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Legal Updates

Implementation of Standard Criteria for Mining Land Degradation under Minister of Environment/Environmental Control Agency Regulation Number 20 of 2025

5 November 2025
Ivonnie Wijaya, Steven Aristides Wijaya
Legal Updates
Implementasi Kriteria Baku Kerusakan Lahan Tambang Berdasarkan Permen LH/BPLH 20 Tahun 2025

Summary

Regulation of the Minister of Environment/Environmental Control Agency Number 20 of 2025 concerning Standard Criteria for Environmental Damage to Land Due to Mining Business and/or Activities (“MoE/BPLH Reg 20/2025”) was issued on October 15, 2025, and took effect on its date of promulgation on October 23, 2025.

This regulation implements the provisions of Government Regulation Number 22 of 2021 concerning the Implementation of Environmental Protection and Management (“GR 22/2021”) by providing clear, measurable, and nationally uniform technical benchmarks for determining when land affected by mining activities is legally deemed to have sustained damage.

Background and Context

The issuance of this regulation is based on the need to implement the mandate of Article 272 paragraph (5) of GR 22/2021, as well as to clarify the criteria for land "damage" resulting from mining activities, which previously lacked a uniform definition. Thus, this regulation is expected to help mining business operators measure their environmental management performance and to serve as a basis for the government in supervising and enforcing laws related to land degradation.

Key Provisions

The main substance of this regulation is reflected in the following key provisions:

Regulatory Aspect Description Article
Prevention Obligation

Mining business operators are obligated to prevent Environmental Damage. This prevention is carried out through two methods:

  1. compliance with the Standard Damage Criteria, and
  2. monitoring of the Standard Damage Criteria.
 Article 2
Damage Parameters The Standard Criteria for Land Damage are established based on three parameters: Physical, Chemical, and Biological. The Physical parameters cover 9 aspects (former mine areas, Topsoil, slope, erosion, landslides, Surface Water Runoff, Groundwater level, activity distance, and Mine Openings). The Chemical parameter consists of Potentially Polluting Rock. The Biological parameters cover 3 aspects (vegetation, land cover, biodiversity). The technical details of these criteria are listed in Annex I. Article 3
Definition of Compliance "Compliance" (adherence) is explicitly defined as the fulfillment of all Standard Criteria for Environmental Damage stipulated in this regulation. Article 4
Monitoring Stages Monitoring implementation must be preceded by a planning stage. This planning includes the collection of permit documents (environmental approvals, Mining Business Permit [Izin Usaha Pertambangan (IUP)], geotechnical studies, hydrogeological studies, etc.), equipment preparation, and the preparation of a detailed annual monitoring plan document. Article 5 & Article 6
Monitoring Frequency This regulation sets different monitoring frequencies: At least once every six months for dynamic parameters (e.g., Topsoil, slope, erosion, landslides, Surface Water Runoff, Groundwater level, Potentially Polluting Rock, activity distance, Mine Openings, and biodiversity). At least once every one year for parameters with slower changes (former mine areas, riparian vegetation, and land cover of revegetation areas). Article 7
Reporting & Consequences The person in charge of the business must report the monitoring results to the Minister/Head or governor according to their authority. This report will be evaluated to determine whether "land damage occurred" or "no damage occurred". If damage is found, the business operator must carry out mitigation and/or recovery. If not, the prevention obligation continues. Article 8
Enactment This regulation takes effect on its date of promulgation, namely October 23, 2025. Article 9

Annex I: Summary of Standard Damage Criteria

Parameter Key Aspect Standard for Damage (Deemed Damaged If...)
PHYSICAL
Former Mine Areas Management Disturbed areas that are inactive (post-mining land, inactive) are not managed environmentally (e.g., without revegetation or cover crop) for more than 1 year.
Topsoil Availability & Spreading
  1. The available volume of Topsoil in the storage facility is less than 75% of the existing potential (calculated); OR
  2. The spreading of Topsoil in the reclamation area is less than 75% of the Topsoil volume stored in the facility.
Slope Stability

One of these 3 conditions is met:

  1. The slope angle of the area (mine opening, stockpile) is greater than 25%;
  2. The slope angle is greater than 5° from the approved geotechnical study recommendation; OR
  3. The slope height is greater than 10% from the geotechnical study recommendation.
Erosion Rate & Form
  1. The Erosion Rate (calculated using the Universal Soil Loss Equation (USLE)) method.”) in inactive mining blocks is more than 180 tons/ha/year; OR
  2. Rill and/or gully erosion is found (dimensions: width >20 cm, depth >5 cm) with a density of more than 20% of the slope width.
Landslides Occurrence A landslide occurs in the mine opening area (active/inactive). (This excludes deliberate collapses resulting from blasting activities).
Surface Water Runoff Management & Capacity
  1. Topsoil/mining material storage facilities are not equipped with Surface Water Runoff management for Erosion control;
  2. The capacity of the mine water catchment facility is less than 1.25 times the water volume at the highest rainfall over 84 hours;
  3. The TSS (Total Suspended Solids) parameter at the outlet exceeds the quality standard set in the technical approval; OR
  4. There is unmanaged flow in the catchment area.
Groundwater Level Drawdown Groundwater level drawdown occurs in a monitoring well that exceeds 60% of the initial Groundwater level (before mining activities). (Only applies if monitoring wells are required in the environmental document).
Activity Distance Riparian/Buffer Zone
  1. The distance of the Mine Pit (active/inactive) is less than 500 meters from the boundary of rivers, reservoirs, lakes, seas, public infrastructure, and/or settlements; OR
  2. The distance does not comply with the geotechnical study.
Mine Openings Legality
  1. A Mine Opening is found outside the legal permit boundary (Mining Business Permit [Izin Usaha Pertambangan (IUP)]) that is valid; OR
  2. A river diversion is found that lacks permits or approvals (or does not comply with the granted permit).
CHEMICAL
Potentially Polluting Rock Acidity (pH)
  1. The acidity (pH) of soil or standing/seepage water in inactive areas (stockpiles, etc.) is less than 4 or more than 11; OR
  2. The acidity (pH) in the mine pit (void) has not reached the stable range of 6-9 and other water quality parameters are not yet stable (in accordance with the post-mining plan).
BIOLOGICAL
Riparian Vegetation Cover The vegetation cover condition in the riparian zone of a Water Body (river, lake, etc.) and/or the sea is less than 90% of the total applicable riparian area.
Land Cover of Revegetation Area Success
  1. Revegetation success is less than 80% of the total planned revegetation obligation area; OR
  2. A negative change (decrease in vegetation index value) of more than 20% occurs during monitoring in the 3rd year after planting.
Biodiversity Mitigation No mitigation efforts are found to address the fragmentation of important biodiversity habitats (protected species, endemic species, etc.). Mitigation examples: construction of wildlife corridors, bridges, or tunnels.

Annex II: Summary of Monitoring Implementation Procedures

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Monitoring Criteria Main Implementation Method
Former Mine Areas Analysis of remote sensing results (medium-high resolution satellite imagery and/or drones) to identify disturbed areas with no mining or environmental management activities.
Topsoil
  1. Availability: Analysis of imagery/drones and calculation studies of the potential soil volume in storage facilities.
  2. Spreading: Analysis of imagery/drones and calculation studies of the soil volume that has been spread in reclamation areas.
Slope Measurement of slope angle and height (single or overall) in the field, then compared with the 25% limit or specific recommendations from the geotechnical study.
Erosion
  1. Analysis using the USLE (Universal Soil Loss Equation) method in inactive mining block areas.
  2. Analysis of imagery or field observations to identify the presence of rill/gully erosion (width >20 cm, depth >5 cm) on reclaimed land or stockpiles.
Landslides Analysis of imagery, maps, and/or field observations in areas with landslide potential to look for indications of soil and rock movement/landslides.
Surface Water Runoff Analysis of remote sensing (imagery/drone), hydrological modeling, and calculation studies of the actual capacity of runoff water management facilities (ensuring they can accommodate the highest 84-hour rainfall x 1.25).
Groundwater Level Measurement of groundwater level data trends periodically from monitoring wells, then compared with baseline data (before mining activities).
Activity Distance & Mine Openings Analysis of remote sensing results (satellite imagery/drone) to map the location of mine openings, then compared (overlaid) with permit boundary maps (Mining Business Permit [Izin Usaha Pertambangan (IUP)], Forest Area Approval, River Channel Permit) and the 500m distance from vital objects.
Potentially Polluting Rock Direct pH measurement in the field (soil pH, surface water, standing water, or leachate). As well as water quality sampling in mine pits (voids) according to Indonesian National Standards [Standar Nasional Indonesia (SNI)].
Land Cover of Revegetation Area Analysis of remote sensing (imagery/drone) to calculate the percentage of revegetation achievement (> 80%) and to calculate the vegetation index (NDVI) to monitor negative changes (< 20%).
Biodiversity Analysis of imagery, reports, and field observations to verify the existence of protection/mitigation efforts for habitat fragmentation (e.g., bridges, tunnels, or habitat corridors).

Annex III: Reporting Format Structure

Report Section Description
1. Reporter's Identity Includes complete administrative data: Company Name, Activity Address (Regency/City, Province), Phone/Fax No., Email, Contact Person, and Reporting Period (Example: Semester I of 2026).
2. Monitoring Results Presented in a standard table format covering all parameters from Annex I. Table columns must include: Parameter, Specific Location (monitoring point), Result (measurement data), and Notes (supporting information, e.g., management efforts that have been undertaken).
3. Supporting Attachments

This section is mandatory and is used for report data validation. Must at least attach:

  1. Related Permit Documents,
  2. Permit Map (as a basis for comparison),
  3. Imagery of management activities (e.g., drone/satellite imagery), and
  4. Photo/video documentation of management activities in the field.

Conclusion

MoE/BPLH Reg 20/2025 establishes the technical benchmarks for defining mining "land damage". Two key points that require attention from persons in charge of mining businesses and/or activities are:

  1. The obligation to comply with all standard criteria (physical, chemical, biological) stipulated in Article 3 and Annex I; and

  2. The obligation to conduct monitoring, reporting, and recovery actions if an exceedance of the damage standards occurs.

Related Regulations

Click a regulation to view details.

Peraturan Menteri Lingkungan Hidup/Badan Pengendalian Lingkungan Hidup Nomor 20 Tahun 2025 tentang Kriteria Baku Kerusakan Lingkungan Hidup untuk Lahan Akibat Usaha dan/atau Kegiatan Pertambangan
Peraturan Pemerintah (PP) Nomor 22 Tahun 2021 tentang Penyelenggaraan Perlindungan dan Pengelolaan Lingkungan Hidup
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