Decree of the Minister of Marine Affairs and Fisheries Number 25 of 2026 Determines Blue Carbon Locations and Verifies Land Tenure

Introduction

On April 15, 2026, the Minister of Marine Affairs and Fisheries (“MoMAF”) issued Decree of the Minister of Marine Affairs and Fisheries Number 25 of 2026 on the Guidelines for Determining Blue Carbon Management Locations ("MoMAF Decree 25/2026"). MoMAF Decree 25/2026 provides technical guidelines for the central and regional governments to verify and designate coastal ecosystem locations as blue carbon management areas.

MoMAF Decree 25/2026 serves to support climate change mitigation in the marine and fisheries sector, with reference to Presidential Regulation Number 110 of 2025 on the Implementation of Carbon Economic Value Instruments and the Mitigation of National Greenhouse Gas Emissions. This Decree governs the stages for determining blue carbon management locations through a data-driven process and field verification. This Decree serves as a basis to ensure that blue carbon management locations can be utilized in the calculation of the Nationally Determined Contribution ("NDC"), the national registry, and the Carbon Economic Value (Nilai Ekonomi Karbon, “NEK”) scheme.

Key Provisions

Criteria for Selecting Blue Carbon Management Locations

The FIRST Dictum stipulates the Guidelines for Determining Blue Carbon Management Locations in the Marine and Fisheries Sector as set forth in the Annex. Annex Chapter II Letter C governs five criteria that must be met before an area is designated as a blue carbon management location. For businesses, these criteria can serve as a reference in assessing the feasibility of activities, which include:

1. Suitability of the location for the presence of blue carbon ecosystems within spatial plans and/or zoning plans;

2. Status and legality of land (including land and waters) in accordance with applicable laws and regulations, spatial allocation, and free from disputes;

3. Socioeconomic support that can be provided by the government, private institutions, society, or local communities;

4. Biophysical conditions of the area that are accessible and at risk of emissions, biophysical degradation, and land conversion; and

5. Synergy with other activities.

Selection Stages and Public Consultation

The stages for determining blue carbon management locations encompass identification, analysis, verification and validation, public consultation, and determination of blue carbon management locations as stipulated in Annex Chapter III. Businesses participate in the public consultation stage, which is governed under Annex Chapter III Point 4. During this stage, businesses alongside the government, academics, local communities, traditional communities, customary law communities, and civil society organizations participate in providing input to obtain stakeholder agreement and support.

Cross-Sectoral Synergy in Blue Carbon Management

Annex Chapter III Point 2 governs the analysis of synergy with other activities in determining blue carbon management locations. This provision mandates the assessment of the plan's compatibility with other activities, both sectoral and cross-sectoral. Blue carbon management involves collaboration among ministries, agencies, institutions, the private sector, and the public. Synergy among activities is directed to enhance beneficial values, improve resource efficiency, and ensure program sustainability.

Spatial Technical Standards and Map Resolution

Annex Chapter III Point 2 governs spatial data analysis in determining blue carbon management locations. In drafting the analysis document, the Review Team for the Determination of Blue Carbon Management Locations employs an overlay method for maps of prospective blue carbon locations with a minimum scale of 1:50,000 and conducts boundary delineation with at least three coordinate points. This provision must be met to ensure the analysis document complies with technical requirements during the evaluation process.

Field Verification and Land Status

Annex Chapter III Point 3 and Form C Section D.2 govern field verification and validation, including the verification of land status and legality. In this stage, companies present documents demonstrating land tenure or ownership and participate in on-site verification by the team. The verification is conducted through field verification surveys, interviews with local communities and land owners, as well as coordinate point collection using GPS and field documentation. The verification results encompass confirmation of land status, the absence of active disputes, and the willingness of land owners or land controllers regarding the blue carbon management plan.

Closing

MoMAF Decree 25/2026 governs the guidelines for determining blue carbon management locations through criteria and stages that must be fulfilled. Businesses must ensure the location aligns with spatial plans and/or zoning plans, possesses clear and dispute-free land status, and is supported by adequate socioeconomic and biophysical conditions. Businesses also participate in public consultations and pay attention to synergy with other activities. Technically, the analysis is conducted through mapping with a minimum scale of 1:50,000 and boundary delineation with at least three coordinate points. This stage is followed by field verification and validation to ensure data suitability, including land status, community support, and area conditions. Therefore, companies must ensure the readiness of documents and field conditions, particularly regarding land tenure or ownership, before a location is submitted for blue carbon management designation.