The Indonesian Government (President) recently issued Presidential Regulation No. 110 of 2025 on the Implementation of Carbon Economic Value Instruments and National Greenhouse Gas Emission Control, effective as of 10 October 2025 (“PR 110“), to redefine the carbon economic value instruments and carbon trading mechanism. Revoking the previous Presidential Regulation No. 98 of 2021 on Implementation of Carbon Economic Value to Achieve Nationally Determined Contribution (NDC) Targets and Control over Greenhouse Gas Emissions in Relation to National Development (“PR 98“).
Several notable updates are introduced in PR 110, such as (i) the inclusion of Carbon Allocation (i.e., the CO2e permitted during a certain period according to the national capacity), (ii) new broader definition of carbon unit, which now reads as the certified result of emission reduction and/or removal issued through domestic or international certification scheme, or a GHG Emission Quota, equivalent in a ton of CO2e (previously, PR 98 only acknowledged carbon units as the unit registered in the National Registry System for Climate Change Control (SRN-PPI)), and (iii) a confirmation that carbon trading can be carried out without waiting for Indonesia to meet its Nationally Determined Contribution (NDC) targets, as mentioned in Article 58 (1) of PR 110.
Another noteworthy update is the introduction of the Carbon Unit Registry System (SRUK) – provision and management of data and information system on carbon units at the level of carbon pricing instrument implementation. SRUK is different from the current SRN-PPI (which now serves as a NDC-level platform for managing data and information on mitigation and adaptation actions and resources across Indonesia), as SRUK will streamline the carbon trading process and ensure interoperability with international carbon market standards. SRUK uses a decentralized network in which all data and transactions are transparent, traceable, real-time, permanent, and interoperable with other registries. Every carbon unit and carbon trading is now recorded in SRUK – no longer SRN PPI as previously regulated in PR 98.
Commentary
It seems that the Indonesian government, through the PR 110, is trying to boost Indonesia’s carbon market and national emissions management, as well as aligning the carbon market governance with international standards. In the following months, businessperson should anticipate a series of implementing regulations that will change the landscape of carbon market in Indonesia. Several carbon-related aspects to anticipate, among others, (i) the possibility of conducting direct international carbon trading without waiting for the achievement of NDC target, (ii) transition from SRN-PPI to SRUK, and (iii) alignment of existing regulations.
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