Regulation Watch · Environmental Compliance · Indonesia, including Bali
Waste-Sector Carbon Trading Must Run Through SRUK
Permen LH/BPLH 11/2026 creates the operating route for domestic and international carbon trading from industrial solid waste, industrial and domestic wastewater, and domestic solid waste, with project validation, environmental-compliance screening, government approval, and SRUK recording.
- Published
- Established on 12 August and promulgated on 14 August 2026 in State Bulletin 2026 No. 569.
- Effective
- 14 August 2026
- Added to Watch
- 17 September 2026
Who is affected
Indonesian and foreign investors, PT PMA companies, waste-management and wastewater businesses, industrial facilities, landfill, recycling, composting and waste-to-energy operators, hospitality or property groups developing waste-sector mitigation projects, regulated installations, carbon-project developers and aggregators, validation and verification bodies, carbon-unit buyers and sellers, and parties planning domestic or cross-border carbon transactions from the waste sector.
Practical impact
The regulation provides the sector-specific route for carbon trading from industrial solid waste, industrial and domestic wastewater, and domestic solid waste. Eligible private participants must be lawful business entities with a mitigation obligation and the capacity to manage the relevant assets, technology, or facilities, or partner with a qualified business. Domestic emission trading and offsets, as well as international transactions, must follow the applicable project-document, validation, verification, issuance, approval or authorisation, and SRUK recording stages. A current environmental sanction or poor compliance history can block carbon-unit issuance.
Late discovery: Permen LH/BPLH 11/2026 was established on 12 August, promulgated as State Bulletin 2026 No. 569 on 14 August, and took effect on the promulgation date. It is now actionable because the official national database confirms the final promulgation identity and the Ministry's JDIH lists the instrument as current.
The regulation covers carbon trading from three waste subsectors: industrial solid waste, industrial and domestic wastewater, and domestic solid waste. Trading may occur through the Indonesian carbon exchange or directly, but unit use and transactions must be integrated with the Carbon Unit Registry System (SRUK). The framework covers domestic emissions trading and offsets, plus international transactions with or without authorisation and corresponding adjustment.
Private participation is not open merely because a business handles waste. The participant must be a lawful business entity with a mitigation obligation and the capacity to manage the relevant mitigation assets, technology, or facilities. A business without that capacity may cooperate with another lawful and capable business. Project ownership, contractual rights, benefit sharing, and the responsibility for SRUK filings should therefore be settled before investment or sales commitments are signed.
For a new offset project, the operator submits a DRAM or DPP through SRUK, obtains independent validation, performs the mitigation action, verifies the achieved reductions, and applies for a recommendation or approval to issue carbon units. The Ministry screens the applicant's environmental-compliance history and current sanction status. A non-compliant history or active environmental sanction is a stated ground for rejection, while an approved issuance letter remains valid for six months.
International sales require a transaction-by-transaction classification. Transfers used for another country's NDC or other international mitigation obligations need authorisation and corresponding adjustment; even transfers outside those uses require ministerial approval through SRUK, confirmation of unit status, recording, and reporting. Existing projects registered before the regulation are excused from obtaining a new DRAM or DPP acknowledgement, but still need the relevant issuance recommendation or approval and must observe the transitional SRUK recording rule.
Required action
- Before marketing a waste-sector carbon project or carbon units, confirm that the activity falls within the regulation's waste subsectors and that the project owner has the required business legality, mitigation responsibility, asset or technology capacity, environmental approvals, and documented rights over the project and units.
- For a new offset project, prepare and submit the DRAM or DPP through SRUK, including the mitigation plan, methodology, environmental and sustainable-development impacts, public consultation, stakeholder participation, and agreed benefit-sharing arrangements; do not start the credited mitigation activity until the document is validated.
- Use an independent validation and verification body that is a legal entity, has competent waste-sector personnel, holds the required national or international accreditation, provides qualified Indonesian personnel, and has no conflict of interest.
- Before applying for carbon-unit issuance, clear any environmental sanctions and reconcile the project's compliance history, environmental documents, monitoring data, findings, emission calculations, ownership, and double-counting controls.
- For international transactions, determine before contracting whether authorisation and a corresponding adjustment are required, obtain the applicable SRUK recommendation or approval, and ensure the transaction and unit use are recorded and reported through SRUK.
- Existing offset activities registered before 14 August 2026 should map their transition status immediately and prepare the data needed for the two-working-day SRUK recording rule when interoperability with an international standard is unavailable.