Carbon Credits in Indonesia 2026: Perpres 110/2025, SRUK, and What Buyers and Developers Must Do Now

Indonesia's carbon credit market in 2026 operates under Presidential Regulation 110/2025, which replaced the Perpres 98/2021 framework with a dual-registry system: SRN PPI records climate actions, while SRUK registers tradable carbon units. International sales no longer wait on NDC timelines, and the transition window for existing projects closes in October 2026.

Three facts frame everything else.

The framework changed. Perpres 110/2025 was signed on 10 October 2025, runs to 9 chapters and 103 articles, and replaced Perpres 98/2021. It opened direct private ownership and trading of carbon units, and decoupled voluntary trading from the NDC timeline, effectively ending the de facto moratorium on international voluntary sales that had constrained the market since 2022.

The registry went live. SRUK (Sistem Registri Unit Karbon) launched on 9 July 2026 under Permen LH/BPLH 10/2026, signed 2 July 2026. SRN PPI, running since November 2016, continues in parallel.

The volumes are still small. IDXCarbon traded 903,915 tCO2e in 2025, representing an increase of 118.5% over the 413,764 tCO2e recorded in 2024, with a total value of IDR 36.36 billion across 213 transactions. Cumulatively through the middle of 2026, the exchange has handled roughly 1.98 MtCO2e worth about IDR 93.8 billion, involving 155 registered participants.

Read together: the regulatory architecture is now more developed than the liquidity. That asymmetry is the defining feature of this market in 2026.

Four changes matter operationally.

A dual registry. Action accounting and unit accounting are now separate systems with separate purposes. A project registered in only one cannot complete a trading cycle.

Private participation. Perpres 98/2021 limited involvement to mitigation activities. Private actors can now own and trade units directly.

Voluntary trading decoupled from NDC timing. This is what reopened international sales.

Integrated MRV. The regulation moves from fragmented sectoral systems toward integrated measurement, reporting and verification across all carbon instruments, making verification credibility a precondition rather than a formality.

A one-year transition applies: existing systems must align by 10 October 2026, with implementing regulations due in the same window.

The distinction is about what gets recorded, not which sits above the other.

SRN PPI records climate actions, specifically mitigation and adaptation activities, including reductions counted toward the NDC of Indonesia. SRUK records units, which comprise greenhouse gas emission allowances, domestic SPE-GRK, and internationally standardised offset credits outside the SPE GRK framework, while tracking their issuance, ownership, transfer, and retirement.

Two different regulators operate two different layers, and conflating them is a common error: Permen LH/BPLH 10/2026 establishes the SRUK registry under the Ministry of Environment/BPLH, while POJK 10/2026 overhauls the carbon exchange rules under OJK. The registry records units; the exchange trades them.

Registration under Article 11 runs eight steps.

International trades additionally require an Authorization, which is granted within 15 working days, along with a Corresponding Adjustment.

Projects already recognised under SRN PPI do not restart. DRAM/DPP recognition granted before Perpres 110/2025 carries forward, but the project must register in SRUK before issuing new units, and new issuance remains subject to ministerial recommendation.

Verra and Gold Standard projects use an interim recording route until approximately 6 October 2026. Under it, the sector minister records eligible units in SRUK within two working days of the verification report, certificate or transaction (Article 46).

A strict deadline that often catches participants off guard is that trades conducted outside the exchange must be recorded in SRUK within two working days of the transaction, as stipulated in Article 31(5). Trades not recorded inside that window are treated as completely invalid, rather than simply being subjected to a fine.

The binding constraint is rarely paperwork. It is whether the project's numbers survive independent validation and verification, which represent steps 5 and 6 of the SRUK process.

Three failure modes recur. Sampling designs with too few plots, or plots that do not represent stand heterogeneity, produce wide confidence intervals, and wide intervals mean conservative deductions, which mean fewer issued units. Broken data traceability fails the auditor's backward walk from headline number to field measurement. And unquantified uncertainty attracts the most conservative default assumption available.

All three are decided at sampling-design time, not at verification time. Projects that build stratified, multi-layer sampling into the monitoring plan from the start clear these steps materially faster.

For a unit to support a claim abroad, three things must hold: the unit is recorded in SRUK; an Authorization has been granted; and a Corresponding Adjustment has been applied so the tonne is not counted both by Indonesia and by the buyer's jurisdiction.

Beyond legal status, the diligence question worth asking is how the underlying tonnes were measured, sampling design, uncertainty reporting, and whether raw field data can be inspected. Registry listing establishes that a unit exists. It does not establish how well it was measured.

1. Perpres 110/2025 — https://peraturan.bpk.go.id/ (search "110 Tahun 2025"; accessed 16 Sep 2026)

2. Perpres 110/2025 explainer — https://www.trucarbon.co/perpres-110-2025 (accessed 17 Sep 2026)

3. SRUK explainer — https://www.trucarbon.co/sruk-carbon-unit-registry-explained (accessed 17 Sep 2026)

4. SRUK launch, Permen LH/BPLH 10/2026 and POJK 10/2026 — https://iki-indonesia.id/government-launches-sruk-carbon-unit-registry-permen-lh-bplh-no-10-2026-ojk-issues-pojk-no-10-2026-overhauling-carbon-exchange-rules-idxcarbon/ (29 Jul 2026)

5. Ecosystem Marketplace, SOVCM 2025 — https://www.ecosystemmarketplace.com/articles/sovcm-2025-finds-the-voluntary-carbon-market-in-transition-demand-holding-steady-as-turnover-stabilizes/ (29 May 2025)

6. Columbia CGEP Indonesia profile — https://www.energypolicy.columbia.edu/publications/indonesia/ (accessed 16 Sep 2026)

All regulation numbers must be verified against https://peraturan.bpk.go.id before publication.