MEMR Regulation 11/2026: Mandatory SNI Quantity Assurance, Non-Compliant Oil and Gas Contractors May Be Publicly Announced

Introduction

On 14 August 2026, the Ministry of Energy and Mineral Resources (“MEMR”) enacted Minister of Energy and Mineral Resources Regulation Number 11 of 2026 on the Mandatory Application of the Indonesian National Standard for a Quantity Assurance System for Accountability and Transparency in Upstream Oil and Gas Business Activities (“MEMR Regulation 11/2026”), which took effect on 7 March 2027. This regulation requires Contractors to implement SNI 9040:2021 concerning the Quantity Assurance System for Accountability and Transparency of Quantity Flow in the Oil and Gas Sub-Sector in presenting oil and gas production quantity data, from the sub-surface system through to the delivery point.

MEMR Regulation 11/2026 aims to ensure that oil and gas production data are accurate, transparent, and verifiable, while also supporting increased production and the optimization of state revenues from the upstream oil and gas sector. This regulation also constitutes a follow-up to Article 40 of Law Number 22 of 2001 concerning Oil and Gas, as amended, which regulates the application of standards and quality in upstream oil and gas business activities.

Key Provisions

• Obligation of Contractors to Implement the SNI Quantity Assurance System

As stipulated in Articles 2 and 3, Contractors are required to implement the SNI Quantity Assurance System in upstream oil and gas business activities, including in the data Flow System from the production process through to the delivery and/or processing point. Contractors are required to routinely present quantity data at each production stage based on a Flow System that has implemented the SNI, involving personnel who possess the qualifications and competencies in the field of oil and gas Quantity Assurance Systems.

• Quality Control by a Public Service Agency

Article 4 stipulates that the quantity data presented by Contractors must undergo quality control by a public service agency providing testing services in the oil and gas sector, with reference to the SNI Quantity Assurance System. The results of the quality control shall be submitted to the Minister. In its implementation, the public service agency must maintain data confidentiality and enter into a data confidentiality agreement with the Contractor as stipulated in Article 5. Furthermore, pursuant to Article 6, the results of the quality control shall serve as material for evaluation and/or improvement by the Contractor. Contractors are required to prepare reports on the results of the evaluation and/or improvement for submission to SKK Migas or BPMA annually and at any time when necessary, which shall subsequently be submitted to the Minister through the Director General.

• Personnel Competency and Certification

Article 7 stipulates that personnel involved in implementing the Quantity Assurance System must possess competencies in accordance with the competency standards established for upstream oil and gas business activities. Such competency standards are issued by an LSP designated by the Minister with reference to the modules and technical standards established by the Minister. Based on compliance with such competency standards and technical standards, the LSP shall issue competency certificates.

• Supervision and Consequences of Non-Compliance

Article 8 stipulates that the Minister shall supervise the implementation of the SNI Quantity Assurance System in the presentation of quantity data at each stage of oil and gas production, as well as the implementation of its competency standards. Supervision may be conducted through an integrated operating system, periodic reporting by Contractors, and/or direct supervision. In this regard, the Minister shall assign a public service agency providing testing services in the oil and gas sector to develop an integrated operating system and conduct direct supervision.

Article 9 stipulates that the implementation of such supervision shall be coordinated by the Director General together with SKK Migas or BPMA and/or the Inspectorate General. SKK Migas and BPMA shall monitor and evaluate the implementation of the SNI Quantity Assurance System by Contractors. If non-compliance is identified, SKK Migas or BPMA shall submit a recommendation to the Minister to issue a written warning through SKK Migas or BPMA. Contractors must follow up on such warning no later than 15 calendar days from the date the warning is issued. If the warning is not followed up within such period, the Minister will announce the list of Contractors that do not implement the SNI Quantity Assurance System.

• Financing of Quality Control and Supervision Services

Article 10 stipulates that the implementation of quality control and direct supervision by a public service agency providing testing services in the oil and gas sector shall be subject to service fees borne by the Contractor, in accordance with the provisions of laws and regulations.

Closing

MEMR Regulation 11/2026 reinforces the obligation of Contractors to implement the SNI Quantity Assurance System in presenting oil and gas production data, supported by quality control, competent and certified personnel, and a Government supervision mechanism. Contractors need to ensure implementation of the SNI, compliance with personnel competency requirements, and follow-up on the results of quality control and supervision in order to avoid written warnings and public announcement as Contractors that do not implement the SNI Quantity Assurance System. In addition, Contractors need to take into account the costs of quality control and direct supervision as part of their obligations under this regulation.