OJK Board of Commissioners Member Regulation No. 6 of 2026 Strengthens the Governance of Carbon Exchange Operators through Enhanced Operational Standards, Corporate Governance, and Information Technology Systems

Introduction

On 24 July 2026, the Financial Services Authority (OJK) enacted Board of Commissioners Member Regulation No. 6 of 2026 concerning the Procedures for Conducting Carbon Trading through a Carbon Exchange ("PADK OJK 6/2026"). The regulation establishes the operational procedures, technical and operational requirements, capital requirements, and reporting obligations applicable to parties intending to operate a carbon exchange in Indonesia. 

PADK OJK 6/2026 was issued to implement the provisions of OJK Regulation No. 14 of 2023 concerning Carbon Trading through a Carbon Exchange, as amended by OJK Regulation No. 10 of 2026. The regulation also officially revokes and replaces OJK Circular Letter No. 12/SEOJK.04/2023 concerning the Procedures for Conducting Carbon Trading through a Carbon Exchange ("SE OJK 12/2023").

Compared with SEOJK 12/2023, PADK OJK 6/2026 introduces several significant regulatory changes. These include the migration of system integration requirements from the National Registry System for Climate Change Control (SRN PPI) to the Carbon Unit Registry System (SRUK), the expansion of domestic carbon units eligible for trading through a carbon exchange, refinements to the issuance mechanism for Greenhouse Gas Emission Reduction Certificates (SPE-GRK), simplified documentary requirements for capital adequacy, revised listing requirements for foreign carbon units that have not yet been recorded in the registry system, and additional incidental reporting obligations requiring the submission of notarial deeds of shareholders' general meetings to OJK within the prescribed timeframe.

Comparison

Comparison between PADK OJK 6/2026 and SE OJK 12/2023:

 

Key Provisions

Types of Carbon Units and Cross-Border Trading Requirements

Annex I Section II(a) of PADK OJK 6/2026 expands the scope of carbon units that may be traded through a Carbon Exchange. Under the new framework, Carbon Exchange Operators may facilitate the trading of three categories of Carbon Units classified as securities, namely:

• Greenhouse Gas (GHG) Emission Allowances;
• Greenhouse Gas Emission Reduction Certificates (SPE-GRK); and
• Non-SPE-GRK securities. 

This represents a broader trading framework than that provided under SEOJK 12/2023 by accommodating additional categories of carbon instruments within Indonesia's carbon market.

PADK OJK 6/2026 also permits Carbon Exchange Operators to facilitate the trading of foreign carbon units. For foreign carbon units that have not yet been recorded in the Carbon Unit Registry System (SRUK), the regulation requires that such units:

• be registered, validated, and verified through an internationally accredited registry system;
• satisfy the applicable requirements for trading on a foreign carbon exchange; and
• comply with any additional requirements stipulated by OJK.

These requirements strengthen the integrity of cross-border carbon trading while ensuring that foreign carbon units admitted into the Indonesian market satisfy internationally recognised verification standards.

Requirements for Shareholders and Management of Carbon Exchange Operators

Annex I Sections IV and V of PADK OJK 6/2026 introduce comprehensive governance requirements applicable to prospective controlling shareholders, members of the Board of Directors, and members of the Board of Commissioners of Carbon Exchange Operators. The regulation is intended to ensure that Carbon Exchange Operators are managed by individuals possessing the requisite integrity, competence, and professional experience.

Among the principal requirements, prospective members of the Board of Directors and the Board of Commissioners must not have been convicted of financial crimes or certain criminal offences, including corruption, environmental crimes, and tax offences, within the preceding 20 years.

In addition, members of the Board of Directors must possess at least two years of managerial experience in the capital market, financial services, or climate change sectors. At least one member of the Board of Directors must also have experience in regulatory development or activities relating to carbon trading and sustainable finance. These competency requirements demonstrate OJK's intention to ensure that Carbon Exchange Operators are led by individuals with both regulatory expertise and practical market experience.

Furthermore, every prospective controlling shareholder, member of the Board of Directors, and member of the Board of Commissioners is required to obtain OJK approval through a Fit and Proper Test prior to assuming their respective positions. This requirement reinforces OJK's supervisory role in maintaining the governance standards of Carbon Exchange Operators and aligns the regulatory framework with governance standards applicable to other financial market institutions under OJK supervision. 

Cybersecurity and Operational Infrastructure Standards

Annex I Section VII of PADK OJK 6/2026 introduces enhanced information technology governance and cybersecurity requirements for Carbon Exchange Operators. The regulation establishes minimum standards for information technology infrastructure, operational resilience, and system security to ensure the reliability and integrity of carbon trading activities conducted through the exchange. 

Among the key requirements, Carbon Exchange Operators are required to maintain both their data center and disaster recovery center within the jurisdiction of Indonesia. The regulation also requires the trading system to be integrated with the Carbon Unit Registry System (SRUK) to support the validation and settlement of carbon unit transactions.

In addition, Carbon Exchange Operators must conduct periodic information technology security assessments through independent information technology auditors to identify vulnerabilities affecting both hardware and software infrastructure. Operators are further required to implement crisis management procedures and business continuity measures to safeguard the continuous operation of their trading systems. These requirements reflect OJK's increasing emphasis on operational resilience and cybersecurity as integral components of the governance framework for financial market infrastructure.

Reporting Obligations of Carbon Exchange Operators

Annex I Section XI of PADK OJK 6/2026 strengthens the reporting framework applicable to Carbon Exchange Operators as part of OJK's supervisory function. The regulation requires operators to submit both periodic reports and incidental reports to facilitate ongoing regulatory oversight.

Periodic reporting obligations include:

• a monthly transaction summary report, which must be submitted no later than the fifth trading day of the following month; and
• an audited annual operational report.

In addition to periodic reporting, Carbon Exchange Operators must submit incidental reports upon the occurrence of certain material events, including system disruptions, changes to members of management, and the imposition of regulatory sanctions, within the reporting deadlines prescribed under PADK OJK 6/2026

The expanded reporting requirements reinforce OJK's supervisory framework by enabling more timely monitoring of operational, governance, and compliance developments affecting Carbon Exchange Operators.

Closing

PADK OJK 6/2026 significantly strengthens Indonesia's regulatory framework governing carbon trading through a Carbon Exchange. Compared with the previous regime under SEOJK 12/2023, the regulation introduces substantial reforms covering the trading and listing of carbon units, institutional governance and capital requirements, information technology and cybersecurity standards, and reporting obligations applicable to Carbon Exchange Operators. Collectively, these measures demonstrate OJK's commitment to developing a more transparent, integrated, and credible carbon market ecosystem to support the continued growth of Indonesia's national carbon market.

Entities intending to operate a Carbon Exchange should review their institutional structure, governance arrangements, capital compliance, and information technology infrastructure to ensure full compliance with PADK OJK 6/2026. Particular attention should also be given to satisfying the fit and proper requirements applicable to controlling shareholders and management, implementing system integration with SRUK, and establishing robust reporting procedures to comply with both periodic and incidental reporting obligations required to obtain and maintain their status as a Carbon Exchange Operator.