DPP must align with MOF Reg 6/2026
• Audit contractual arrangements — review liability allocation where third-party operators are involved
• Assess compliance history — the Minister may consider sanctions record when granting recommendations
• Monitor SRUK and OJK — SRUK goes live June 2026; revised POJK 14 expected same month

Term

Meaning

CA

Corresponding Adjustment

DPP

Project Design Document (Dokumen Perencanaan Proyek)

DRAM

Mitigation Action Design Document (Dokumen Rancangan Aksi Mitigasi Perubahan Iklim)

GHG

Greenhouse Gas

IDXCarbon

Bursa Efek Karbon

MOF

Ministry of Forestry (Kementerian Kehutanan)

MOF Reg 6/2026

Ministry of Forestry Regulation No. 6 of 2026 on Procedures for Carbon Trading Through GHG Emissions Offsetting Within the Forestry Sector

MOEF Reg 7/2023

Ministry of Environment and Forestry Regulation No. 7 of 2023 on Procedures for Carbon Trading in the Forestry Sector

MRA

Mutual Recognition Arrangement

NDC

Nationally Determined Contribution

NEK

Carbon Economic Value (Nilai Ekonomi Karbon)

Non-SPE GRK

Internationally certified carbon units (e.g. Verra VCS, Gold Standard, Plan Vivo)

PBPH

Forest Utilization Business License (Perizinan Berusaha Pemanfaatan Hutan)

PB-PJL Karbon

Carbon Environmental Services Utilization Business License (Perizinan Berusaha Pemanfaatan Jasa Lingkungan Karbon)

POJK 14/2023

Financial Services Authority Regulation No. 14 of 2023 on Carbon Trading through Carbon Exchange

SPE GRK

Greenhouse Gas Emission Reduction Certificates (Sertifikat Pengurangan Emisi Gas Rumah Kaca)

SRN PPI

National Registry System for Climate Change Mitigation (Sistem Registri Nasional Pengendalian Perubahan Iklim)

SRUK

Carbon Unit Registry System (Sisterm Registri Unit Karbon)

UNFCCC

United Nations Framework Convention on Climate Change

Verra VCS

Verra Verified Carbon Standard