← Back to Regulation Watch

Regulation Watch · Environmental Compliance · Indonesia. Decision 2709/2026 designates 5,984 PROPER participants nationwide for the 2025–2026 evaluation period. Its official appendix includes numerous Bali businesses, including hotels and resorts, I Gusti Ngurah Rai International Airport, the Ngurah Rai aviation-fuel terminal and other regulated facilities.

PROPER Participants Have Until 9 October to Challenge Provisional Ratings

KLH/BPLH has sent provisional 2025–2026 PROPER ratings to the 5,984 participants designated under Decision 2709/2026 and will accept objections through 9 October 2026, including from listed Bali hotels, resorts, infrastructure and fuel operators.

Published
Decision 2709/2026 was established in Jakarta on 18 June 2026 and published in the official PROPER decision database on 1 August 2026. The instrument is an administrative ministerial decision and does not identify a separate State Gazette or promulgation date. The official SIMPEL portal posted the evaluator-objection schedule on 7 October 2026.
Effective
18 June 2026. The decision states that it took effect on the date it was established. The official SIMPEL portal states that the 2025–2026 evaluation began on 10 August 2026 and that provisional ratings have now been sent.
Added to Watch
8 October 2026

Who is affected

Companies and facilities expressly listed in Decision 2709/2026; their Indonesian and foreign shareholders, directors and management; environmental, legal, compliance and sustainability teams; and investors, lenders, operators and hotel or infrastructure owners whose risk assessment may be affected by a PROPER rating. It does not apply merely because a company operates in Indonesia; the company or facility must be a designated participant.

Practical impact

Every designated participant should now have a provisional PROPER report in SIMPEL. If the company disputes the evaluator's findings or rating, it has only until 9 October 2026 to use the SANGGAHAN process. The decision makes participants subject to evaluation under the PROPER framework and assigns the evaluator as KLH/BPLH, a regional environmental authority or a KLH/BPLH regional control centre. A provisional rating is not the final annual rating, but failing to challenge a factual or evidentiary error during the published window can leave the company without this scheduled opportunity to correct the record before finalization.

The Ministry of Environment and Environmental Control Agency established Decision 2709/2026 on 18 June 2026 and made it effective that day. The decision designates 5,984 companies and facilities for the 2025–2026 PROPER environmental-performance evaluation and assigns each participant to KLH/BPLH, a regional environmental authority or a KLH/BPLH regional control centre for evaluation.

The official SIMPEL portal now states that provisional reports have been sent and that participants may submit an objection through 9 October 2026. It also directs participants to monitor the SEMENTARA and SANGGAHAN menus. This is a short operational deadline, not a new environmental-permit filing window and not an extension of the separate PROPER reporting deadline that closed on 9 August.

The participant list has direct Bali relevance. It includes hotels and resorts in Badung and other Bali locations, I Gusti Ngurah Rai International Airport, the Ngurah Rai aviation-fuel terminal, drinking-water and other regulated facilities. Foreign ownership does not change the process: the listed Indonesian company or facility must review and, where necessary, challenge its own provisional report.

A sound objection should identify the precise finding, explain the factual or technical error and attach contemporaneous evidence that was valid for the evaluated period. Environmental approvals, monitoring data, accredited laboratory results, waste and hazardous-material records, corrective-action evidence and prior SIMPEL submissions should be reconciled before filing. A general disagreement without documentary support is unlikely to resolve an evidentiary gap.

The portal does not state a closing hour for the 9 October objection deadline. Participants should therefore file early, retain the timestamped receipt and monitor the evaluator schedule and subsequent SIMPEL status. If the account is inaccessible or the provisional report is missing, the company should contact its assigned evaluator immediately and keep written evidence of the issue and response.

PROPER is a public environmental-performance rating mechanism. A provisional score is not yet the final annual rating, and the deadline notice does not itself impose a fine. The practical risk is that an uncorrected finding proceeds into the final rating and may create reputational, commercial and regulatory consequences or expose an underlying environmental breach that is enforceable under separate law.

Required action

  • Confirm that the relevant company or facility appears in the official appendix to Decision 2709/2026; use the legal name, SIMPEL ID, sector, location and assigned evaluator shown in the decision.
  • Log in to SIMPEL immediately and review the provisional report and the SEMENTARA and SANGGAHAN menus for every listed facility, rather than relying on an email alert or a prior-period rating.
  • Reconcile each finding against the environmental approval, permits, monitoring and laboratory records, waste manifests, emissions and wastewater data, incident records, prior submissions and correspondence for the evaluated period.
  • If a finding is disputed, prepare a concise issue-by-issue objection supported by dated source documents and submit it through the designated SIMPEL objection route no later than 9 October 2026.
  • Retain the submitted objection, every attachment, the system receipt or timestamp and any evaluator correspondence, and monitor the official evaluator schedule and SIMPEL status until the objection is resolved.
  • Escalate any red or black provisional finding, missing report, inaccessible account or material data inconsistency to company management and the assigned evaluator without waiting for the final rating.

Start the Conversation

Need help applying this change?

Discuss how the regulation affects your company, investment, property, or compliance position.

Discuss Your Business