Regulation of the Minister of Environment/Environmental Management Agency Number 3 of 2026 to Strengthen the National Environmental Information and Monitoring System for Business Activities

Introduction

On April 20, 2026, the Minister of Environment/Head of the Environmental Management Agency issued and enacted Regulation of the Minister of Environment/Environmental Management Agency Number 3 of 2026 on the Environmental Status Information System (“Regulation 3/2026”). Regulation 3/2026 governs the preparation of the Indonesia Environmental Status (Status Lingkungan Hidup Indonesia, “SLHI”) and the Regional Environmental Status (Status Lingkungan Hidup Daerah, “SLHD”), as well as the integrated environmental status and monitoring system as a basis for decision-making.

The Government enacted Regulation 3/2026 to implement Article 489 letter a of Government Regulation Number 22 of 2021 on the Implementation of Environmental Protection and Management. Regulation 3/2026 regulates information systems to support the monitoring of environmental conditions, including pressures from business activities and their impacts, while collecting and presenting integrated environmental data as a basis for oversight and decision-making.

Key Provisions

Monitoring of Operational Pressures and Data Inventory of Businesses

As stipulated in Article 11 paragraphs (1) and (2), the government records environmental pressures originating from industrial operations. This monitoring covers:

1. The use of natural resources and the volume of greenhouse gas (GHG) emissions;

2. Direct and indirect emissions into the air, water, and soil;

3. The volume of waste, space or land utilization, and waste generation; and

4. Levels of noise, radiation, and other disturbances.

Environmental Permit Oversight Obligations and Compliance Documentation

As stipulated in Annex Book III, regional governments oversee compliance with environmental licensing obligations through an integrated database. This oversight includes:

1. The status of valid Environmental Approval Documents as listed in Table 65;

2. Monitoring results of business licensing related to AMDAL, UKL/UPL, and SPPL documents as reported in Table 66;

3. Data on companies holding Hazardous and Toxic Waste (Bahan Berbahaya dan Beracun, “B3”) management permits as listed in Table 52; and

4. Industrial fuel consumption data as listed in Table 32 to assess efficiency and air emission loads.

Specific Licensing Data Transparency for the Land and Forestry Sectors

Annex Book II number 5 regulates the reporting of environmental status in the land and forestry sectors, which includes land use licensing data. The recorded data includes:

1. The names of the land use or utilization permit holders;

2. The area of the licensed territory and its location supported by spatial data or maps; and

3. The economic scale classification of the permit holder, namely large, medium, and small scale.

Water Quality Oversight and Waste Installation Management

Annex Book II number 2 regulates the presentation of surface and groundwater quality data affected by industrial activities. Oversight is conducted through:

1. Inventorying the number of polluting industries and their Wastewater Treatment Plants (Instalasi Pengolahan Air Limbah, “IPAL”);

2. Monitoring compliance in the construction and operation of IPAL; and

3. Monitoring pollutant loads from industrial and non-industrial sources.

Corporate Performance Rating Program as a Compliance Instrument

Article 25 paragraph (5) letter d regulates the use of the Corporate Performance Rating Program (Program Penilaian Peringkat Kinerja Perusahaan, “PROPER”) as a weighting indicator for regional heads to receive environmental awards. The use of PROPER includes:

1. Recording the achievement of PROPER ratings within the relevant region as part of the assessment for the completeness of SLHD documents; and

2. Using the receipt of such awards as a basis for evaluating regional government performance to obtain the Nirwasita Tantra award from the central government for regional leadership achievements in the environmental field.

Inventory of Solid and Liquid Waste Pollution Sources

Annex Book III regulates the collection of solid and liquid waste generation data from industrial activities through Table 50 regarding the volume of waste by pollution source. The collected data includes:

1. The volume of solid and liquid waste from every stage of the production process;

2. The types and sources of pollution from operational facilities; and

3. The status of waste management and monitoring.

Mitigation of Technological Failure Risks and Industrial Accidents

Annex Book II number 8 covers non-natural disaster risks in environmental status reporting. The recorded data includes:

1. The occurrence or potential for technological failures, including industrial accidents and construction failures;

2. Failures in nuclear, biological, and chemical technology; and

3. Transportation accidents that impact the environment.

Ecolabel Product Standardization and Government Procurement Access

Annex Book III regulates the inventory of environmentally friendly products within the integrated environmental status and monitoring system. The recorded data includes:

1. The number of environmentally friendly products listed in government procurement of goods and services as per Table 4;

2. Products with Type I and Type II Indonesia Ecolabel certification as per Table 5 and Table 6; and

3. The implementation of environmentally friendly labeling as reported in Table 7.

Circular Economy Transition and Industrial Waste Management

The implementation of circular economy policies in managing industrial garbage and waste is measured through performance indicators referring to the reporting formats in Annex Book I and Annex Book III, namely:

1. The Waste Management Performance Index (Indeks Kinerja Pengelolaan Sampah, “IKPS”) at the regional level as listed in Table 49; and

2. Data on waste reduction and recycling achievements as listed in Table 53.

Spatial Data and Disaster-Based Investment Risk Management

The integration of spatial data from disaster risk maps is mandatory in environmental risk assessments to support preventive efforts and activity planning, as regulated in Annex Book II number 8 and Annex Book III Table 58. The data used includes:

1. Mapping of prone areas through the Disaster Risk Index as listed in Table 58;

2. Environmental carrying and assimilative capacities for water, land, and sea resources as listed in Table 2; and

3. Information on regional vulnerability to geological and hydrometeorological disasters.

Publication of Environmental Performance and Public Reputation Impacts

Environmental status documents are published to the public as regulated in Article 21 paragraph (1). This publication includes:

1. Environmental performance profiles presented through electronic and non-electronic media;

2. Presentation of information in formats such as infographics, short videos, and brief texts; and

3. The list of environmental award recipients, including parties with the best performance ratings, as listed in Table 72.

Synchronization of Economic Growth with Environmental Sustainability

The evaluation of environmental conditions uses economic indicators in the DPSIR analysis, as regulated in Annex Book III and Article 10 paragraph (1) letter c. The indicators used include:

1. Gross Domestic Product at Current Prices as listed in Table 74;

2. Gross Domestic Product at Constant Prices as listed in Table 75; and

3. The economic growth rate as part of the factors influencing environmental changes.

Digital Data Validity and SILHD Reporting Deadlines

Regulation 3/2026 took effect on April 20, 2026, upon its promulgation, as regulated in Article 29. Reporting provisions include:

1. The inclusion of a data validity statement signed by regional authorities;

2. The deadline for data submission through the Environmental Information System (Sistem Informasi Lingkungan Hidup Daerah, “SILHD”) application is no later than April 30 of the following year at 23:59 WIB; and

3. The use of the SMART method or other measurable methods in preparing the analysis of priority environmental issues, as regulated in Article 17 paragraph (2).
   

Closing

Regulation 3/2026 signifies a fundamental shift in environmental oversight governance toward a digital system that is integrated, transparent, and binding for all business sectors in Indonesia. This approach expands the scope of business compliance, which is no longer limited to avoiding administrative sanctions but also includes significant public reputational risks, as access to information regarding corporate environmental performance, PROPER ratings, and records of incidents such as technological failures and industrial accidents is opened to the general public. In its implementation, businesses are required to ensure the accuracy and consistency of highly comprehensive operational data, including greenhouse gas emissions, fuel efficiency, sources and volumes of solid and liquid waste pollution, the management and existence of wastewater treatment plants, and the validity of environmental approval documents and land use permits that prioritize the disclosure of permit holder identities. Non-compliance with these reporting obligations not only carries legal enforcement implications but may also restrict access to government procurement of goods and services due to failure to meet ecolabel standards, as well as increase the risk of delays or restrictions on business expansion, which is now evaluated through environmental carrying capacity instruments and disaster risk indices. As these provisions took effect on April 20, 2026, without a transition period, businesses and legal practitioners are required to immediately conduct comprehensive internal audits and adjustments to ensure data accuracy and reporting compliance through the SILHD system before the annual deadline, in order to minimize legal, financial, and operational risks and maintain the sustainability of business activities.