From 2022, Indonesia operated what amounted to a moratorium on international sales of voluntary carbon credits, not through an outright ban, but by tying credit transfers to NDC accounting in a way that made export impractical. Perpres 110/2025 undid that restriction, and the consequences for regional supply are larger than the domestic trading volumes suggest.
The Mechanism That Closed the Market
The constraint was accounting, not prohibition. If every credit sold abroad had to be reconciled against Indonesia's own NDC commitment, and the reconciliation process did not exist operationally, then credits could not move.
Project developers with verified units held them. International buyers seeking Indonesian nature-based supply went elsewhere.
| Before Perpres 110/2025 | After | |
|---|---|---|
| International voluntary sales | Blocked in practice | Permitted with authorization |
| Private ownership of units | Limited to mitigation activity | Direct ownership and trading |
| NDC linkage | Coupled to voluntary trading | Decoupled |
| Registry | SRN PPI only | SRN PPI plus SRUK unit registry |
Why the Reopening Matters Beyond Indonesia
Indonesia holds one of the world's largest areas of tropical forest, extensive peatland, and roughly a fifth of global mangroves. Removing it from international supply for three years shifted where buyers looked, and reinstating it changes regional pricing dynamics.
For Southeast Asian project developers generally, the more useful signal is regulatory: Indonesia demonstrated that a large forest nation can build a dual registry, define authorization procedures and reopen trade inside a defined timeline. Neighbouring jurisdictions building their own frameworks are watching that precedent closely.
What Reopening Does Not Fix
Three constraints persist regardless of the legal change.
Domestic demand remains thin. The exchange exists and functions; the volumes moving through it are small relative to supply potential.
The evidence burden is unchanged. Authorization is granted against projects that have completed validation and verification, meaning that while the legal path has reopened, the measurement path did not get shorter.
Buyers are stricter than they were in 2022. Three years of published criticism of forest carbon baselines has raised the diligence bar. A project returning to market now faces harder questions than one that left it.
The Practical Reading
The reopening creates an opportunity for projects that spent the moratorium building defensible measurement, and exposes those that did not.
The binding constraint was never the law. It was, and remains, whether a project's numbers survive contact with an independent assessor.
Selling into a compliance market?
Compliance buyers examine sampling design, uncertainty and data traceability directly, because a later finding of ineligibility returns the liability to them. TREEO builds the evidence file that answers it.
