Renewable Energy 2026

Last Updated September 11, 2026

Indonesia

Law and Practice

Authors



Santoso, Martinus & Muliawan Advocates (SMMA) is an independent Indonesian law firm established in 2021. Its partners are alumni of major international law firms in Jakarta and Singapore, and have represented FTSE 100, US Fortune 500 and Asia's largest companies in high-profile transactions and disputes. SMMA has significant experience in advising sponsors on pioneering power and infrastructure projects in Indonesia and can effectively assist clients in navigating the regulatory complexities and uncertainties in Indonesia. It is familiar with regulatory issues and challenges across all stages of project development and project finance, including procurement, construction, land acquisition and operation.

This content appeared in Renewable Energy 2025 and is awaiting update from the firm.

The Government of Indonesia (GoI) has set ambitious targets to reduce reliance on fossil fuels and accelerate the transition to renewable energy. Under its enhanced Nationally Determined Contribution (NDC), Indonesia has pledged to cut greenhouse gas emissions by 31.89% unconditionally (or 43.2% with international support) by 2030, and to reach net-zero emissions by 2060. However, progress to date has fallen short of these commitments.

The National Energy Policy issued in 2014 set a target for renewables to account for 23% of the national energy mix by 2025 and 31% by 2030. However, data from the Ministry of Energy and Mineral Resources (MEMR) shows that renewable energy represented only 14.68% of the mix as of 2024.

In 2022, the GoI introduced a moratorium on new coal-fired power plants (CFPPs). However, the regulation includes exemptions for:

  • CFPPs already listed in the Electricity Supply Business Plan (Rencana Usaha Penyediaan Tenaga Listrik, or RUPTL); and
  • CFPPs that meet specific criteria, namely:
  • integration with industries that increase the added value of natural resources or qualify as National Strategic Projects with significant contributions to job creation and/or economic growth;
  • commitment to reduce greenhouse gas emissions by at least 35% within ten years of operation, compared to the national CFPP average in 2021, through advanced technology, carbon offsets or renewable co-firing; and
  • operation limited to no later than 2050.

Importantly, these exemptions allow the continued development of captive CFPPs for powering smelters. Given the GoI’s emphasis on downstream mineral processing, the construction of additional captive CFPPs is likely in the near future.

In the transportation sector, the GoI has launched incentives for electric vehicles and charging infrastructure. Although these measures do not amount to a formal phase-out of internal combustion engines, they represent an incremental step toward reducing fossil fuel dependence.

Hydropower

Hydropower is the largest contributor to Indonesia’s renewable energy mix. The installed hydropower capacity is approximately 7.1 GW, which accounts for around 7.06% of national installed generation capacity. The 2025 National Electricity General Plan (RUKN) estimates Indonesia’s total hydropower potential to be 95 GW, of which the overwhelming majority (94.6 GW) is attributed to run-of-river systems.

Geothermal

Indonesia is among the world leaders in geothermal resources. Installed geothermal capacity currently stands at 2.67 GW (2.64% of total capacity), which makes it the second-largest renewable contributor after hydropower. National potential is vast (around 23.8 GW across 357 identified sites), with 14.4 GW having been confirmed as proven reserves. Given Indonesia’s volcanic geography, geothermal energy is expected to remain central to baseload renewable generation.

Biomass and Biogas

Biomass and biogas together contribute approximately 3.7 GW of installed capacity, largely through co-firing programmes in existing coal-fired power plants operated by PLN (Perusahaan Listrik Negara – the state electricity company). The 2025 RUKN estimates Indonesia’s biomass potential to be 53.4 GW, with an additional 1.3 GW from palm oil mill effluent, which brings total bioenergy potential to around 55.7 GW.

Solar Photovoltaic (PV)

Indonesia currently has a total installed solar PV capacity of only 920 MWp (0.9% of total capacity), but the country's solar resource is estimated at 3,315 GWp.

Wind

Wind energy plays a marginal role at present, with an installed capacity of 151.5 MW (0.15% of total). However, potential is estimated at 154.6 GW, divided between 60.4 GW onshore and 94.2 GW offshore.

Emerging Energy Sources

The clean energy transition in Indonesia has begun to expand into emerging energy sources. One area of rapid development is biofuels, where Indonesia operates one of the world’s most ambitious blending mandates in the transport sector. The biodiesel programme has advanced to B40 (40% fatty acid methyl ester in diesel), which contributes substantially to the renewable share in the national energy mix.

Contrastingly, hydrogen is still an emerging concept. Legally, hydrogen has been recognised as a form of “new energy” under the Energy Law. While current production is still confined to grey hydrogen from natural gas, a number of Indonesian companies are exploring pathways for green hydrogen and ammonia, particularly through geothermal and large-scale renewable projects. A clearer framework is expected to be introduced in the forthcoming New and Renewable Energy Law.

In June 2025, Indonesia and Singapore signed three memoranda of understanding (MoU) on:

  • cross-border electricity trade;
  • carbon capture and storage; and
  • sustainable industrial zones.

Singapore’s Energy Market Authority also granted additional conditional licences and approvals for the import of renewable energy. With this new addition, there are currently six consortiums that have obtained conditional licences to import renewable energy from Indonesia. The signing of the MoU is expected to accelerate the development of large-scale solar PV projects in Sumatra Island and the development of a new subsea electricity cable between Indonesia and Singapore.

On 27 February 2025, the MEMR issued Regulation No 5 of 2025 on Guidelines for Power Purchase Agreements from Power Plants Utilising Renewable Energy Sources. The regulation serves as a guideline for the drafting of power purchase agreements (PPAs) between PLN and independent power producers (IPPs) for renewable plants – ie, geothermal, hydropower, solar, wind, biomass, biogas, waste-to-energy and ocean energy power plants. The MEMR also issued Regulation No 10 of 2025 on a Roadmap for Energy Transitions in the Electricity Sector.

A significant number of renewable projects are being procured by PLN via assignment to its subsidiaries, namely PT PLN Nusantara Power (PLN NP) and PT PLN Indonesia Power (PLN IP). For these projects, the PLN subsidiary is the one selecting strategic partners for each project, becoming the majority (51%) shareholder in the project. Previous projects that were developed under this scheme include the 145 MWac Cirata floating solar PV project (developed by Masdar and PLN NP) and the 50 MW solar PV project in the new capital city, Nusantara Capital City (Ibu Kota Nusantara, or IKN) (developed by Sembcorp and PLN NP).

In September 2024, PLN NP invited companies to participate in its preliminary evaluation. Shortlisted companies will then be invited to participate in PLN NP’s strategic partner selection process once PLN assigns certain renewable projects to PLN NP. It is envisaged that there will be 13 projects (hydro and solar) where PLN will do the procurement directly but PLN NP will be included as a mandatory partner with minority shareholding, and four other projects (wind) where it is not yet known if PLN NP will be the majority or minority shareholder.

According to the MEMR, an additional installed capacity of 876.5 MW was sourced from renewable energy during the first six months of 2025.

There is currently no specific legal framework for renewable energy. Current key primary legislation includes the following.

  • Law No 30 of 2007 on Energy (Energy Law) provides the overarching framework for Indonesia’s energy sector, and obliges both central and regional governments to increase the supply and utilisation of new and renewable energy (NRE) (Articles 20(4) and 21(2)). It also allows business entities and individuals developing NRE projects to receive fiscal or non-fiscal incentives until their projects become economically viable. The Energy Law is general in nature, but establishes the legal foundation for subsequent renewable energy regulations, including the national target of achieving a 31% renewable share by 2050 under the National Energy Policy (KEN).
  • Law No 30 of 2009 on Electricity, as most recently amended by Law No 6 of 2023 on Stipulation of Government Regulation in Lieu of Law No 2 of 2022 (Electricity Law) is the principal law governing electricity generation, transmission, distribution and sales, including for renewable energy.
  • Law No 21 of 2014 on Geothermal Energy, as most recently amended by Law No 6 of 2023 on Stipulation of Government Regulation in Lieu of Law No 2 of 2022 (Geothermal Law) governs both the exploration and exploitation of geothermal resources for electricity generation and for direct-use applications. Notably, this law removes geothermal from the legal classification of “mining” which enables projects to be developed in conservation forest areas (this is important, as many geothermal fields are located in forested zones).

Key implementing regulations include:

  • Government Regulation No 79 of 2014 on National Energy Policy (GR 79/2014 or KEN);
  • Government Regulation No 25 of 2021 on Energy and Mineral Resources Business (GR 25/2021);
  • Presidential Regulation No 22 of 2017 on the General Plan of National Energy (PR 22/2017 or RUEN);
  • Presidential Regulation No 112 of 2022 on the Acceleration of Renewable Energy Development for Electricity (PR 112/2022);
  • MEMR Regulation No 11 of 2021 on the Implementation of Electricity Business, as amended by MEMR Regulation No 2 of 2024 on Rooftop Solar Power Plants Connected to Electrical Power Networkers of Holders of Business Licence for the Provisions of Electrical Power for Public Interest (MEMR Reg 11/2021);
  • MEMR Regulation No 2 of 2024 on Rooftop Solar Power Plants Connected to Electrical Power Networkers of Holders of Business Licence for the Provisions of Electrical Power for Public Interest (MEMR Reg 2/2024);
  • MEMR Regulation No 5 of 2025 on Guidelines for Power Purchase Agreements from Power Plants Utilising Renewable Energy Sources (MEMR Reg 5/2025);
  • MEMR Regulation No 10 of 2025 on Road Map for Energy Transition in the Electricity Sector (MEMR Reg 10/2025);
  • MEMR Decree No 188.K/TL.03/MEM.L/2025 on Approval of the Electricity Supply Business Plan of PLN for 2025-2034 (2025-2034 RUPTL); and
  • MEMR Decree No 85.K/TL.01/MEM.L/2025 on National Electricity Plan (2025 RUKN).

Upcoming Changes

NRE Law

The draft bill on the NRE Law has been under discussion between the House of Representatives and the GoI for more than seven years, and it is expected to be finalised soon. The bill is anticipated to cover not only renewable energy, but also “new energy” sources such as nuclear, hydrogen and ammonia.

Electricity Law

A draft amendment to the Electricity Law is currently being prepared by the House of Representatives. The amendment is expected to strengthen support for renewable energy, provide greater detail on electricity exports, and simplify the tariff structure for end customers.

Waste-to-energy

The GoI is preparing a draft amendment to the government regulation on waste-to-energy programmes. In parallel, Indonesia’s sovereign wealth fund, Danantara, has launched the Patriot Bond, targeting USD3.1 billion. Proceeds will be used, among other purposes, to develop waste-to-energy projects across 33 locations nationwide.

Export of electricity

In light of the recent MoU signed between Indonesia and Singapore on the export of electricity, the GoI is preparing a draft amendment to Government Regulation No 42 of 2012 on Cross-Border Electricity Sales. Among other effects, the amendment is expected to extend the validity period of the export and interconnection permits (which currently can only be granted for a maximum period of five years), address power wheeling for export projects, and streamline licensing requirements.

The primary regulators for renewable energy in Indonesia are as follows.

The Minister of Energy and Mineral Resources (MEMR) is the central authority that oversees the national energy and electricity policy. The two directorate generals within the MEMR that are relevant for renewable energy activities are the Directorate General of Electricity and the Directorate General of New Renewable Energy and Energy Conservation. Among other powers, the MEMR has the authority to:

  • issue electricity business licences;
  • conduct inspection and supervision of electricity business and facilities (including imposing sanctions and revoking business licences);
  • issue tariff approval; and
  • adjust the ceiling tariff for renewable projects currently set in PR 112/2022.

The National Energy Council (Dewan Energi Nasional, or DEN) was created by the President and comprises 15 individuals: seven from government bodies and eight from stakeholder groups. DEN is tasked with:

  • designing and formulating national energy policies;
  • establishing the National Energy General Plan and measures to address energy crises and emergencies; and
  • supervising the implementation of cross-sectoral energy policies.

The Minister of Investment and Downstream Industry/Indonesia Investment Co-ordinating Board (BKPM) co-ordinates business licensing, especially with respect to foreign investment. The Online Single Submission (OSS) system for licensing is managed by the BKPM.

The electricity sector in Indonesia is highly regulated. Renewable IPPs may carry out electricity generation activities and sell electricity under long-term PPAs with PLN, with a maximum period of 30 years from the commercial operation date (COD). PLN has to carry out limited tenders for the procurement of electricity from renewable sources, but direct appointments are permitted under certain circumstances.

For geothermal specifically, the company must obtain two main business licences:

  • the Geothermal Licence (IPB); and
  • the electricity supply business licence for public interest (IUPTLU) for power generation.

Captive power projects are allowed. However, due to restrictions on electricity sales and business areas, rooftop solar PV projects are typically structured by way of a long-term operating lease agreement between the solar PV developer and the customer.

Under MEMR Regulation No 48 of 2017 on Supervision of Business in the Energy and Mineral Resources Sector, the transfer of shares in an IPP company that sells electricity to PLN is prohibited prior to the COD, unless the transfer is to an affiliate that is directly owned more than 90% by the sponsor and is at one level below it. Any transfer of shares after the COD may be subject to certain contractual restrictions under the PPA.

For geothermal companies specifically, the initial public offering and transfer of shares in an Indonesian exchange are allowed after exploration, subject to prior approval from the MEMR. The transfer of shares via private sales is permitted but must be notified to the MEMR within five business days.

The lines of power generation (above 1 MW), transmission, distribution and sales are open for up to 100% foreign investment, as is geothermal business. Foreign investment companies are subject to minimum issued and paid-up capital requirements of IDR10 billion.

According to the 2023 Electricity Statistics issued by the MEMR, Indonesia has power plants with a total installed capacity of 91 GW. PLN owns and operates around 46 GW, and others (including IPPs supplying power to PLN and captive power plants) make up the remaining 45 GW.

The lines of businesses of electricity generation, transmission, distribution and sales are open for private investors. However, the Constitutional Court has recently issued a ruling that the electricity business must be conducted in an integrated (bundling) manner, and it cannot be conducted in an unbundling model (where each of the generation, transmission, distribution and sales is done by a different company).

Renewable IPPs may carry out electricity generation activities and sell electricity under long-term PPAs with PLN, with a maximum period of 30 years from COD. PLN has to carry out limited tenders for the procurement of electricity from renewable sources, but direct appointments are permitted under certain circumstances, as follows:

  • hydropower projects utilising multipurpose infrastructure built by the state (eg, reservoirs, dams and irrigation canals);
  • geothermal projects with an IPB holder, as the tender of the geothermal working area is already done by the MEMR;
  • expansion of existing renewable power plants at the same location (for geothermal, hydro, solar PV, wind, biomass and biogas); and
  • excess power (excess capacity) from operating power plants.

To participate in PLN’s tender, a company must pass certain financial and technical criteria and be shortlisted on PLN’s list of selected providers.

Market Structure

Biogas in Indonesia does not yet operate within a unified national market. Unlike electricity, which is fed into a single grid, biogas is typically produced and consumed locally. Most projects are still on-site (eg, palm oil mills processing palm oil mill effluent into energy, or landfill projects capturing methane for immediate use). As far as current regulations stand, there is no provision specifically allowing the injection of biogas into the national gas transmission grid. Any future injection of biomethane would likely fall under general natural gas regulations.

Key Parties

The main parties involved in biogas are Pertamina and PGN, government agencies, and producers of biogas and biomass – ie, major producers of biogas as a byproduct of their operations. Palm oil companies in particular have been encouraged to install biogas units. The Minister of Industry (MOI) and the MEMR offer some grants or subsidies for these installations (eg, through the Palm Oil Estate Fund for energy utilisation).

Applicable Rules and Regulations

Under PR 112/2022, PLN is required to purchase electricity from biogas and biomass power plants, provided that project developers can demonstrate a secure fuel supply throughout the PPA term. Several projects are already in operation, such as:

  • the AANE Jangkang Belitung, Indonesia’s first commercial-scale biogas plant, which has been operating since 2014 with a capacity of 1.2 MW and annual production of around 8.5 million kWh; and
  • the 3 MW Ujung Batu power plant in Riau, developed by PT Pasadena Biofuels Mandiri in 2023.

Licensing and Permitting

The business classification covering biogas as an alternative fuel is registered under KBLI 35203, which includes activities for processing gaseous fuel that can be directly utilised as energy. This encompasses fuel produced from agricultural, plantation, livestock or waste by-products, with additional processes undertaken to improve quality, such as purification, blending or other treatment. The activity is designated as high risk, which requires a Business Identification Number (Nomor Induk Berusaha, or NIB) and operational licences.

Once licensed, holders of a business licence for biogas as an alternative fuel are required to maintain the availability of biogas to meet domestic demand at reasonable prices, and to ensure the operation of appropriate facilities for provision, distribution and marketing.

The Geothermal Law distinguishes between direct use (using geothermal heat/fluid directly for its thermal energy without converting to electricity, such as for tourism, industry and agribusiness) and indirect use (for electricity). A company engaging in indirect use of geothermal power must obtain two main business licences:

  • the Geothermal Licence (IPB); and
  • the electricity supply business licence for public interest (IUPTLU) for power generation.

The MEMR has the authority to auction geothermal working areas for indirect use. Prior to the tender, PLN is required to submit the electricity tariff proposal, model power purchase agreement and pre-transaction agreement (which will be signed by the winning bidder and PLN) to the MEMR. PR 112/2022 stipulates that PLN may purchase the electricity from the project if the exploration is already completed and there is a proven geothermal resource, indicating that the PPA will only be signed once the exploration is completed. The maximum exploration period (including feasibility study) under the Geothermal Law is five years, which may be extended twice for a maximum period of one year for each extension. The exploration period can be granted for a maximum of 30 years after the feasibility study is approved by the MEMR.

The MEMR may also assign a business entity to carry out preliminary surveys and exploration (PSPE) in potential working areas. Geothermal working areas from this process will be auctioned via limited tender to the PSPE holder and state-owned enterprises engaging in the geothermal line of business.

In addition to the IPB licensing scheme described above, Indonesia still has several geothermal projects that were developed under the old joint operation contract (JOC) model. In this structure, PT Pertamina Geothermal Energy Tbk (PGE) holds the concession over geothermal working areas designated by the GoI. PGE appoints joint operation contractors to conduct geothermal exploration and exploitation within the area, and the electricity produced from the project is sold to PLN based on an energy sales contract.

Key Parties

The main parties involved are as follows:

  • The Directorate General of New Renewable Energy in the MEMR has authority to supervise the geothermal sector in Indonesia, including for the issuance of the IPB and the tender of geothermal working areas.
  • The Directorate General of Electricity in the MEMR has authority to supervise the electricity sector in general, including with respect to the issuance of IUPTLU and electricity tariff approval for geothermal projects.
  • PGE is a subsidiary of PT Pertamina (Persero), which is the holder of geothermal working areas in various locations in Indonesia, including several geothermal concessions under the old JOC model.
  • PLN is the main offtaker for electricity generated from geothermal projects.

Hydrogen

The production of hydrogen remains at an early stage in Indonesia. At present, hydrogen produced for industrial applications is treated simply as part of industrial activity subject to general industrial regulations. For green hydrogen (ie, hydrogen generated from renewable electricity via electrolysis), there is as yet no established PPA mechanism or offtake framework, which reflects the fact that such production has not yet reached a commercial scale in Indonesia.

Despite this absence of a regulatory framework, several key policy documents have provided further structure to Indonesia’s hydrogen ambitions. The Executive Summary of the Study on Green Hydrogen Development in Indonesia: Potential and Challenges, issued by BKPM, underscores the potential for green hydrogen to deliver exponential reductions in emissions as it begins to replace fossil-based fuels across transportation, buildings, electricity generation, industrial heating and feedstock applications. This policy direction has been reinforced by the MEMR, which, together with PLN, inaugurated Indonesia’s first pilot green hydrogen plant at the Muara Karang combined-cycle power plant in Jakarta, signalling a practical commitment to advancing hydrogen development.

The MEMR recently issued the National Hydrogen and Ammonia Roadmap for 2025–2060, which lays out three sequential phases.

  • The Initiation Phase (2025–2034) prioritises pilot projects, including hydrogen refuelling stations, hydrogen-powered buses and trucks, and the blending of up to 20% hydrogen into the natural gas network. In the power sector, the focus remains on co-firing, with ammonia and hydrogen blending targets set at 3% by 2025 and 2030 respectively, rising to 30% ammonia and 10% hydrogen by 2034 and 2035.
  • The Development and Integration Phase (2035–2045) foresees broader deployment of hydrogen technologies across industrial applications.
  • The Acceleration and Sustainability Phase (2046–2060) envisions full-scale commercialisation with hydrogen integrated into Indonesia’s clean energy system.

Biofuels

Biodiesel is already integrated into the fuel market by mandate (Pertamina and other distributors blend and distribute it).

Quality Standard

Indonesia has begun to establish quality standards for biofuels, although they remain concentrated on biodiesel. The basis is SNI 7182:2015, which sets out specifications for biodiesel quality. Its key parameters include:

  • a minimum methyl ester content of 96.5%;
  • a minimum cetane number of 51;
  • a maximum sulphur content of 50 mg/kg;
  • an oxidative stability requirement of at least 480 minutes (using the Rancimat method); and
  • a maximum total glycerol content of 0.24%.

At this stage, however, there are no equivalent SNI provisions governing higher biodiesel blends such as B35 or B40, nor are there national standards in place for bioethanol or aviation fuel.

Incentives

The GoI provides subsidies for biodiesel (the gap between the biodiesel production cost and the diesel selling price is covered by the Oil Palm Fund). No subsidy yet exists for hydrogen but, given global trends, Indonesia might incentivise green hydrogen for export or domestic industry via tax breaks. The NRE Bill includes the concept of a “Value of Carbon” (Nilai Ekonomi Karbon) incentive, under which a business that produces clean energy can earn carbon credits or other economic value.

Under the Electricity Law, consumers may conduct electricity business activities (generation, transmission and distribution) for their own use. In this case, the electricity business licence (IUPTLS) must be held by the end user. Due to the restriction on electricity sales and business areas, captive solar PV projects are typically structured as long-term operating lease agreements between the customer and the solar PV developer.

The main regulation governing grid-connected rooftop solar PV projects is MEMR Regulation 2/2024, pursuant to which, customers are allowed to own and operate rooftop solar PV power plants for their own use. However, such use will be subject to approval from the business area holder and the quota determined by the MEMR. Parallel operation charges are not applicable for rooftop solar PV projects for own use. MEMR Regulation 2/2024 also removed the net-metering benefit that used to be available for PLN’s customers under the previous regulation.

Market Structure

Indonesia’s electricity transmission and distribution network is dominated by PLN, which is mandated to supply electricity for the public interest. Under the Electricity Law, PLN has the “first priority” to undertake electricity supply in any given area. However, private companies, regional-owned enterprises, co-operatives and community-based entities may also engage in electricity supply business for public use if duly licensed, especially in cases or regions where PLN does not undertake the service. In practice, PLN holds IUPTLU covering generation, transmission, distribution and retail in most regions.

Assets and Grid Operation

The national grid infrastructure is predominantly owned and operated by PLN. Electricity from renewable sources is generally fed into PLN’s grid under PPAs with PLN as the offtaker or comes from renewable power plants owned and operated by PLN. Government Regulation No 25 of 2021 on Implementation of the Energy and Mineral Resources Sector (GR 25/2021) confirms that transmission and distribution are regulated businesses that require licences, and allows integrated operations by the same entity for public supply.

Applicable Rules and Regulations

Public grid operators (ie, PLN) have obligations to serve, including universal service targets and reliability standards, overseen by the MEMR and the Energy Regulatory Agency. Renewable electricity generators generally connect to PLN’s grid at the appropriate voltage level. As the grid operator, PLN is responsible for grid interconnection agreements and for ensuring system stability when intermittent renewables feed in.

Notably, energy storage systems (ESS) – particularly battery energy storage systems – are increasingly recognised in regulations as a means to support renewable integration. PR 112/2022 contemplates the use of battery or other energy storage facilities alongside intermittent renewable plants, and provides that projects like solar PV or wind that include storage may be subject to different tariff considerations. For instance, PR 112/2022 mandates the MEMR to set benchmark prices for renewables, with separate or additional pricing for installations equipped with batteries or storage. Following this, MEMR Reg 5/2025 allows renewable IPPs to incorporate storage technology and introduces the concept of “deemed dispatch” for renewable PPAs, which can compensate developers if the grid operator cannot offtake power due to congestion or other reasons. This incentivises the use of storage or grid upgrades to minimise curtailment.

There is no specific regulatory framework governing potential grid congestion and intermittency. PLN owns and operates the majority of transmission assets in Indonesia and a significant amount of generation assets. IPPs supplying power to PLN are also required to always comply with PLN’s dispatch instruction. Therefore, PLN can curtail the electricity supply at any time to mitigate potential grid congestion. PPAs between IPPs and PLN typically require PLN to pay for deemed dispatch if the curtailment (which is not caused by the IPP’s fault) exceeds a certain threshold.

The transportation and storage of renewable gas is governed not by a dedicated regime but rather by the general framework applicable to natural gas. The sector remains highly centralised, with transmission and distribution infrastructure dominated by PGN and Pertamina itself. Producers of renewable gas must either construct small, dedicated pipelines for “own use” under a licence from the Directorate General of Oil and Gas, or contract with a licensed pipeline operator such as PGN. By law, pipeline operators are obliged to provide third-party access where technically and economically feasible, although in practice such arrangements are still rare for renewable gas.

Where pipeline connection is not viable, renewable gas may be upgraded and compressed into Bio-CNG or liquefied into Bio-LNG, stored in cylinders or tanks, and transported by truck or vessel in a manner similar to LPG or conventional CNG. Indonesia has not yet developed large-scale storage facilities specific to biogas or biomethane; the market is limited to smaller bottling and distribution initiatives for off-grid cooking or transport applications.

Indonesia does not have an established sector for district heating or centralised heat distribution from renewable sources, primarily due to the tropical climate (which minimises demand for heating) and the lack of existing heat network infrastructure.

For the utilisation of geothermal power for heat, the rights to transport and store geothermal heat fall within the scope of the IPB, which authorises the holder not only to explore and exploit geothermal resources within the designated working area, but also to undertake the ancillary activities required for delivering the extracted heat to a power generation facility. In practice, geothermal operations are almost always developed in close proximity to the designated geothermal working area, which minimises the logistical need for long-distance transportation of geothermal steam or hot water. Consequently, the licence holder is usually responsible for building, operating and maintaining the necessary infrastructure to ensure the reliable supply of heat energy to the power plant.

Hydrogen

There is currently no specific regulation governing the storage and transportation of hydrogen in Indonesia. However, according to the Indonesian Hydrogen Roadmap, studies and pilot projects are planned for the movement of hydrogen in the form of high-pressure liquid, solid carriers and underground storage. In the maritime transport sector, demonstration projects are envisaged to test hydrogen shipping, accompanied by the development of liquid hydrogen infrastructure at ports and designated logistics hubs.

Biofuels

The transport and storage of biodiesel and bioethanol in Indonesia are governed under MEMR Regulation No 4 of 2025 on the Utilisation and Business Activities of Biofuels. Article 3 stipulates that the business activities of biofuels may only be conducted by a licensed biofuel business entity that is authorised to undertake the processing, purchase, sale, transportation, storage and marketing of biofuels. With respect to storage, Article 8 requires that biofuel business entities provide dedicated storage facilities for the biofuels they manage. Article 17 further clarifies that oil fuel business entities may store biofuels prior to blending them with conventional petroleum fuels. Blending obligations are set out under Article 15(2), which requires oil fuel business entities to carry out blending of biofuels with specific fuel types:

  • biodiesel blended with designated types of diesel oil;
  • biodiesel blended with general diesel fuel;
  • bioethanol blended with gasoline;
  • hydrotreated vegetable oil (HVO/diesel biohydrocarbon) blended with diesel fuel at a cetane number specification of 51, as distributed at fuel stations for road transportation; and
  • bioavtur blended with aviation turbine fuel.

The sale and purchase of electricity in Indonesia is governed by the Electricity Law, which requires any business entity seeking to distribute and sell electricity to obtain a business area and integrated IUPTL licence. PLN’s business area covers the whole territory of the Republic of Indonesia, except for certain areas that have been carved out and granted to other developers; therefore, in practice, the retail supply of electricity to end users in Indonesia is monopolised by PLN for general consumers. PLN sells electricity to households, businesses and industries at tariffs approved by the government – a customer cannot currently choose a different electricity supplier in the way they might in liberalised markets, as there is no competitive retail market. Renewable electricity generated by IPPs is sold wholesale to PLN via PPAs, and then PLN mixes it into the overall supply for end users.

There are currently 65 business area holders (including PLN) across Indonesia. Most non-PLN business areas are industrial estates with independent power suppliers.

The retail gas market in Indonesia (piped gas to end users) is relatively small. The main supplier to end users is PGN (and its subsidiaries), which delivers natural gas via pipelines to industrial, commercial and some residential consumers. When it comes to gas from renewable sources (biogas/biomethane), there is not yet a distinct retail market. Renewable gas, if injected into the grid, will be commingled with natural gas and delivered by the existing gas utility to customers. End users typically cannot tell the difference and are not sold “biogas” separately.

Trading “heat” as a commodity to end users is virtually non-existent in Indonesia, given the lack of centralised heating systems. End users who need heat (eg, hot air, steam or hot water) typically produce it on-site (eg, through boilers, heaters, heat pumps or solar water heaters). PR 112/2022 allows PLN to purchase steam from geothermal licence holders, which will be subject to the same ceiling tariff as the purchase of electricity from geothermal power plants.

Hydrogen is not yet supplied to general end users. With no hydrogen refuelling stations in place, demand from households or transport is virtually non-existent. For biofuels, the dominant channel is blending with fossil fuels. End users consume biodiesel and ethanol only as part of blended products at the pump. Ethanol, for instance, is supplied by producers to Pertamina and blended into gasoline before reaching consumers at petrol stations, which makes the trade B2B upstream rather than retail.

There is currently no specific regulatory framework for the trade of renewable energy certificates (RECs) in Indonesia. PLN offers the sale of RECs to buyers in Indonesia, using an electronic tracking system from APX TIGRs.

A recent development is the establishment of an organised REC market on a commodity exchange. In 2024, the Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi,or Bappebti) issued Bappebti Regulation No 11 of 2024 on Procedures for Trade of Physical Renewable Energy in the Futures Exchange, which essentially creates a framework for trading RECs as a commodity. Following this, in April 2025, the Indonesia Commodity and Derivatives Exchange became the first licensed exchange to facilitate REC trading. Under this system, RECs are traded on the exchange, with Indonesia Clearing House providing clearing and settlement.

Due to restrictions on business areas and electricity sales in Indonesia, corporate PPAs are typically structured as long-term operating lease agreements.

Land Acquisition

Land acquisition remains a major concern for project development in Indonesia. A lot of land in Indonesia is not yet certified, which means that project developers often have to go through a lengthy and uncertain process to identify and verify the status and ownership of the land. Under Law No 2 of 2012 on Land Procurement for Public Interest as amended by the Job Creation Law, PLN (and in some cases IPPs) may utilise the mandatory land acquisition process as provided under the law, but the timeline for this process is very long (sometimes more than 300 business days).

Prior to obtaining title over the land, the developer must obtain a Conformity to Spatial Utilisation Activities (KKPR), which, among others, confirms that the proposed site of the project is already aligned with the spatial planning. KKPR is one of the basic licensing requirements that must be obtained by companies before they can obtain business licences.

Environmental Approval

Before commencing any business activity in Indonesia, companies have to prepare environmental documents and obtain an environmental approval. For renewable power plants and electricity transmission assets, the environmental documents are usually in the form of either an Environmental Impact Analysis (AMDAL) for projects with more significant impact on the environment, or an Environmental Management Efforts – Environmental Supervision Efforts document (UKL/UPL). Whether or not a project is subject to the AMDAL or UKL-UPL requirement will depend on the capacity and size of the project. The preparation of an AMDAL will involve public consultation.

Environmental approval is one of the basic licensing requirements that must be obtained by companies before they can obtain business licences.

Building Approval (PBG)

Building Approval is also one of the basic licensing requirements that must be obtained by companies before they can obtain business licences. The Building Approval must be obtained prior to the commencement of construction activities.

Forestry Area Use Approval (PPKH)

Where a renewable energy project is located within a designated forestry area, the project developer is required to obtain a PPKH, which serves as the legal basis permitting the use of forest areas for non-forestry activities, including renewable energy development. The scope of permissible activities is limited, and only certain renewable energy projects may be licensed to operate in forestry areas. Without this approval, no development may proceed on forest-designated land.

Onshore Contracting

Under the Indonesian Construction Law, foreign contractors (in the form of either foreign investment companies or joint operations with a local contractor) may only undertake construction work within market segments that are high-risk, high-technology and/or high-cost. Construction contracts for the provision of construction services in Indonesia have to be governed by Indonesian law; if made in dual language, the Indonesian version will prevail in the event of a dispute.

Split EPC contract models (for onshore work and offshore work) may be implemented, but project developers will have to consider the restrictions under the Construction Law and the tax implications of the arrangement.

Offshore renewable energy in Indonesia (eg, offshore wind, tidal, wave and ocean thermal) is still at a very early stage. Nevertheless, several studies have identified potential sites, including areas off the coasts of South Sulawesi, Java, and selected eastern islands, where wind speeds are promising. Pilot initiatives have been explored, such as a tidal current project in the Larantuka Strait in Flores.

From a regulatory standpoint, there is currently no separate framework governing offshore renewable projects; they are subject to the same permitting and licensing requirements as apply to onshore renewable energy development. What distinguishes offshore projects, however, is the necessity of subsea transmission infrastructure: every offshore wind farm, tidal array or ocean thermal project must export power to the onshore grid (or, in some cases, across borders) via subsea cables.

Subsea Infrastructure

Subsea cable placement in Indonesia is governed under marine spatial-use law. The Minister of Marine Affairs and Fisheries Decree No 14 of 2021 on Submarine Pipeline and/or Cable System provides the national map and designated corridors for subsea pipelines and cables, which serve as the reference for any undersea installation. In parallel, Minister of Marine Affairs and Fisheries Decree No 42 of 2022 on Mechanism for Implementing the Establishment and/or Placement of Buildings and Installations at Sea establishes the procedure for placing buildings and installations at sea.

Developers must submit a proposal detailing the project plan, geographic co-ordinates, intended use of marine space, navigational safety considerations, disaster mitigation measures and ecosystem safeguards. The proposal is reviewed by the National Team on Subsea Cable and Pipeline Management, which validates the application and issues recommendations for a marine survey. Once approvals are obtained and the marine survey confirms compliance, the project may receive a Conformity of Marine Spatial Utilisation, environmental approval and the relevant business licences.

A significant number of Indonesian renewable projects have been financed by way of limited-recourse project financing from international lenders. The main legal considerations for project finance are as follows.

Bankability

A bankable PPA with balanced risk allocation between sponsors and PLN is a key concern in project finance. PPAs with PLN typically provide take-or-pay obligations and an obligation for PLN to purchase the project in the event of PLN’s default or prolonged government force majeure. Government guarantees are available for IPP projects (including renewable projects). However, over the past ten years, there have been many precedents of renewable projects being financed by international lenders on a project finance basis without any government guarantee.

World Bank Negative Pledge

The World Bank Negative Pledge requires that any lien created on any “public assets” as security for a loan will equally and ratably secure the GoI’s loan payment to the World Bank, or alternatively the GoI must provide an equivalent lien to the World Bank. The World Bank Negative Pledge exempts liens granted for acquisition finance transactions, but not for limited-recourse project finance.

The term “public assets” is defined broadly to include assets of any entity owned or controlled by the country, or operating for the account or benefit of the country. Therefore, it may be interpreted to include assets belonging to state-owned enterprises or subsidiaries of state-owned enterprises. In projects where one or all of the sponsors are state-owned enterprises or subsidiaries of state-owned enterprises, the structuring and security package will have to take into account the World Bank Negative Pledge restrictions.

Security, Direct Agreements and Enforcement

The security package for renewable energy projects typically mirrors that of other project-financed assets, including:

  • mortgages (hak tanggungan) over land and buildings;
  • fiduciary security over movable assets, receivables and insurance proceeds;
  • pledge of shares;
  • pledge of bank accounts; and
  • conditional novation of key project contracts (eg, EPC, O&M and insurance).

Tax Allowance

Government Regulation No 78 of 2019 on Income Tax Facilities for Investment in Certain Business Fields and/or in Certain Regions provides tax allowances for investments in designated sectors and regions, including power generation (including for mini and micro power plants with investment below IDR100 billion) and geothermal. The allowance includes:

  • a reduction of next taxable income of up to 30% of the amount of qualifying investment in the form of fixed assets (including land), spread at 5% per year over a period of six years;
  • accelerated depreciation of tangible assets and accelerated amortisation of intangible assets;
  • a reduction of the final income tax on dividends paid to foreign shareholders to 10%, unless a lower rate is available under the applicable tax treaty; and
  • an extended loss carry-forward facility to a maximum of ten years under certain conditions.

Import Duty and VAT Exemptions

The import of capital goods for power plants (not only renewables) may be subject to import duty and VAT exemption if the goods are not yet produced in Indonesia or if the local products are not yet sufficient (in quantity or specifications). This facility is available for IPPs selling power to PLN and holders of electricity business areas (wilayah usaha).

There is no specific regulatory framework for the decommissioning and disposal of renewable energy installations in Indonesia. In general, renewable energy project developers must prepare environmental documents (either AMDAL or UKL-UPL, depending on the scale of the project) and obtain environmental approval before the commencement of construction. The environmental documents generally include post-operation measures (including the decommissioning of the facilities).

In addition, the disposal of hazardous and toxic waste (which may include certain materials in solar PV panels and battery systems) will have to be done in accordance with the Environmental Law and its implementing regulations.

The following upcoming developments are of note.

  • NRE Law – the draft bill on the NRE Law has been under discussion between the House of Representatives and the GoI for more than seven years, and it is expected to be finalised soon. The bill is anticipated to cover not only renewable energy, but also “new energy” sources such as nuclear, hydrogen and ammonia.
  • Electricity Law – a draft amendment to the Electricity Law is currently being prepared by the House of Representatives. The amendment is expected to strengthen support for renewable energy, provide greater detail on electricity exports, and simplify the tariff structure for end customers.
  • National Energy Policy (KEN) – a new KEN is expected to be issued shortly, replacing the policy issued in 2014. The revised KEN is likely to lower the renewable energy mix target to 19–21% by 2030 (from the previous 23% by 2025), while significantly increasing longer-term targets to 58–61% by 2050 (previously 30%) and 70–72% by 2060.
  • Second NDC – the GoI is currently in the final stage of preparing its second NDC, which is expected to include a higher renewable energy mix target, confirmation of the Forestry and Other Land Use (FOLU) Net Sink 2030 target, and a new goal of achieving Zero Waste Net Emission by 2050.
  • Waste-to-energy – the GoI is preparing an amendment to the draft government regulation on waste-to-energy programmes. In parallel, Indonesia’s sovereign wealth fund, Danantara, has launched the Patriot Bond, targeting USD3.1 billion. Proceeds will be used, among other purposes, to develop waste-to-energy projects across 33 locations nationwide.
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Trends and Developments


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UMBRA – Strategic Legal Solutions is an Indonesian law firm advising on project development, project financing, energy, infrastructure, and ESG-related matters. The firm is ranked for Projects & Energy by Chambers Asia-Pacific 2026. UMBRA has advised on a range of major power and infrastructure projects in Indonesia, including the 50 MW Nusantara Solar Energi Project Finance, the 510 MW Batang Toru Hydropower Project, the 60 MW Saguling Floating Solar Project, and the 35 MW Tembesi Floating Solar Project. Previous work includes advising sponsors, project companies, lenders, and other stakeholders on project structuring, financing arrangements, power purchase agreements, EPC and O&M arrangements, security documents, and other project-related documentation. The firm also advises clients on renewable energy development and the legal and regulatory aspects of Indonesia’s energy transition.

Indonesia’s energy transition is marked by two key developments: more ambitious renewable energy targets and a stronger policy push toward renewable-based energy independence.

The revised National Energy Policy under Government Regulation No 40 of 2025 raises the target for the share of new and renewable energy in primary energy supply from 31% to 53–55% by 2050. This ambition is reflected in PLN’s Electricity Supply Business Plan 2025–2034 (RUPTL), under which renewable energy accounts for more than half of planned capacity additions, with greater emphasis on geothermal, hydropower, and solar.

Against this backdrop, the government is pursuing significant regulatory reforms to address existing barriers, provide greater certainty for investors, and facilitate emerging renewable energy business models. These reforms are expected to shape Indonesia’s renewable energy market and create new opportunities across the broader energy transition value chain. We outline below some of the trends and developments within Indonesia’s renewable energy sector.

The President’s 100 GW Solar Programme

One of the Indonesian government’s most ambitious policy initiatives is the 100-GW Solar Power Programme, under which the government aims to install up to 100 GW of solar photovoltaic capacity by 2029 (CNBC Indonesia, 2026). On 25 August 2026, the President formally launched the programme at the Gilimanuk solar power plant site in Bali, marking the commencement of its implementation (Ministry of State Secretariat (MSS), 2026). If implemented as planned, the programme would represent a significant breakthrough for Indonesia’s power sector and substantially accelerate the country’s energy transition.

The initial phase comprises 14 solar power plants across six provinces, namely West Java, Central Java, East Java, Bali, Bangka Belitung Islands, and Riau Islands, with an aggregate capacity of approximately 5.3 GWp. The projects are at different stages of development, ranging from commercial operation and construction to tender preparation and projects that have secured PPAs. The portfolio includes, among others, the 1,688 MWp Jatiluhur, 1,250 MWp Cirata, 636 MWp Jatigede, 605 MWp Madura, 134.2 MWp Gajah Mungkur, 132 MWp Pasuruan, and 130.2 MWp Banyuwangi solar power projects (Ministry of Energy and Mineral Resources (MEMR), 2026; MSS, 2026). The government estimates that the full 100 GWp programme will require approximately USD73 billion in investment, while potentially generating approximately 5.52 million jobs and reducing annual electricity subsidies by approximately IDR73.9 trillion (MSS, 2026).

MEMR has also indicated that the government is in the process of incorporating the programme into Indonesia’s national energy planning framework. Currently, MEMR has confirmed that the initiative will be reflected in PLN’s Electricity Supply Business Plan (RUPTL) (Dunia Energi, 2026). Nevertheless, the broader regulatory framework and implementing policies necessary to support the programme have yet to be issued.

The programme splits into two: roughly 80 GW of decentralised, small-scale solar systems paired with a battery energy storage system (BESS) and 20 GW of utility-scale solar connected directly to the national grid. A key objective of the programme is to replace diesel-based electricity generation, particularly in eastern Indonesia, where many communities continue to rely on diesel generators (CNBC Indonesia, 2026). Under the government’s current vision, each village is expected to be equipped with approximately 1 MW of solar PV capacity integrated with BESS infrastructure (Bloomberg Technoz, 2026).

Procurement: the GIGA ONE model

The programme is also driving innovation in procurement structures. In May 2026, PLN launched the 1.225 GW PLTS Mentari Nusantara I project through an integrated procurement scheme branded “GIGA ONE”, with the tender formally commencing on 30 April 2026 (Kompas.com, 2026). The scheme consolidates multiple projects into a single strategic package in order to achieve better economies of scale and greater project certainty for investors, with capacity distributed across Java (600 MW), Kalimantan (340 MW), Maluku and Papua (120 MW), West Nusa Tenggara (80 MW), Sulawesi (50 MW) and Sumatra (35 MW), and commercial operation targeted for 2029 (CNN Indonesia, 2026). Bidders may submit proposals for more than one package subject to capacity limits, and construction is expected to commence following financial close, at around mid-2027 (Kontan, 2026). PLN has indicated that the GIGA ONE approach will be replicated for hydro, wind, and BESS procurement (Ecobiz Asia, 2026), which suggests that bundled, portfolio-level tendering may become the prevailing model for subsequent large-scale renewable procurement in Indonesia.

Regulatory framework under preparation

MEMR is preparing a draft Presidential Regulation to accelerate the development of the 100 GW solar programme and co-ordinate with the relevant ministries and agencies, including in relation to licensing (Bisnis.com, 2026). Key implementation issues include land availability and domestic content (TKDN) requirements. MEMR and ATR/BPN have identified approximately 24,000 hectares of potentially suitable land in Java, subject to further verification of supporting grid infrastructure (MEMR, 2026; Bisnis.com, 2026). The government has also emphasised the use of domestic content in implementing the programme (Bloomberg Technoz, 2026).

Refining the Renewable Energy Procurement and Pricing Framework

Indonesia is preparing a substantial revision to Presidential Regulation No 112 of 2022 on the Acceleration of Renewable Energy Development for Electricity Supply (PR 112/2022) which has been the key regulation for the procurement and pricing of renewable electricity. Based on the draft shared in the public consultation held by MEMR in November 2025, the key changes on the draft are outlined below.

Broader scope and energy-transition rules

The draft covers several technologies not specifically addressed under the current PR 112/2022, including pumped-storage hydropower, peaker hydropower, floating solar, hybrid power plants and BESS. It would also allow the regulation to be used as a reference by electricity business area holders other than PLN.

The draft also broadens the exemption on the prohibition of new coal-fired power plants (CFPP) development currently regulated in PR 112/2022. Under the current PR 112/2022, new CFPPs are generally prohibited, except for projects already included in the RUPTL before PR 112/2022 took effect or projects that meet specific conditions, including a 35% emission-reduction commitment and an operating limit of 2050. The draft broadens these exceptions by allowing new CFPPs for system reliability or energy independence purposes and replacing the 2050 operating limit with a commitment to support Indonesia’s net-zero emissions target by 2060.

More flexible procurement routes

The draft introduces procurement routes for the newly recognised technologies and expands the cases where PLN may use direct appointments. These include renewable plants developed in hybrid configuration with existing CFPP, projects developed under government-to-government arrangements, and projects supported by specific demand from green consumers. For hydro, solar and floating-solar projects using state-owned dams, reservoirs or irrigation infrastructure, MEMR, the Ministry of Public Works and PLN would conduct a joint procurement, followed by PLN’s direct appointment of the successful bidder.

New pricing mechanisms

The draft introduces a feed-in tariff for geothermal projects reaching COD within ten years after the revised regulation takes effect, while later projects would remain subject to a ceiling price. It also introduces floor prices for hydropower, solar, wind, ocean energy, hybrid power plants and BESS, while retaining ceiling prices and negotiated prices for specified technologies. Prices below the floor price would require MEMR approval.

BESS pricing would also become more flexible. PR 112/2022 generally caps battery-storage prices at 60% of the electricity purchase price for relevant solar and wind projects. The draft removes this cap and provides different pricing approaches depending on the function of the BESS. Essentially, ceiling price applies to BESS functioning as load shifting and/or smoothing, while the purchase price for other functions of BESS will be agreed by the parties.

Carbon credits ownership

Ownership of carbon credits generated by power projects has been a longstanding issue since the issuance of Indonesia’s umbrella regulation on carbon trading in 2021. Given the number of stakeholders typically involved in a power project, determining which party is entitled to the resulting carbon credits has been challenging. The draft regulation seeks to provide greater certainty by expressly recognising independent power producers as the owners of carbon credits generated by their renewable power projects, in recognition of their contribution to emissions reduction and the development of renewable energy.

A New Framework for Electricity Generation Business

The MEMR is currently preparing a Draft Government Regulation on Electricity Supply Business Activities (Draft GR), which is intended to replace Government Regulation No 14 of 2012 on Electricity Supply Business Activities as amended by Government Regulation No 23 of 2014 (GR 14/2012). The Draft GR introduces a number of significant policy reforms that are expected to reshape Indonesia’s electricity sector, particularly in relation to electric vehicle infrastructure, renewable energy procurement, environmental attributes, and captive power generation.

Some of the key policy changes are discussed below.

A new regulatory framework for electric vehicle charging businesses

Consistent with Indonesia’s policy to accelerate the adoption of electric vehicles (EVs), the Draft GR introduces a dedicated regulatory framework for EV charging businesses. The regulation recognises two categories of EV charging activities: (i) EV charging facilities, which may take the form of private charging installations or public electric vehicle charging stations (SPKLU); and (ii) battery swapping businesses.

One of the most significant changes introduced by the Draft GR is the removal of the requirement to obtain a business area (wilayah usaha) and an approved RUPTL in order to operate an SPKLU. This represents a substantial departure from the current framework under MEMR Regulation No 1 of 2023, which requires SPKLU operators to first obtain a designated business area and an approved RUPTL before commencing operations. If enacted, this reform is expected to significantly lower regulatory barriers for private investment in Indonesia’s EV charging infrastructure.

Expanded scope for direct appointment in electricity procurement

Both GR 14/2012 and the Draft GR provide that electricity procurement by holders of electricity supply business licences for public interest (IUPTLU) is generally conducted through competitive tender processes. Certain procurement activities may nevertheless be undertaken through direct selection or direct appointment under specified circumstances.

The Draft GR significantly expands the categories of electricity procurement eligible for direct appointment, including electricity purchases from non-renewable power plants conducting early retirement, power plants developed through joint venture companies established between subsidiaries of integrated IUPTLU holders and their private partners, renewable power plants with a committed green consumer, as well as renewable power plants developed in the same location of an operating power plant.

These amendments are expected to provide greater procurement flexibility for PLN and other integrated electricity suppliers in order to accelerate energy transition in the electricity sector.

Recognition of environmental attributes

Consistent with the planned amendment to PR 112/2022, the Draft GR also introduces a framework governing environmental attributes generated by electricity producers. Under the Draft GR, holders of IUPTLU and electricity supply business licences for own use (IUPTLS) operating renewable energy power plants or conventional power plants undertaking climate change mitigation measures would be entitled to environmental attributes, such as carbon credits and renewable energy certificates.

Importantly, the Draft GR goes a step further by expressly providing that electricity purchases by integrated IUPTLU holders do not include the transaction of environmental attributes. If retained in the final regulation, this provision could create greater commercial flexibility for renewable energy developers and investors, allowing them to monetise environmental attributes separately from electricity sales and potentially unlock an additional revenue stream from renewable energy projects.

Expansion of rights for captive power licence holders (IUPTLS)

Another notable amendment concerns electricity supply for own use. Under the existing regulations, electricity supply for own use is generally limited to electricity used for the licence holder’s own business, with the sale of electricity prohibited. The Draft GR proposes to broaden this scope by allowing electricity generation for the licence holder’s affiliates to support business activities within an integrated ecosystem and/or a downstream industrial area, as well as enabling energy exchange arrangements.

If adopted, this broader framework could significantly reshape the way corporate groups structure their electricity supply, allowing greater flexibility in sharing and optimising electricity generation across affiliated entities and potentially reducing reliance on third-party electricity supply.

Expansive Role of Danantara in the Power Sector

In 2025, Indonesia enacted Law No 1 of 2025, amending the State-Owned Enterprises (SOE) Law and establishing Badan Pengelola Investasi Daya Anagata Nusantara (BPI Danantara). As a state-owned legal entity wholly owned by the government of Indonesia, BPI Danantara is mandated by law to manage state-owned enterprises (SOEs).

Within less than a year of its establishment, BPI Danantara has already been entrusted with two significant mandates in Indonesia’s electricity sector, underscoring the government’s intention to position the institution as a strategic investment platform for major energy infrastructure projects.

The first mandate relates to the development of waste-to-energy (WTE) projects. Under Presidential Regulation No 109 of 2025 on Urban Waste Management through Environmentally Friendly Technology-Based Renewable Waste-to-Energy Processing, BPI Danantara is responsible for selecting WTE developers, preparing project readiness and feasibility assessments, and investing in WTE projects that are commercially viable, financially feasible, and supported by appropriate risk management.

More recently, the government has also designated BPI Danantara to support the implementation of Indonesia’s cross-border electricity export initiative. As a follow-up to this mandate, Danantara Investment Management (DIM), a subsidiary of BPI Danantara, has signed memoranda of understanding with two companies to explore potential co-operation for electricity exports to Singapore. The proposed project is expected to have a generation capacity of approximately 3.4 GW, with the development targeted for 2035. Danantara views this initiative as part of a broader vision of positioning the Indonesia–Singapore electricity interconnection as a catalyst for the development of the ASEAN Power Grid, thereby supporting greater regional electricity market integration.

Classifying the Clean-Energy Economy Via KBLI 2025

In December 2025, Statistics Indonesia issued Statistics Indonesia Regulation No 7 of 2025 on the Indonesian Standard Industrial Classification (KBLI 2025), replacing KBLI 2020. KBLI 2025 has been implemented in the OSS system since 18 June 2026 and introduces more specific classifications for several activities that are increasingly relevant to the energy transition.

Electricity generation and carbon activities

KBLI 2025 rearranged the classification of electricity activities. Electricity generation is now separated into: (i) non-renewable generation that produces emissions; (ii) non-renewable generation that does not produce emissions; and (iii) renewable generation. Each of these classifications expressly includes the sale of carbon credits by the electricity-generation company. Furthermore, separate activities for trading carbon units are classified under the financial sector, including trading carbon units for a company’s own account and carbon brokerage.

Electricity storage and standalone BESS

KBLI 2025 also introduces KBLI 35132 for Electricity Storage Activities, covering the conversion of electricity into stored energy and its conversion back into electricity. This expressly includes pumped storage, compressed-air storage and BESS facilities. While the introduction of KBLI 35132 appears to provide a basis for exploring various electricity storage business models, including standalone BESS projects, the market continues to await further regulatory developments to clarify the regulatory framework applicable to electricity storage activities.

CCS and hydrogen

KBLI 2025 also provides greater clarity on the classification of carbon capture and storage (CCS) and hydrogen-related activities. In particular, it introduces a specific KBLI code for carbon transportation activities, addressing a classification gap under the previous KBLI framework. KBLI 2025 also introduces a range of dedicated KBLI codes covering various hydrogen-related activities, including hydrogen exploration, extraction, production, storage, distribution, transportation, and sale, providing a more comprehensive classification framework for the development of the hydrogen value chain.

The New Licensing Playbook in the Energy Sector

In June 2026, MEMR issued MEMR Regulation No 7 of 2026 on Business Activity Standards for the Implementation of Risk-Based Business Licensing in the Energy and Mineral Resources Sector (MEMR Reg 7/2026). The regulation sets the licensing standards for the electricity, oil and gas, mineral and coal, and new and renewable energy sectors.

MEMR Reg 7/2026 introduces several measures intended to simplify spatial licensing. Survey and exploration activities in the new and renewable energy sector are no longer required to obtain a Suitability of Space Utilisation Activities (Kesesuaian Kegiatan Pemanfaatan Ruang, or KKPR). For generation, transmission, and substation infrastructure within PLN’s business area, MEMR is responsible for the KKPR application. Other electricity infrastructure may also obtain KKPR without a substantive spatial assessment in certain specified locations and circumstances.

At the same time, the requirements for Generation IUPTLU have become more detailed. In addition to the requirements under GR 28/2025, MEMR Reg 7/2026 requires documents relating to the operational worthiness of the installation, domestic content compliance, and completion of the electricity infrastructure project. This could potentially make the timing of the IUPTLU application unclear as some of these documents are generally available only after construction has progressed or been completed, while developers may need an IUPTLU earlier in the project cycle, including obtaining import-duty facilities for capital goods.

Overall, while MEMR Reg 7/2026 is intended to streamline licensing, further confirmation from MEMR is still needed on several practical issues. That includes the timing of IUPTLU applications, the implementation of the new spatial-licensing measures, and the alignment of the regulation with the 2025 Indonesian Standard Industrial Classification (KBLI).

Hybrid Power Plants and the De-Dieselisation Challenge

To support Indonesia’s Net Zero Emission target and advance the energy transition roadmap, MEMR has enacted MEMR Regulation No 19 of 2025 on Hybrid Power Plants (MEMR Reg 19/2025). Beyond establishing a legal basis for hybrid power generation, the regulation also seeks to enhance the commercial and operational viability of such projects through reforms to electricity pricing and procurement arrangements. The key features of MEMR Reg 19/2025 are outlined below.

Hybrid power plant framework

The regulation establishes a dedicated regulatory framework for hybrid power plants, combining renewable sources with BESS, hydrogen, or existing diesel generation designed for small islands and isolated grids.

New pricing framework for hybrid power plants

MEMR Reg 19/2025 departs from the single ceiling-price regime previously established under PR 112/2022. To improve commercial viability for renewable energy developers, it introduces a dual-pricing structure comprising both a ceiling price and a floor price, the details of which will be set out in a forthcoming ministerial decree. Several commercial principles have already been established under the new mechanism:

  • Tariffs are fixed for the term of the power purchase agreement (PPA) and are not subject to escalation or indexation.
  • Electricity grid facility price is excluded from the electricity price and capped at 5% of that price, a substantial reduction from the 30% cap under PR 112/2022. Costs exceeding this threshold require explicit approval from the Ministry.
  • Tariffs are denominated in rupiah, calculated by reference to the Jakarta Interbank Spot Dollar Rate (JISDOR), with price evaluations permitted every two years.

To mitigate the financial exposure of PLN, MEMR Reg 19/2025 also provides for state compensation where the purchase of hybrid electricity increases PLN’s generation costs, subject to available fiscal capacity.

Procurement process

Under MEMR Reg 19/2025, PLN is required to procure electricity from eligible hybrid configurations as a single integrated system through direct selection, with priority given to location-based clustering of power plants within a small-scale system. While the regulation aims to support the de-dieselisation programme, it only expressly governs procurement and pricing mechanisms for diesel power plants combined with hydrogen power plants and BESS. This raises questions of whether MEMR Reg 19/2025 will apply to de-dieselisation projects that have undergone procurement – typically involving a combination of diesel and solar power plants that is not listed in the regulation – or whether a formal stipulation from MEMR (eg, MEMR regulation or decree) would be required to extend the application of this regulation to those ongoing de-dieselisation projects.

Improving the Framework for Indirect Geothermal Utilisation

The Indonesian government is preparing to revise GR 7/2017, with the aim of addressing long-standing bottlenecks in the geothermal sector and accelerating geothermal development in support of the national energy transition.

The proposed amendments are expected to focus on three key areas: improving investment attractiveness, streamlining administrative processes, and addressing practical challenges that have constrained project development, particularly in procurement, financing, and exploration. The amendment is expected to introduce a range of changes to the existing geothermal framework, including revisions to the tender process for obtaining a geothermal working area; greater clarity on the requirements for extending or replacing the exploration period; clarification of the treatment of carbon credits; a legal basis for direct geothermal utilisation; and the utilisation of geothermal-associated minerals.

The proposed framework also emphasises sustainable geothermal development that balances the economic, social, and environmental aspects of geothermal projects, with the aim of enhancing their positive impact on surrounding communities.

To further improve the economics of geothermal projects, which currently face electricity tariffs of approximately USD 9.5 cents/kWh, the government is also considering additional tax incentives for geothermal projects (PajakNow, 20 August 2026).

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Law and Practice

Authors



Santoso, Martinus & Muliawan Advocates (SMMA) is an independent Indonesian law firm established in 2021. Its partners are alumni of major international law firms in Jakarta and Singapore, and have represented FTSE 100, US Fortune 500 and Asia's largest companies in high-profile transactions and disputes. SMMA has significant experience in advising sponsors on pioneering power and infrastructure projects in Indonesia and can effectively assist clients in navigating the regulatory complexities and uncertainties in Indonesia. It is familiar with regulatory issues and challenges across all stages of project development and project finance, including procurement, construction, land acquisition and operation.

Trends and Developments

Authors



UMBRA – Strategic Legal Solutions is an Indonesian law firm advising on project development, project financing, energy, infrastructure, and ESG-related matters. The firm is ranked for Projects & Energy by Chambers Asia-Pacific 2026. UMBRA has advised on a range of major power and infrastructure projects in Indonesia, including the 50 MW Nusantara Solar Energi Project Finance, the 510 MW Batang Toru Hydropower Project, the 60 MW Saguling Floating Solar Project, and the 35 MW Tembesi Floating Solar Project. Previous work includes advising sponsors, project companies, lenders, and other stakeholders on project structuring, financing arrangements, power purchase agreements, EPC and O&M arrangements, security documents, and other project-related documentation. The firm also advises clients on renewable energy development and the legal and regulatory aspects of Indonesia’s energy transition.

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