BPH Migas Regulation 2/2026 Regulates the Obligation to Obtain an NRU and Install QR Codes for Fuel Oil Business Entities

Introduction

On 11 August 2026, the Downstream Oil and Gas Regulatory Agency (“BPH Migas”) enacted BPH Migas Regulation Number 2 of 2026 concerning Business Registration Numbers for Fuel Oil (“BPH Migas Regulation 2/2026”), which took effect on 18 August 2026 and became effective as of the date of promulgation. This regulation governs the obligation to hold, as well as the procedures for the issuance of, a Business Registration Number (“NRU”) for every business entity holding a business licence for the processing, transportation, storage, and/or trading of fuel oil (“BBM”).

BPH Migas Regulation 2/2026 was established to achieve orderly administration while improving the effectiveness of BPH Migas in carrying out its duties and authorities in supervising the supply and distribution of BBM in Indonesia. This regulation also replaces BPH Migas Regulation Number 3 of 2022 concerning Business Registration Numbers for Fuel Oil, which is considered no longer consistent with legal developments and the needs of the public. Through this new regulation, BPH Migas accommodates the need for a more integrated and technology-based NRU administrative system to support legal certainty and the effectiveness of supervision of BBM business activities.

Key Provisions

• Issuance and Format of the Business Registration Number

Article 2 requires every business entity holding a business licence for the supply and distribution of BBM to have an NRU for each type of business licence it holds. BPH Migas issues NRUs to business entities conducting activities involving the processing of crude oil or processed products, transportation of BBM through pipelines, storage of BBM, and/or trading of BBM. NRUs are issued based on business licensing data received through the integration of the BPH Migas application system with the business licensing system of the Ministry of Energy and Mineral Resources, which has been integrated with the OSS System.

Article 3 stipulates that the NRU is issued in the form of an electronic certificate and QR Code signed by the Head of BPH Migas. The certificate must contain at least the NRU code, business entity name, type of business licence, business licensing number, validity period, and business entity address. The NRU code is structured based on the type of business licence, sequential registration number, provincial and regency/city location, as well as the month and year in which the validity period of the business licence expires. The numbering format and form of the NRU certificate and QR Code are further stipulated in the appendices to BPH Migas Regulation 2/2026.

• Obligation to Install the NRU QR Code

Referring to Article 4, business entities holding an NRU are required to install the NRU QR Code on each main facility and/or infrastructure listed in their business licensing. The QR Code must be placed in a location that is readily visible, with its size adjustable to the condition of the relevant infrastructure or facility. The procedure for installing the NRU QR Code is further stipulated in Appendix III to BPH Migas Regulation 2/2026:

• Procedure for obtaining the NRU QR Code:

1. Open the licensing application available through the Ministry of Energy and Mineral Resources and/or BPH Migas.

2. Log in using the business entity's user ID.

3. Select the licence reporting menu → Manage Reporting, which will then direct the user to the Silvia BPH Migas application.

4. Select the Business Entity Data → NRU menu.

5. Select the View NRU QR Code action to display the QR Code details.

6. Determine the QR Code size as appropriate for each infrastructure and/or facility.

7. Select Print NRU QR Code..

 

• Locations for installing the NRU QR Code

 

• Functions and Use of the Business Registration Number

Article 5 stipulates that the NRU serves as a registration requirement for business entities to participate in the selection process for the assignment of the supply and distribution of Certain Types of Fuel Oil and/or Special Assignment Fuel Oil in general BBM trading business activities. In addition, the NRU is used to record the ownership of infrastructure and facilities by business entities in BBM supply and distribution activities and serves as one of the forms of assessing business entity compliance.

• Administrative Sanctions for Violations of the NRU Obligations

Article 7 stipulates administrative sanctions for business entities holding an NRU that violate the obligation to install the NRU QR Code and other obligations as stipulated in BPH Migas Regulation 2/2026. Such sanctions consist of a written warning and/or revocation of the NRU.

A written warning may be issued up to three times, with each warning having a maximum period of one month. If the business entity has not fulfilled its obligations after the expiry of the third written warning, BPH Migas may revoke the relevant NRU. However, the NRU may be reissued if the business entity has fulfilled its obligations and submitted supporting data as evidence that the violation has been remedied.

Transitional Provisions

Article 8 regulates transitional provisions for NRUs that have already been issued and those whose issuance is still in process when BPH Migas Regulation 2/2026 comes into force. NRUs issued before the regulation came into force remain valid until the expiry of the validity period of such NRUs.

Meanwhile, NRUs whose issuance was still in process before this regulation came into force will continue to be processed in accordance with the provisions of BPH Migas Regulation 2/2026. Accordingly, the regulatory changes do not automatically invalidate NRUs that are already in force or issuance processes that are ongoing.

Closing

BPH Migas Regulation 2/2026 strengthens the governance of NRUs through an issuance process integrated with the business licensing system, the obligation to install QR Codes on BBM infrastructure and facilities, and the utilisation of NRUs as an instrument for data collection and assessment of business entity compliance. This regulation also provides certainty for business entities through transitional provisions that maintain the validity of NRUs that have already been issued and regulate NRU issuance processes that are still ongoing.

For business entities engaged in the processing, transportation, storage, and/or trading of BBM, the implementation of BPH Migas Regulation 2/2026 requires particular attention, especially with respect to holding an NRU for each type of business licence and fulfilling the obligation to install the NRU QR Code. Compliance with these provisions is important given that violations may result in sanctions ranging from written warnings to revocation of the NRU.