Financial Services Authority Regulation Number 10 of 2026 Reformulation of Carbon Trading through the Carbon Unit Registry System (SRUK) and Strengthening Consumer Protection

Introduction

On 2 July 2026, the Financial Services Authority enacted Financial Services Authority Regulation Number 10 of 2026 on Amendments to Financial Services Authority Regulation Number 14 of 2023 (“POJK 14/2023”) concerning Carbon Trading through the Carbon Exchange (“POJK 10/2026”), which took effect on 6 July 2026. The substantive amendments include changes to the registration system nomenclature from the National Registry System for Climate Change Control (Sistem Registri Nasional Pengendalian Perubahan Iklim – “SRN PPI”) to the Carbon Unit Registry System (Sistem Registri Unit Karbon – “SRUK”), as well as adjustments to the types of Carbon Units traded, from the previous Technical Approval for Greenhouse Gas Emission Caps for Business Actors (PTBAE-PU) and Greenhouse Gas Emission Reduction Certificates (SPE-GRK) to Greenhouse Gas (GHG) Emission Quotas, GHG Emission Reduction Certificates (SPE-GRK), and non-SPE GRK. In addition, POJK 10/2026 imposes stricter requirements on the trading of carbon units originating from overseas by requiring Carbon Exchange operators to ensure the integrity, quality, and registration standards of such units. POJK 10/2026 also reaffirms the obligation to apply consumer protection principles to every party involved and provides flexibility for the Financial Services Authority to issue different policies based on certain considerations.

Comparison

The following table compares POJK 10/2026 and POJK 14/2023:

Key Provisions

Registration in the Carbon Unit Registry System (SRUK)

Pursuant to Article 1 point 2 and Article 3 paragraph (2), every carbon unit to be traded through the Carbon Exchange must first be registered in the Carbon Unit Registry System (SRUK) as well as with the Carbon Exchange operator in accordance with the applicable regulations.

Under this regulatory framework, SRUK functions as a centralized registration system used to provide, manage, and administer data and information relating to carbon units for the implementation of carbon economic value instruments, thereby supporting orderly administration, transparency, and the integrity of carbon trading in Indonesia.

There is a distinction between the SRUK and the SRN PPI used under POJK 14/2023. In terms of definition and scope, the SRN PPI under POJK 14/2023 is a web-based system that manages data and information relating to climate change mitigation actions and resources, climate change adaptation, and carbon economic value in Indonesia in a broad and general manner. In contrast, the SRUK under the new regulation is more specifically focused on the provision and management of data and information directly related to carbon units at the level of administering carbon economic value instruments.

Accordingly, while the SRN PPI is a comprehensive system that records all climate change-related activities (mitigation, adaptation, and carbon economic value), the SRUK is a dedicated system specifically designed to administer carbon unit commodities so that trading on the Carbon Exchange can be conducted in a more transparent and integrated manner.

Requirements for the Trading of Foreign Carbon Units

Pursuant to Article 3 paragraphs (3) and (4), Carbon Exchange operators are permitted to facilitate the trading of foreign carbon units even if such units are not registered in the Carbon Unit Registry System (SRUK). However, such foreign carbon units must satisfy the following requirements:

·      They have been registered, validated, and verified by an institution accredited by an international registry system operator and/or have been listed on a foreign carbon exchange.

·      They satisfy other requirements stipulated by the Financial Services Authority (OJK) following coordination with the ministry responsible for environmental affairs.

·      Carbon Exchange operators are responsible for ensuring the integrity, quality, and registration standards of such foreign carbon units.

Strengthening Supervision and Consumer Protection

By inserting Article 26 paragraph (3), the Financial Services Authority expands the scope of its supervision to include the sustainability governance of Carbon Exchange service users in conducting their business activities.

Furthermore, the newly inserted Article 35A requires all parties involved in carbon trading to comply with consumer protection principles.

Intervention in the Resignation of Directors/Commissioners

Article 31 paragraph (4) grants the Financial Services Authority new authority to postpone or restrict the resignation process of members of the Board of Directors and the Board of Commissioners of a Carbon Exchange operator.

Such postponement may be exercised where the Financial Services Authority considers that the resignation poses a risk of significantly affecting the performance and operational continuity of the Carbon Exchange.

Pursuant to Article 31 of POJK 10/2026, the Financial Services Authority’s intervention mechanism regarding the resignation of members of the Board of Directors or the Board of Commissioners of a Carbon Exchange operator does not require prior approval but instead adopts a reporting mechanism under which the Carbon Exchange operator must report the resignation no later than 2 (two) working days after becoming aware of it.

Based on such ex-post report, the Financial Services Authority evaluates its impact, and where the resignation is considered likely to significantly disrupt the performance and operational continuity of the Carbon Exchange, the Financial Services Authority is authorized to issue a decision postponing the resignation process.

However, the Regulation does not technically regulate how the Financial Services Authority may prevent or implement such postponement in practice.

Sanctions

Pursuant to Article 33, any violation of the provisions of POJK 10/2026, including non-compliance with the obligation to register Carbon Units in the SRUK, fulfillment of the requirements for the trading of foreign Carbon Units, or reporting obligations, may be subject to administrative sanctions.

Such sanctions may be imposed individually or cumulatively, depending on the severity of the violation, in the form of:

·      written warnings;

·      administrative fines in the form of an obligation to pay a specified amount of money;

·      restrictions on business activities;

·      suspension of business activities;

·      revocation of business licenses; and/or

·      cancellation of registration.

Transitional Provisions

Pursuant to Article II paragraph (1), POJK 10/2026 provides a transitional period during which Carbon Exchange operators may continue to facilitate the trading of Carbon Units that remain registered in the electronic system administered by the relevant ministry before the SRUK becomes operational.

The transitional facility applies from the effective date of POJK 10/2026, namely 6 July 2026, and is available for a maximum period of 3 (three) months from the promulgation of the Regulation or until the SRUK becomes operational, whichever occurs first.

This provision is intended to ensure the continuity of carbon trading during the migration process from the previous registration system to the Carbon Unit Registry System (SRUK), thereby preventing any gap in the registration mechanism or disruption to transactions conducted through the Carbon Exchange.

Closing

POJK 10/2026 strengthens Indonesia’s carbon trading regulatory framework through adjustments to the registration system, the expansion of the scope of tradable carbon units, and the enhancement of governance standards applicable to Carbon Exchange operators.

The adoption of the Carbon Unit Registry System (SRUK) as the primary registration system and the strengthening of consumer protection obligations reflect the Financial Services Authority’s efforts to enhance the integrity, transparency, and accountability of carbon trading activities.

At the same time, the transitional arrangements for the full implementation of the SRUK provide Carbon Exchange operators with sufficient time to adapt without disrupting the continuity of trading activities.

Accordingly, all Carbon Exchange operators, service users, and other parties involved in carbon trading should align their operational systems, registration mechanisms, governance practices, and reporting obligations with the requirements of POJK 10/2026.