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Contributors: Almaida Askandar, S.H., MBA, Nita Damayanti, S.H., and Clarissa Felicia Hidriani, S.H.

Published on 8 August 2026 by IABF Law Firm, Jakarta, Indonesia.

Key Amendments to the IDX Carbon Regulations Following the Implementation of the Carbon Unit Registry System

I.       Introduction

Presidential Regulation No. 110 of 2025 on the Implementation of Carbon Economic Value Instruments and National Greenhouse Gas Emission Control (“Presidential Regulation 110/2025“) came into force on 10 October 2025 and revoked Presidential Regulation No. 98 of 2021 (“Presidential Regulation 98/2021“). Presidential Regulation 110/2025 continues to recognize a carbon exchange as one of the mechanisms through which carbon trading may be conducted. To align the carbon exchange framework with Presidential Regulation 110/2025, the Financial Services Authority (Otoritas Jasa Keuangan or “OJK“) issued OJK Regulation No. 10 of 2026 amending OJK Regulation No. 14 of 2023 on Carbon Trading through the Carbon Exchange (“OJK Regulation 10/2026“). The Board of Directors of the Indonesia Stock Exchange (“IDX“) subsequently issued the following decisions (collectively, the “IDX Directors’ Decisions“):

1. 1. IDX Board of Directors Decision No. Kep-00102/BEI/07-2026 on the Amendment to the Regulation on Carbon Exchange Service Users (“Decision 102/2026“);
   2. IDX Board of Directors Decision No. Kep-00103/BEI/07-2026 on the Amendment to the Regulation on the Registration of Carbon Units with a Carbon Exchange Operator (“Decision 103/2026“);
   3. IDX Board of Directors Decision No. Kep-00104/BEI/07-2026 on the Amendment to the Regulation on Carbon Unit Trading through a Carbon Exchange Operator (“Decision 104/2026“); and
   4. IDX Board of Directors Decision No. Kep-00105/BEI/07-2026 on the Amendment to the Regulation on the Supervision of Trading through the Carbon Exchange (“Decision 105/2026“).

II.      Expanded Carbon Units Categories

The IDX Directors’ Decisions align the terminology used in the IDX Carbon regulations with OJK Regulation 10/2026 and the Carbon Unit Registry System (Sistem Registri Unit Karbon or “SRUK“). In particular, the regulations now accommodate Greenhouse Gas Emission Quotas, Greenhouse Gas Emission Reduction Certificates, non-SPE-GRK carbon units, and carbon units that are not recorded in SRUK, subject to the applicable laws and regulations.

III.    Carbon Exchange Service Users

Under the previous regulation, Service Users were expressly categorized as emissions trading business actors, non-emissions trading business actors, project owners, or other parties approved by OJK. Decision 102/2026 no longer retains these specific categories and instead regulates Service Users based on the carbon units and trading activities available to them.

IV.    Registration of Carbon Units with the Carbon Exchange Operator

A.       Tradable Carbon Units

Decision 102/2026 permits Service Users to trade the following carbon units:

1.      Carbon units recorded in SRUK, comprising:

a.      Greenhouse Gas Emission Quotas (Kuota Emisi Gas Rumah Kaca or “GHG Emission Quotas“);

b.     Greenhouse Gas Emission Reduction Certificates (Sertifikat Pengurangan Emisi Gas Rumah Kaca or “SPE-GRK“); and

c.      non-SPE-GRK carbon units.

2.      Carbon units not recorded in SRUK, subject to the applicable laws and regulations.

B.      Expanded Trading Activities

Decision 102/2026 permits Service Users to conduct the following activities:

1. 1. 1. registering SPE-GRK, non-SPE-GRK carbon units, and carbon units not recorded in SRUK in accordance with the applicable carbon-unit registration rules;
      2. selling carbon units through the Auction Market where the Service User owns the relevant carbon units or has been authorized by their owner;
      3. selling SPE-GRK, non-SPE-GRK carbon units, and carbon units not recorded in SRUK through the Regular Market, Negotiated Market, and Non-Regular Market;
      4. purchasing those carbon units through the Regular Market, Negotiated Market, Auction Market, and Non-Regular Market; and/or
      5. retiring SPE-GRK, non-SPE-GRK carbon units, and carbon units not recorded in SRUK.

For transactions involving GHG Emission Quotas, Decision 102/2026 permits the following activities:

1. 1. obtaining an allocation of GHG Emission Quotas through purchases in the Auction Market;
   2. buying and selling GHG Emission Quotas through the Regular Market and Negotiated Market;
   3. surrendering GHG Emission Quotas; and
   4. applying for the addition of a specific category of Service User permitted to purchase GHG Emission Quotas in the Auction Market and/or trade them in the Regular Market and Negotiated Market.

Carbon Exchange Operator Authority and Disclaimer

Carbon Exchange Operator has authority to approve or reject registration applications submitted by Service Users, prospective Service Users, or the Relevant Ministry.

Carbon Exchange Operator does not validate or vouch for the accuracy, adequacy, or content of the Carbon Unit documentation submitted, it disclaims responsibility for the substance of what’s registered.

V.     Deregistration of Recorded Carbon Units

Previously, recorded carbon units could be deregistered upon their expiry, at the request of the relevant ministry, or at the request of the project owner. Decision 103/2026 expands these grounds to include a request from the business actor trading the relevant SPE-GRK, non-SPE-GRK carbon unit, or carbon unit not recorded in SRUK, as well as OJK’s revocation of the registration approval for a carbon unit not recorded in SRUK.

VI.    Market Mechanism and Extended Trading Hours

Mechanism of Market

• • Auction Market: GHG Emission Quotas (Kuota Emisi GRK) are auctioned by the Relevant Ministry; SPE GHG/non-SPE GHG/units not recorded on SRUK are auctioned by their owners (who may appoint another Service User to act as the auction organizer). Winners are determined based on price priority and time priority. Each series may only be auctioned once.
  • Regular Market: operates on a continuous auction mechanism; three order types are available, limit order, market order, and stop order. The price fraction is set at Rp200, with a minimum price of Rp200, and an Auto Rejection mechanism applies if the price deviates more than 20% from the reference price.
  • Negotiated Market: direct bilateral bargaining between Service Users, subsequently confirmed through the exchange system.
  • Non-Regular Market: specifically for SPE GHG/non-SPE GHG/units not recorded on SRUK, the seller sets a price, the buyer may accept it or submit a different price, and the seller then confirms.

Trading Hours

IDX Carbon’s trading hours extended from 9:00 a.m.-3:00 p.m. to 7:00 a.m.-7:00 p.m. Western Indonesian Time on Carbon Exchange Days. The amendment therefore doubles the daily trading window available to market participants.

VII.  Supervision of Trading through the Carbon Exchange

Prohibitions for Carbon Exchange Service Users:

• • Creating a false impression regarding the activity/price movement of a Carbon Unit (wash trading);
  • Trading that could potentially cause market manipulation;
  • Engaging in fraudulent, manipulative transactions, or using insider information (insider trading);
  • Carrying out transactions based on false or misleading statements/information;
  • Creating a misleading impression that a Carbon Unit is actively traded when it is not, or encouraging irregular/unfair transactions.

In carrying out its supervisory function, if there is an indication of a violation, the Carbon Exchange Operator may take the following actions:

1. 1. requesting an explanation, either directly or indirectly, from the Carbon Exchange Service User;
   2. temporarily halting trading of a Recorded Carbon Unit and/or imposing a temporary ban on trading activity at the PBK (suspension) on the Carbon Exchange Service User;
   3. lifting the temporary halt on trading of a Recorded Carbon Unit and/or the temporary ban on trading activity at the PBK on the Carbon Exchange Service User as referred to in provision II.5.2 of this Regulation;
   4. coordinating with relevant parties, including the Financial Services Authority (OJK) and/or the Relevant Ministry;
   5. examining orders and/or transactions indicated as irregular;
   6. reporting to OJK if an indication of a violation is found; and/or
   7. taking any other action necessary to carry out its supervisory function

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Disclaimer

This news update is prepared for general informational purposes only. The content does not constitute legal advice, a legal opinion, or counsel from IABF Law Firm. The information contained herein may not reflect the most current developments. Any quotation, distribution, or use of this information for any purpose is solely at the user’s own risk.