Regulation Watch · Environmental Compliance · Indonesia. The regulation applies nationally across NDC sectors and subsectors to domestic and international carbon-unit projects and transactions recorded through the Carbon Unit Registry System.
Indonesia Makes SRUK the Control Layer for Carbon Units
Permen LH/BPLH 10/2026 requires carbon-unit issuance, use and transactions to be recorded through SRUK, with a two-working-day deadline for direct offset trades and sanctions that can cancel units or close registry accounts.
- Published
- Established by the Minister of Environment and Head of the Environmental Control Agency on 2 July 2026 and promulgated on 6 July 2026 in State Bulletin 2026 No. 449.
- Effective
- 6 July 2026. The regulation took effect on promulgation.
- Added to Watch
- 27 October 2026
Who is affected
PT PMA and PT PMDN companies developing, owning, buying, selling or using carbon units; foreign and domestic investors, carbon-project developers, regulated installations, carbon-exchange participants, direct-trade counterparties, international standards and registries, validation and verification bodies, sector ministries, regional governments, financiers, directors, shareholders, and environmental, legal, finance and sustainability teams.
Practical impact
SRUK is now the national control layer for carbon-unit issuance, ownership, use, status and transaction history. The framework covers Indonesian SPE GRK units, units issued under international certification systems, emissions quotas, domestic exchange and direct trades, international transfers, performance-based payments and carbon levies. An offset project must register an account, submit general and technical data and a DRAM or DPP, obtain sector-ministry recognition, complete independent validation and verification, and obtain the required recommendation or approval before units are issued. International uses for another country's NDC or another international mitigation obligation also require authorisation and a corresponding adjustment. A direct offset trade must be recorded in SRUK within two working days after the transaction.
Late discovery: Permen LH/BPLH 10/2026 was established on 2 July, promulgated on 6 July 2026 and took effect on promulgation. The official national database records it in State Bulletin 2026 No. 449, while the Environment Ministry's JDIH lists the instrument as current.
The regulation makes SRUK the national record for carbon-unit issuance, ownership, use, status and transaction history. It covers domestic and international trading through the carbon exchange or direct contracts, Indonesian SPE GRK units, units issued under international certification systems, emissions quotas, performance-based payments and carbon levies. SRUK must connect with the national climate registry, the carbon exchange and other national or international registries.
For an offset project, the responsible business or activity registers an account, supplies general and technical data and submits a DRAM or DPP. The responsible sector minister then assesses the project's scope, methodology, certification route, entity legality, intended unit use and supporting evidence. Recognition is followed by independent validation, implementation reporting, independent verification and a sector recommendation or approval before the unit is issued.
International use depends on its purpose. A unit used for another country's NDC or another international mitigation obligation needs ministerial authorisation and a corresponding adjustment. A voluntary international use outside those purposes does not require that authorisation or adjustment, but the project, issuance, ownership, use and transaction must still follow the relevant sector approval and SRUK recording route.
The transaction deadline is strict. A direct offset trade must be recorded in SRUK within two working days after the transaction, including the parties, unique unit code, volume and valid transfer or contractual evidence. Article 32 states that a transaction missing that deadline is invalid and is not recognised for Indonesia's NDC. Exchange trades must interoperate with SRUK in real time.
The transitional rule helps older projects but does not remove oversight. An offset activity registered before Presidential Regulation 110/2025 does not need a new notice recognising its DRAM or DPP, but its unit issuance still needs the sector minister's recommendation or approval. Where an international registry is not interoperable, the required record must be entered through SRUK within two working days after the verification report, unit certificate or transaction.
Enforcement can affect the asset itself. A breach may lead to cancellation of an issued SPE GRK unit, permanent closure of the registry account, an obligation to restore emissions or buy replacement units equal to the manipulated amount, and separate sector-ministry administrative sanctions. Project contracts and financing documents should therefore allocate responsibility for registry access, late recording, invalidity, cancellation, replacement units and double-counting failures.
Required action
- Map every carbon project, unit, account, exchange position, direct contract and international-standard record to the responsible SRUK user and confirm that ownership, location, vintage, methodology, status and intended use are consistent across systems.
- For a new offset project, register the account and submit the required general data, technical data and DRAM or DPP before validation, then obtain sector-ministry recognition, independent validation and verification and the applicable issuance recommendation or approval.
- Before signing an international transfer, determine whether the unit will be used for another country's NDC or another international mitigation obligation and, if so, obtain sector-ministry recommendation, ministerial authorisation and the corresponding adjustment.
- Record every direct offset transaction in SRUK within two working days and retain the parties' identities, unique unit codes, volume, transfer evidence, contract, ownership history and intended unit use.
- For an international standard that is not yet interoperable with SRUK, coordinate the manual registry record and preserve the verification report, unit certificate and transaction data needed for the two-working-day transitional recording rule.
- Add controls against double issuance, double claiming and double use, including geographic and methodology checks, valid legal allocation of units, retirement controls and contract terms for cancellation, replacement units and registry failures.