Permen LHK 21/2022 Procedures for Carbon Economic Value

Updated 2026-11-02 · 4 min read · By the akar.earth specialist team

Permen LHK 21/2022 set Indonesia's carbon economic value (NEK) procedures: trading, results-based payment, levies, SPE-GRK and SRN-PPI, and its 2026 status.

Permen LHK 21/2022 is the Ministry of Environment and Forestry regulation that set out how Indonesia’s carbon economic value (NEK) framework works in practice. It translated Perpres 98/2021 into procedures for carbon trading, results-based payment, carbon levies, measurement and verification, issuance of SPE-GRK certificates and recording in the SRN-PPI registry.

What Permen LHK 21/2022 is

The Indonesian title is Tata Laksana Penerapan Nilai Ekonomi Karbon (procedures for implementing carbon economic value). It was issued by the then-combined Ministry of Environment and Forestry (KLHK) as the main implementing rule under Perpres 98/2021.

Where the Perpres set principles, Permen LHK 21/2022 set the workflow. At a high level, it covered:

• The NEK instruments: carbon trading (emissions trading and offsetting), results-based payment and carbon levies.
• Mitigation action design: the DRAM (Dokumen Rancangan Aksi Mitigasi), a design document describing the activity, baseline, boundaries and monitoring plan.
• Measurement, reporting and verification (MRV) of results by accredited verifiers.
• Certification of verified results as SPE-GRK, the domestic emission reduction certificate.
• Registration of actions, results and certificates in SRN-PPI.
• Roles for the ministry, sector ministries and businesses.

We do not cite article numbers or deadlines from it here. Use the official text if you need them.

Who it applied to

The regulation applied across NEK sectors, but forestry was central because forest and land use carry the largest share of Indonesia’s NDC reductions. In practice it reached:

• Businesses with emission caps (later PTBAE-PU holders).
• Project proponents wanting to certify offsets, including forest licence holders and social forestry permit holders.
• Verifiers, who had to work within the domestic MRV process.
• Buyers of SPE-GRK, including on IDXCarbon from 2023.

Forestry-specific trading steps came in a separate rule, Permen LHK 7/2023.

What it required and changed

Permen LHK 21/2022 created a domestic project cycle that mirrors international standards:

The key change for developers was that a project could no longer rely only on an international registry if its units were to count in Indonesia or trade domestically. The domestic cycle had to be followed too.

What it meant for forest carbon developers and buyers

For developers, the regulation added a second set of documents and approvals. Many teams found that their international project documents could be adapted, but not reused as they stood: baselines, boundaries and monitoring periods had to fit domestic formats. Clean, well-documented field data made adaptation easier. Our PDD development work covers both formats.

For buyers, Permen LHK 21/2022 created a recognisable domestic product (SPE-GRK) with a government-run registry record. That helped compliance buyers and domestic voluntary buyers. International buyers still needed clarity on transfer and corresponding adjustments, which this regulation did not fully resolve.

Where it stands in 2026

Three things have changed since 2022:

1. Perpres 110/2025 became the legal anchor, reworking the Perpres 98/2021 base on which this regulation rested.
2. The ministry was split into a Ministry of Environment (with BPLH) and a Ministry of Forestry, each issuing its own rules. Forestry now has Permenhut 6/2026.
3. SRUK replaced SRN-PPI as the registry for traded carbon units.

Concepts from Permen LHK 21/2022 persist in the new rules. For example, secondary reporting on the 2026 waste-sector rule refers to transitional treatment of DRAM records. So the 2022 vocabulary is still useful even where the text itself has been overtaken.

Lessons that still apply

Three lessons from the 2022 procedure carry straight into the 2026 rules. First, write project documents so they can be mapped to a domestic format, not only to an international template. Second, keep the evidence behind every number (plot data, imagery, calculations) in a form a domestic verifier can audit. Third, expect government approval steps and build their timing into the project plan and any offtake contract. Projects that followed these habits under Permen LHK 21/2022 have found the move to SRUK and the new sector procedures easier.

Open questions

• Formal status. Check whether the 2026 regulations revoke Permen LHK 21/2022 in full, in part, or leave parts in force for sectors without new rules.
• Legacy documents. Projects with approved DRAMs or SPE-GRK under the old process should confirm how their records move into SRUK.
• Levy and RBP detail. Procedures for carbon levies and results-based payment under the new framework should be read from the current texts, not inferred from 2022.

For the sequence of rules, see the regulation timeline and the Indonesia regulation hub.