Perpres 110/2025: The New Legal Anchor for Carbon Trading

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

Perpres 110/2025 is the legal anchor for Indonesian carbon trading. What it covers, the 2026 rules built on it, and what it means for forest carbon projects.

Perpres 110/2025 is the Presidential Regulation on implementing carbon economic value instruments and controlling national greenhouse gas emissions, and it is now the legal anchor for carbon trading in Indonesia. Every major 2026 carbon rule, from the exchange amendment POJK 10/2026 to the forestry procedure Permenhut 6/2026 and the new SRUK registry, is built on it.

What Perpres 110/2025 is

The Indonesian title is Penyelenggaraan Instrumen Nilai Ekonomi Karbon dan Pengendalian Emisi Gas Rumah Kaca Nasional. It sits at the same level as Perpres 98/2021, the regulation that first set up the carbon economic value (NEK) framework, and secondary sources describe it as changing provisions of that earlier regulation.

In practice, Perpres 110/2025 keeps the NEK idea (carbon pricing serves the national climate target) and gives it new machinery. The government’s carbon steering committee secretariat (Komrah NEK) describes the business process as covering all NEK instruments:

• carbon trading, domestic and international;
• results-based payment (RBP);
• carbon levies (pungutan atas karbon);
• Article 6 Paris Agreement schemes.

Who it applies to

Perpres 110/2025 assigns roles to ministries and agencies, and the implementing rules then apply to businesses and communities. In the 2026 set-up:

The parties affected include compliance companies holding emission allowances, project developers and proponents, social forestry groups and customary communities, and domestic and foreign buyers.

What it changes

The visible changes in 2026 all trace back to Perpres 110/2025:

1. A new registry. Carbon units traded on the exchange must be recorded in SRUK, which replaces SRN-PPI for that purpose. Secondary sources report that Permen LH/BPLH 10/2026 on SRUK took effect on 6 July 2026 and that SRUK launched on 9 July 2026.
2. Updated exchange rules. POJK 10/2026 amends POJK 14/2023 and applies from 6 July 2026. A third-party IDXCarbon guide says the amendment aligns the exchange with Perpres 110/2025.
3. Sector procedures. Forestry got Permenhut 6/2026, socialised on 29 April 2026. Waste got Permen LH/BPLH 11/2026, set on 12 August 2026. Other sectors may follow.
4. International pathways. Sector rules now separate foreign trades that require government authorisation and a corresponding adjustment, including Article 6.2 and 6.4 transfers, from those that do not.
5. A market launch date. The Komrah NEK secretariat targeted full operation of the national carbon market from 7 July 2026.

What it means for forest carbon developers and buyers

For developers, Perpres 110/2025 confirms that Indonesian forest carbon runs on two tracks at once. A project may be certified under an international standard such as the Verra VCS Program or Plan Vivo, and it still needs to fit the domestic chain: mitigation activity, measurement, validation and verification, recording in the national registry, then trading. Plan your monitoring data so it can serve both. Field plots, consistent IDs and clean geospatial boundaries make the double reporting much cheaper.

For buyers, the framework is clearer than it was in 2022–2024, but the questions to ask are the same: Is the unit recorded in SRUK? Is it authorised for the use you intend? Will Indonesia apply a corresponding adjustment? Our Article 6 hub explains the international side.

For social forestry and customary groups, the forestry rule built on Perpres 110/2025 names them as legitimate, equal participants. See carbon in social forestry.

A practical checklist under Perpres 110/2025

Before you sign an offtake or start a new forest project, work through these points:

1. Which sector rule applies? Forestry activities follow Permenhut 6/2026; other sectors follow their own ministry’s rule.
2. Who holds the right to the carbon? Confirm the licence, permit or customary recognition behind the project area before anything else.
3. Which registry records the units? Plan for SRUK recording, plus any international registry, and keep the two consistent.
4. Which market will you use? Exchange trading, direct trading and international transfer each carry different conditions.
5. What claim does the buyer want? A domestic offset, a voluntary claim abroad or an Article 6 transfer each need different paperwork.

Open questions

• Exact relationship with Perpres 98/2021. Confirm the revocation and transitional clauses in the official text.
• Authorisation procedure. Our research found no reliable public source describing the step-by-step procedure for authorising units for Article 6 transfer.
• Levy design. Carbon levies are listed as an instrument; the rates and collection mechanism should be checked against the latest implementing rules rather than assumed.
• Mutual recognition. How international standards are recognised domestically is still developing; see mutual recognition arrangements.

Track the sequence on our regulation timeline, or start from the Indonesia regulation hub. For a reading of how the framework applies to a specific site and tenure, see our regulatory navigation service.