Adjustment of Work Plans and Budgets Policies to Promote Business Certainty and State Revenue Based on Minister of Energy and Mineral Resources Regulation Number 17 of 2025
Summary
Regulation of the Minister of Energy and Mineral Resources of the Republic of Indonesia Number 17 of 2025 concerning Procedures for the Preparation, Submission, and Approval of Work Plans and Budgets [Rencana Kerja dan Anggaran Biaya (“RKAB”)] and Procedures for Reporting the Implementation of Mineral and Coal Mining Business Activities (“Regulation 17/2025”) [Peraturan Menteri Energi dan Sumber Daya Mineral Republik Indonesia Nomor 17 Tahun 2025] was issued on September 30, 2025, and took effect on its date of promulgation, October 3, 2025.
This regulation was issued to provide a legal basis for the readjustment of annual RKABs during the production operation stage, specifically to control the production and sale of Minerals and Coal amid declining global commodity prices to safeguard state revenue.
Background and Context
The issuance of Regulation 17/2025 is based on two main considerations.
First, the decline in global mineral and coal commodity prices necessitates various efforts to safeguard state revenue. These efforts are manifested in the form of readjusting the annual RKAB at the production operation activity stage. This adjustment aims to provide room for controlling the production and sale of Minerals and Coal.
Second, the previous regulation, Minister of Energy and Mineral Resources Regulation Number 10 of 2023 concerning Procedures for the Preparation, Submission, and Approval of Work Plans and Budgets and Procedures for Reporting the Implementation of Mineral and Coal Mining Business Activities (“Regulation 10/2023”) [Peraturan Menteri ESDM Nomor 10 Tahun 2023] as amended by Regulation Number 15 of 2024 concerning the Amendment to Minister of Energy and Mineral Resources Regulation Number 10 of 2023 concerning Procedures for the Preparation, Submission, and Approval of Work Plans and Budgets and Procedures for Reporting the Implementation of Mineral and Coal Mining Business Activities (“Regulation 15/2024”) [Peraturan Menteri ESDM Nomor 15 Tahun 2024], was deemed no longer suitable for current developments and legal needs, thus requiring replacement.
Therefore, this Regulation was issued to implement the provisions of Article 177 paragraph (3) and Article 178 paragraph (4) of Government Regulation Number 96 of 2021 concerning the Implementation of Mineral and Coal Mining Business Activities [Peraturan Pemerintah Nomor 96 Tahun 2021], as last amended by Government Regulation Number 39 of 2025.
Comparison with Previous Regulations
Regulation 17/2025 revokes and declares Regulation 10/2023 and its amendment, Regulation 15/2024, no longer valid. The following is a comparison of the most significant substantial changes from the previous provisions to the new provisions:
| Aspect | Regulation 10/2023 | Regulation 15/2024 | Regulation 17/2025 |
| RKAB Production Operation Stage Validity Period | Activity plan for 3 (three) years. | Activity plan for 3 (three) years. | Activity plan for 1 (one) year. |
| Deadline for Submission of Subsequent Annual RKAB | At the latest 45 calendar days before the end of the calendar year. | At the latest 45 calendar days before the end of the calendar year. | At the earliest on October 1 and at the latest on November 15 each year. |
| Evaluation and Approval Period (Normal) | A maximum of 30 (thirty) working days since the application is received completely and correctly. | A maximum of 30 (thirty) working days since the application is received completely and correctly. | Evaluation conducted within a maximum of 5 (five) working days. Total approval time is a maximum of 8 (eight) working days since the final evaluation and revision. |
| Automatic Approval Mechanism (Deemed Approval) | Not regulated. | Not regulated. | RKAB approval is issued automatically by the system if the application is complete and the RKAB has not been approved/rejected after the time limit expires. |
| Frequency of RKAB Amendments (Normal) | May submit 1 (one) RKAB amendment per calendar year. | May submit 1 (one) RKAB amendment per calendar year. | May submit 1 (one) RKAB amendment application per calendar year. |
| Deadline for Submission of Periodic Reports (Quarterly) | At the latest 30 (thirty) calendar days after the end of each quarter. | At the latest 30 (thirty) calendar days after the end of each quarter. | At the latest on the 15th (fifteenth) of the following month after the end of each quarter. |
| Additional Sanctions for Overproduction (Exceeding RKAB) | Sanction in the form of temporary suspension of mining business activities without written warning. | Sanction in the form of temporary suspension of mining business activities without written warning. |
Sanctions are imposed cumulatively:
|
Key Provisions
The main substance of this regulation, including prohibitory provisions and sanctions, is reflected in the following key provisions:
| Regulatory Aspect | Provision | Article |
| RKAB Validity Period | Activity plans for the Exploration or Production Operation stage are prepared for a period of 1 (one) year. | Article 3 paragraph (1) |
| Deadline for Annual RKAB Submission | The subsequent year's RKAB must be submitted at the earliest on October 1 and at the latest on November 15 each year. | Article 4 paragraph (1) letter b |
| Requirement for Resource / Reserve Estimation Report | Holders of Production Operation Mining Business Permits (IUP) [Izin Usaha Pertambangan] / Special Mining Business Permits (IUPK) [Izin Usaha Pertambangan Khusus] must submit a resource and reserve estimation report by a competent person (for metallic Minerals, non-metallic Minerals, and Coal). | Article 5 paragraph (1) letter b number 2 |
| Production Level Restrictions | Production levels must not exceed the highest capacity listed in the approved Feasibility Study [Studi Kelayakan] and Environmental Permit [Izin Lingkungan] documents. Holders of metallic Mineral and Coal IUP/IUPK must submit production forecasts according to national industry/market needs. | Article 5 paragraph (1) letter b number 7 and Article 5 paragraph (4) |
| Automatic Approval Mechanism (Deemed Approval) | Approval is issued automatically by the system if the application is complete but has not received approval/rejection after the time limit expires. | Article 6 paragraph (6) |
| Restrictions on RKAB Amendments | May only submit 1 (one) RKAB amendment application per calendar year. | Article 11 paragraph (1) |
| Prohibition of Activities Without RKAB/Land Permit | Permit holders are prohibited from conducting business activities (physical fieldwork) if they have not submitted/not yet received RKAB approval, the RKAB application is rejected, or they have obtained a Production Operation RKAB but have not yet secured a borrow-use permit for forest areas [persetujuan pinjam pakai kawasan hutan], land rights [hak atas tanah], or a sea space utilization permit [izin pemanfaatan ruang laut]. | Article 16 paragraph (1) |
| Prohibition of Production Exceeding RKAB | Permit holders are prohibited from producing Minerals or Coal in excess of the planned production amount stated in the RKAB approval. | Article 17 |
| Quarterly Reporting Deadline | Permit holders must submit Periodic Reports every 3 (three) months at the latest on the 15th (fifteenth) of the following month after the end of each quarter. | Article 21 |
| Severe Sanction of Permit Revocation |
Subject to the sanction of Permit Revocation without warning/temporary suspension stages if:
|
Article 29 |
| Sanctions for Overproduction | Subject to the sanction of Temporary Suspension of business activities (without written warning) plus a Reduction in the planned production amount in the subsequent RKAB for each tonnage of overproduction. Royalty payment obligations must still be fulfilled. | Article 30 |
| Transitional Provisions for 2026-2027 RKAB | RKABs for 2026 and 2027 that were approved before the promulgation of this Ministerial Regulation must be readjusted in accordance with the provisions of this Ministerial Regulation. The old 2026 RKAB may still be used until March 31, 2026, while awaiting approval of the new, adjusted RKAB. | Article 35 letters c and d |
Conclusion
Regulation 17/2025 was issued to replace all previous provisions related to the Work Plan and Budget (RKAB) and reporting on mining business activities. This rule aims to strengthen government supervision of mineral and coal mining business activities, particularly at the production operation stage.
The primary focus of this regulation is to safeguard state revenue amid global commodity price fluctuations through stricter annual production regulation and restrictions. Several key changes to note:
-
Production Operation RKABs are now valid for 1 (one) year, no longer three years as under the previous provisions.
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The approval process is accelerated to a maximum of 8 working days with the implementation of a deemed approval mechanism, requiring business actors to ensure the completeness and accuracy of submitted documents.
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The imposition of sanctions in the form of a production quota reduction in the following year for business actors who overproduce, as a measure to maintain production stability and state revenue.
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