The Permanent Moratorium on New Licences in Primary Forest and Peat

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

Indonesia's primary forest moratorium (moratorium hutan primer): Inpres 5/2019, the PIPPIB map, what it covers and what it means for carbon projects.

The primary forest moratorium (moratorium hutan primer) is Indonesia’s halt on issuing new licences in primary natural forest and peatland. It started as a temporary measure under Presidential Instruction (Inpres) 10/2011 and was made permanent by Inpres 5/2019; the areas covered are shown on the PIPPIB indicative map, which the government revises periodically.

What it is

An Inpres is an instruction from the President to ministers and regional heads. It is not a law that binds private parties directly. It directs officials not to grant certain approvals. The 2011 instruction was extended several times before Inpres 5/2019 made the halt permanent.

The covered areas are drawn on the Peta Indikatif Penghentian Pemberian Izin Baru (PIPPIB), the indicative map of the halt on new licences. “Indicative” matters: the map is updated, areas are added or removed after field checks, and boundaries can be contested. Always use the latest official version for any site assessment.

Who it applies to

The instruction directs national ministries, governors and district heads. In practice it affects:

• Companies seeking new licences for plantations, logging, mining or other land uses in mapped primary forest or peat. Those licences should not be issued.
• Existing licence holders, whose licences generally continue if issued before the area was mapped. Other rules, such as the peat protection rules, still apply.
• Carbon project developers, because the map shapes which areas face legal conversion pressure and which do not.

The instruction lists exceptions for certain national strategic or public-interest activities. We do not list them here because the exact scope has been read differently over time. Check the text.

What it requires and changes

The moratorium does three things:

1. It stops new licences in mapped primary natural forest and peatland.
2. It requires the indicative map to be maintained and updated.
3. It asks relevant agencies to improve forest and peat governance.

It does not, on its own, protect secondary forest, and it does not cancel existing licences. Deforestation can still happen in mapped areas through illegal clearing, fire or smallholder expansion, so the map is not the same as actual protection on the ground.

What it means for developers and buyers

For REDD+ baselines. A REDD+ project must show what would happen without it. If the site is inside the PIPPIB map, a baseline of planned conversion under a new licence is hard to defend, because the law says no new licence should be issued. Unplanned deforestation from local drivers may still be credible, but it needs evidence. This is part of the wider REDD+ baseline debate. Validators and rating agencies will check map status.

For ARR. Primary forest and peat are not ARR targets. ARR suits degraded land. Map status helps confirm that you are not planting in primary forest or on peat where other rules apply. See land eligibility and the 10-year rule.

For concessions. Holders of PBPH licences with primary forest inside their area may find carbon a better use of that forest than conversion, especially where conversion is restricted.

For buyers and EUDR. The moratorium reduces legal conversion of primary forest, but the EUDR cut-off date of 31 December 2020 applies to any deforestation, legal or not. A commodity grown on land cleared after that date fails EUDR even if the clearing was licensed.

Data. Overlaying your project area on the current PIPPIB map, peat maps and deforestation alerts is a basic step in feasibility and eligibility work.

How to check a site against the moratorium

A practical screening sequence for any forest carbon or commodity site:

1. Draw the project boundary as polygons, not points, and record the source and date of each boundary.
2. Overlay the boundary on the current PIPPIB revision and note the revision number or date.
3. Overlay the official peat map and forest area status map, because the moratorium, the peat rules and the forest estate boundaries are separate layers.
4. Check existing licences and permits on the same land, including any that were issued before the area entered the map.
5. Review deforestation and fire history from satellite data since at least 2011, the year the first moratorium began.
6. Keep a dated record of every layer you used, so a validator or buyer can repeat the check.

This screening does not replace legal advice, but it catches most of the problems that later surface during validation or due diligence.

Open questions

• Map revisions. Each revision can move boundaries. Projects should record which version they used and check later versions.
• Exceptions. How strategic national projects interact with the moratorium is not always transparent.
• Enforcement. Studies by NGOs and researchers have found deforestation inside mapped areas. Do not assume the map equals protection; check satellite data. See drivers of deforestation in Indonesia.
• Carbon use of mapped areas. It is not fully clear how the moratorium interacts with new carbon-related business permits in mapped forest. Read the current forestry carbon procedure, Permenhut 6/2026.

For the complete regulatory picture, start at the Indonesia regulation hub.