Minister of Energy and Mineral Resources Designates 474 National Vital Objects in the Energy Sector through Minister of Energy and Mineral Resources Decree Number 385.K/BN.05/MEM.S/2025

Introduction

On November 25, 2025, the Ministry of Energy and Mineral Resources issued Decree of the Minister of Energy and Mineral Resources Number 385.K/BN.05/MEM.S/2025 on National Vital Objects in the Energy and Mineral Resources Sector (“MEMR Decree 385/2025”). MEMR Decree 385/2025 establishes the updated list of facilities, installations, and business areas designated as National Vital Objects [Objek Vital Nasional (“Obvitnas”)], and provides legal certainty as well as priority security protection for strategic energy sector assets.

MEMR Decree 385/2025 was issued to update Obvitnas data. The recitals explain that the government conducted an inventory and factual verification of business units in the energy and mineral resources sector on October 8, 2025. Based on these results, the government has entirely replaced the previous regulation to align the Obvitnas status designations with current operational conditions, including changes resulting from the expiration of contracts and the addition of new infrastructure, to ensure that the security of energy infrastructure is implemented in a more targeted and effective manner.

Definition

Under Presidential Decree Number 63 of 2004 on the Security of National Vital Objects, a “National Vital Object” is defined as an area or location, building or installation, and/or business activity that relates to the livelihood of the general public, the interests of the state, and/or strategic sources of state revenue (a “National Vital Object” or “Obvitnas”).

Comparison

MEMR Decree 385/2025 repeals and declares the following regulations as no longer in force:

1. Decree of the Minister of Energy and Mineral Resources Number 77 K/90/MEM/2019 (“MEMR Decree 77/2019”);

2. Decree of the Minister of Energy and Mineral Resources Number 159.K/90/MEM/2020 (“MEMR Decree 159/2020”);

3. Decree of the Minister of Energy and Mineral Resources Number 202.K/HK.02/MEM.S/2021 (“MEMR Decree 202/2021”);

4. Decree of the Minister of Energy and Mineral Resources Number 270.K/HK.02/MEM.S/2022 (“MEMR Decree 270/2022”);

5. Decree of the Minister of Energy and Mineral Resources Number 448.K/BN.05/MEM.S/2023 (“MEMR Decree 448/2023”); and

6. Decree of the Minister of Energy and Mineral Resources Number 310.K/BN.05/MEM.S/2024 (“MEMR Decree 310/2024”).

The following is a comparison of the total and details of National Vital Objects between MEMR Decree 385/2025 and MEMR Decree 77/2019 along with its amendments:

Key Provisions

Scope and Details of National Vital Object Designation

Under the First Dictum, the Minister designates a list of 474 National Vital Objects in the Energy and Mineral Resources Sector, which includes areas, locations, buildings, installations, and/or businesses. The following table details the asset distribution, primary locations, and operators stipulated in the Annexes to the Decree.

Internal Security Responsibilities

Obvitnas Operators (Business Entities/Companies) are fully responsible for the implementation of security at each Obvitnas location in accordance with the Second Dictum. Companies must fulfill obligations based on laws and regulations concerning security management systems and guidelines for the security of national vital objects.

Threat Handling and Reporting Mechanisms 

In the event of threats or disturbances to a National Vital Object, the Operator must take follow-up actions pursuant to the Third Dictum and applicable laws and regulations. Furthermore, the Operator is required to report such incidents to the Ministry of Energy and Mineral Resources through the Secretary General. This establishes a mandatory reporting obligation for businesses when facing security crises.

Closing

MEMR Decree 385/2025 designates a total of 474 National Vital Objects consisting of 159 Obvitnas in the Oil and Gas subsector, 262 Obvitnas in the Power subsector, 36 Obvitnas in the Mineral and Coal subsector, and 17 Obvitnas in the New and Renewable Energy subsector. Pursuant to the Second Dictum and Third Dictum, Obvitnas Operators are fully responsible for internal security management and are required to handle and report any security threats or disturbances to the Ministry of Energy and Mineral Resources. Upon the enactment of MEMR Decree 385/2025, MEMR Decree 77/2019 and its amendments, as last amended by MEMR Decree 310/2024, are repealed and no longer in force.