Indonesia Stock Exchange Board of Directors Decree Number Kep-00102/BEI/07-2026 Expands the Scope of Tradable Carbon Units and Postpones the Effective Date of the Registration Fee

Introduction

On 9 July 2026, the Indonesia Stock Exchange (IDX) implemented Indonesia Stock Exchange Board of Directors Decree Number Kep-00102/BEI/07-2026 on Amendments to the Carbon Exchange Service User Regulation (“IDX Board of Directors Decree 102/2026”).

IDX Board of Directors Decree 102/2026 establishes the operational framework and revises the registration requirements for business entities seeking to utilize the systems and facilities provided to Carbon Exchange Service Users.

IDX Board of Directors Decree 102/2026 was introduced to support the implementation of international carbon trading. It contains several substantive differences from its predecessor, Indonesia Stock Exchange Board of Directors Decree Number Kep-00079/BEI/11-2025 on the Carbon Exchange Service User Regulation (“IDX Board of Directors Decree 79/2025”). First, the new Decree updates the infrastructure and terminology by adopting the Carbon Unit Registry System (Sistem Registri Unit Karbon – “SRUK”) and Greenhouse Gas (GHG) Emission Quotas, replacing references to the National Registry System for Climate Change Control (Sistem Registri Nasional Pengendalian Perubahan Iklim – “SRN-PPI”) and Technical Approval for Businesses’ Emission Caps (Persetujuan Teknis Batas Atas Emisi bagi Pelaku Usaha – “PTBAE-PU”) used under IDX Board of Directors Decree 79/2025. Second, IDX Board of Directors Decree 102/2026 generally authorizes Carbon Exchange Service Users to trade carbon units recorded in the SRUK—including GHG Emission Quotas, GHG Emission Reduction Certificates (SPE-GHG), and non-SPE GHG units—as well as carbon units not recorded in the SRUK, without distinguishing users into the categories of Emissions Trading Businesses, Non-Emissions Trading Businesses, and Project Owners as provided under the previous regulation. Third, the obligation for Carbon Exchange Service Users to pay the IDR5,000,000 (five million rupiah) registration fee has been postponed and will only become effective on 1 January 2028, whereas the previous regulation required payment beginning on 1 January 2027. Accordingly, IDX Board of Directors Decree 102/2026 revokes and declares IDX Board of Directors Decree 79/2025 no longer effective.

Comparison

The following table compares IDX Board of Directors Decree 102/2026 with IDX Board of Directors Decree 79/2025:

Key Provisions

Expansion of Tradable Carbon Units and International Market Access

Pursuant to Section II.3, the scope of carbon units eligible for trading on the Carbon Exchange has been expanded to facilitate the implementation of international carbon trading.

Under this provision, Carbon Exchange Service Users may trade carbon units recorded in the Carbon Unit Registry System (SRUK), including:

·      Greenhouse Gas (GHG) Emission Quotas;

·      Greenhouse Gas Emission Reduction Certificates (SPE-GHG);

·      non-SPE GHG units; and

·      other carbon units that are not recorded in the SRUK.

For the purposes of the Regulation, a Carbon Exchange Service User is a business entity that is authorized to use the systems and/or facilities provided by the Carbon Exchange operator in accordance with the applicable Carbon Exchange regulations.

Simplified Bank Account Requirements for Foreign Legal Entities

Pursuant to Section IV.3, prospective Carbon Exchange Service Users established as foreign legal entities must possess valid registration evidence or a valid business registration certificate in accordance with the laws of their country of incorporation.

However, they are provided with greater flexibility regarding financial administration, as they may use:

·      a bank account connected to the BI-FAST and/or BI-RTGS systems;

·      a bank account held in the name of the prospective Service User; or

·      the services of a licensed third party authorized to send and receive funds through the Carbon Exchange operator’s account.

Rights and Market Access of Carbon Exchange Service Users

Sections III.1 and III.2 provide that Carbon Exchange Service Users are entitled to register carbon units and conduct carbon trading through:

·      the Auction Market;

·      the Regular Market;

·      the Negotiated Market; and

·      the Non-Regular Commodity Futures Market,

in accordance with the applicable regulations.

Specifically, Carbon Exchange Service Users trading GHG Emission Quotas are entitled not only to obtain quota allocations through the Auction Market mechanism but also to surrender GHG Emission Quotas to fulfill regulatory compliance obligations in accordance with the prevailing laws and regulations.

Incidental Reporting and Administrative Obligations

To maintain accurate administrative records, Section VII.2.6 requires Carbon Exchange Service Users to submit an incidental report within 7 (seven) Carbon Exchange Trading Days following any material change to the company’s information.

A Carbon Exchange Trading Day refers to any day on which carbon units are traded on the Carbon Exchange, namely Monday through Friday, excluding national public holidays and any other holidays designated by the Carbon Exchange operator.

The reporting obligation applies to any material changes concerning:

·      Taxpayer Identification Number (NPWP);

·      business licenses;

·      head office information;

·      the name and information of the Carbon Exchange Service User;

·      the composition of the Board of Directors and Board of Commissioners;

·      the Beneficial Owner of the Carbon Exchange Service User (where applicable); and

·      the Articles of Association and their latest amendments that have been approved, acknowledged, or ratified by the competent authority.

Transitional Provisions

Second Dictum establishes a transitional period under which the obligation to pay the IDR5,000,000 (five million rupiah) registration fee for Carbon Exchange Service Users will only become effective on 1 January 2028.

In addition, Section VIII provides that Carbon Exchange Service Users that violate their obligations or responsibilities in conducting Carbon Exchange transactions may be subject to administrative sanctions imposed by the Exchange, either individually or cumulatively, in the form of:

·      written warnings;

·      administrative fines of up to IDR500,000,000 (five hundred million rupiah); and/or

·      revocation of their approval as Carbon Exchange Service Users.

Closing

With the issuance of IDX Board of Directors Decree 102/2026, existing and prospective Carbon Exchange Service Users should adjust their governance, administrative processes, and transaction mechanisms to comply with the new regulatory framework.

The expansion of the scope of tradable carbon units and the introduction of a special category of Carbon Exchange Service Users reflect the Indonesia Stock Exchange’s commitment to supporting the development of Indonesia’s carbon market and its increasing integration with international carbon trading. The Decree also postpones the effective date of the IDR5,000,000 (five million rupiah) registration fee until 1 January 2028. Businesses should also be aware that violations of the Decree may result in sanctions ranging from written warnings to administrative fines.