Peraturan Presiden 110/2025 (Peraturan Presiden Nomor 110 Tahun 2025 tentang Penyelenggaraan Instrumen Nilai Ekonomi Karbon dan Pengendalian Emisi Gas Rumah Kaca Nasional) is an Indonesian presidential regulation on the implementation of carbon pricing instruments, known in Indonesian law as nilai ekonomi karbon (NEK, "economic value of carbon"), and on the control of national greenhouse gas emissions. It was signed by President Prabowo Subianto and promulgated on 10 October 2025, in Lembaran Negara 2025 No. 172, and took effect on promulgation.^[1][2] It replaced Peraturan Presiden 98/2021, which its preamble describes as no longer suited to legal and social needs, and is the principal instrument of carbon trading and climate regulation in Indonesia.^[3][4]

The regulation organises the field in seven parts: carbon allocation, the preparation and setting of Indonesia's Nationally Determined Contribution (NDC) under the Paris Agreement, the operation of the carbon pricing instruments, a transparency framework, monitoring and evaluation, guidance and funding, and a steering committee.^[5] It introduces a national carbon allocation from which emission caps are derived, names four carbon pricing instruments (carbon trading, results-based payment, a carbon levy, and other instruments), and sets up a registry of carbon units separate from the existing national climate registry.^[6][7][8]

Its transitional provisions gave existing action plans, holders of carbon units and international agreements one year to adjust, and required its own implementing regulations within one year of promulgation.^[9][10] In 2026 the Financial Services Authority amended its carbon exchange rules to align them with the regulation. CRPG's regulatory tracker published a five-part comparison of the regulation with its predecessor in November 2025 and two further analyses.^{[11][12][13][14]}

¶ Background

Perpres 110/2025 was issued under Pasal 4 ayat (1) of the Constitution, UU 32/2009 on environmental protection and management, and UU 25/2004 on the national development planning system.^[3:1] Its preamble states that climate change control must proceed in line with national economic development on the principle of sustainable development, and that Perpres 98/2021, the earlier regulation on the economic value of carbon, had to be replaced.^[3:2]

Perpres 98/2021 had defined Hak Atas Karbon (carbon rights) as the state's control over carbon and recorded mitigation actions and carbon trading in the national climate change control registry, SRN PPI.^[15] The terms Alokasi Karbon (carbon allocation), Sistem Registri Unit Karbon (carbon unit registry) and Corresponding Adjustment do not appear in the held text of the 2021 regulation; all three are defined in Pasal 1 of Perpres 110/2025.^[15:1][6:1] CRPG's comparison series read these changes as a move from a model based on state control of carbon to one based on allocation, and examined the new trading, authorisation, documentation and registry rules in turn.^{[12:1][16][17][18][19]}

¶ Carbon allocation and the NDC

Pasal 1 angka 2 defines carbon allocation as the amount of carbon dioxide equivalent emissions permitted over a certain period in accordance with national capacity. The emission cap (Batas Atas Emisi GRK) is defined in angka 14 as the highest amount of emissions permitted and set on the basis of the carbon allocation, and the carbon reserve (Karbon Cadangan) in angka 17 as carbon allocated at national level to control the risk of missing the NDC target.^[6:2] Under Pasal 3 the allocation is drawn up from periodic sectoral emission inventory data, the long-term and medium-term national development plans, and economic and climate considerations, taking the carbon reserve into account.^[20]

The allocation is prepared with the ministers responsible for forestry, environment, energy, industry, agriculture, finance and national development planning, and set jointly by the relevant ministers after coordination with the steering committee. Pasal 5 allows it to be changed by joint decision where development policy, activity data, emission factors or methodology change, and Pasal 6 makes the adopted allocation the basis for planning and setting the NDC.^[20:1] The NDC itself is carried out through mitigation and adaptation, following a roadmap that the Minister of Environment is to regulate further.^[21]

¶ Mitigation and adaptation

Mitigation proceeds through planning, implementation, and monitoring and evaluation, carried out by ministries and agencies, regional governments, businesses and communities, and coordinated by the minister responsible for the environment.^[22] Pasal 9 lists the mitigation sectors as energy, waste, industrial processes and product use, agriculture, forestry, and marine affairs and fisheries, with sub-sectors including power generation, oil and gas, transport, buildings, solid and liquid waste, rice cultivation, livestock, plantations, peat and mangrove management and blue carbon.^[22:1]

Adaptation follows the same three stages, carried out by ministries at national level, by governors in the provinces and by regents and mayors in the regencies and cities. Pasal 36 names food, water, energy, health and ecosystem resilience as the adaptation fields, and Pasal 37 assigns adaptation in marine affairs and fisheries to the ministry for that sector.^[23]

¶ Carbon pricing instruments

Pasal 55 lists the instruments as carbon trading (Perdagangan Karbon), results-based payment (Pembayaran Berbasis Kinerja), the carbon levy (Pungutan Atas Karbon) and other instruments consistent with science, technology and legislation, all intended to support the NDC target. Emission reductions achieved through offsets count towards the NDC, and the minister must include them unless a corresponding adjustment has been issued under the United Nations Framework Convention on Climate Change.^[7:1]

¶ Carbon trading

Carbon trading may proceed before the NDC target is reached, through a carbon exchange or by direct trade, and every trade must be recorded in the carbon unit registry (SRUK).^[24] Domestic trading comprises emissions trading and offsetting. Emissions trading is run by the minister for each sector, who designates the regulated installations (Instalasi yang Diatur), sets their caps on the basis of the carbon allocation, fixes emission quotas and determines what share of a cap may be met with offsets. An installation must keep within its cap through mitigation, by buying quotas from other installations or by buying offsets; under Pasal 63 ayat (3), one that exceeds its cap must pay carbon tax.^[25]

Businesses outside the regulated installations may sell carbon units from mitigation actions as offsets. To obtain them they submit either a Dokumen Rancangan Aksi Mitigasi (DRAM), a design document meeting government requirements, or a Dokumen Perencanaan Proyek (DPP), a project document meeting an international standard, and pass independent validation and verification.^[6:3][26] The Minister of Environment issues units certified as emission reduction certificates (SPE GRK) on the recommendation of the sectoral minister, while non-SPE GRK units are issued by international standards with the sectoral minister's approval; both are recorded in SRUK, which Pasal 65 ayat (8) requires to run on a decentralised network that is transparent, traceable, real-time and able to connect with other registries.^[26:1]

International trading is divided by Pasal 68 into trade that requires an authorisation (Otorisasi) and a corresponding adjustment, covering internationally linked emissions trading, offsets meeting Article 6.2 and 6.4 of the Paris Agreement, and voluntary offsets used for other international obligations, and trade that requires neither because the units are not used towards an NDC or an international obligation. Authorisation is granted by the Minister of Environment on the recommendation of the sectoral minister.^[6:4][27] Pasal 69 allows domestic carbon trading to be connected to international carbon markets.^[27:1]

¶ Results-based payment and the carbon levy

Results-based payment rewards verified mitigation or adaptation results at international, national or provincial level, and under Pasal 70 ayat (3) does not transfer ownership of carbon.^[28] The carbon levy takes the form of central or regional taxation, customs and excise, or other state levies based on carbon content, emission potential, emissions or mitigation performance; its policy is formulated by the finance minister.^[29] Funds and benefit-sharing from all three instruments may be managed by the institution that manages environmental funds or another designated institution.^[29:1]

¶ Transparency framework

Pasal 75 requires progress towards the NDC to be accountable through measurement, reporting and verification (MRV), the national climate change control registry (SRN PPI), the carbon unit registry (SRUK), and SPE GRK and non-SPE GRK certification.^[8:1] Pasal 1 separates the two registries: SRN PPI holds data on climate actions and resources at the level of the NDC, while SRUK holds data on carbon units at the level of the pricing instruments.^[6:5] Those responsible for mitigation and adaptation actions must record them in SRN PPI, and the records are used, among other things, to avoid double counting.^[30] An SPE GRK is issued after registration in SRUK and independent verification, cannot be issued from unused emission quota, and is withheld where a business has not reported its measurements in SRUK.^[31]

¶ Steering committee and oversight

Pasal 96 establishes a steering committee to direct policy, lead coordination, and supervise and evaluate the carbon pricing instruments and emission control. It is chaired by the Coordinating Minister for Food, with the Coordinating Ministers for Economic Affairs and for Infrastructure and Regional Development as vice-chairs; its members include the Chair of the Board of Commissioners of the Financial Services Authority, whose membership does not reduce that authority's independence. The committee reports to the President at least once a year.^[32] Monitoring and evaluation run from businesses through regents, mayors and governors to the minister, who with the sectoral ministers prepares a joint annual report to the President.^[33] Funding may come from the state and regional budgets, from emitting businesses taking part in the instruments, from benefit-sharing allocations, and from other lawful sources.^[34]

¶ Transitional and final provisions

Pasal 97 to 99 give one year from promulgation for national and regional greenhouse gas action plans to be adjusted, for businesses holding carbon units not yet traded or used in results-based payment to comply with the new rules, and for international agreements on carbon pricing to be adjusted.^[9:1] Pasal 100 keeps in force the implementing regulations of Perpres 61/2011 on the national action plan, Perpres 71/2011 on greenhouse gas inventories and Perpres 98/2021 so far as they do not conflict with the new regulation, and Pasal 101 revokes Perpres 98/2021.^[35][4:1]

¶ Implementation

The Financial Services Authority (Otoritas Jasa Keuangan, OJK) issued POJK 10/2026, signed on 2 July 2026, to amend its 2023 carbon exchange regulation so that it would be in line with Perpres 110/2025. The amendment replaced the requirement to record exchange-traded units in SRN PPI with a requirement to record them in SRUK, and allowed units recorded in a ministry's electronic system to be traded for up to three months until SRUK became operational.^[11:1] A separate OJK regulation on incidental reporting, POJK 9/2026, applies to reporters in the carbon exchange sector alongside the capital market and derivatives sectors.^[36]

¶ See also

• Permen LHK 21/2022
• PP 26/2025
• Climate change bill of Indonesia
• Financial sector regulation in Indonesia

¶ External links

• Perpres No. 110 Tahun 2025 (JDIH BPK)

¶ References