Indonesia's carbon rules now sit in three layers. Perpres 110/2025, signed 10 October 2025, is the framework. Permen LH/BPLH 10/2026 establishes the SRUK unit registry underneath it. Permenhut 6/2026 and 7/2026 govern how all of that applies inside forest areas. Projects that read only the top layer miss the requirements that actually bind them.
Why There Are Three Layers
Perpres 110/2025 replaced Perpres 98/2021 and runs to 9 chapters and 103 articles. It sets the architecture: a dual registry, direct private participation, voluntary trading decoupled from the NDC timeline, and integrated MRV across all carbon instruments.
However, a presidential regulation sets structure, not procedure. The operational detail arrives through ministerial regulations, and because authority over climate registries and over forestry were separated, those ministerial regulations come from two different ministries.
| Layer | Instrument | Issued by | Governs |
|---|---|---|---|
| Framework | Perpres 110/2025 | President | Architecture, participation, NDC treatment |
| Registry | Permen LH/BPLH 10/2026 | Ministry of Environment/BPLH | SRUK, unit lifecycle, authorization |
| Exchange | POJK 10/2026 | OJK | Carbon exchange trading rules |
| Forest areas | Permenhut 6/2026, 7/2026 | Ministry of Forestry | Forestry carbon trading, governance |
Getting the ministry right matters editorially as well as legally: "KLHK" no longer exists as a single current entity. Use KLH/BPLH for the climate registry and Kemenhut for forestry carbon trading.
What Perpres 110/2025 Changed
Four changes have operational consequences.
The dual registry separates action accounting from unit accounting, so a project must appear in both SRN PPI and SRUK to complete a trading cycle.
Private participation is now direct. The predecessor regulation limited involvement to mitigation activities; private actors can now own and trade units themselves.
Decoupling from the NDC timeline ended the de facto moratorium that had constrained international voluntary sales since 2022.
Integrated MRV replaces fragmented sectoral systems, which makes 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 Forestry Layer
Permenhut 6/2026 and 7/2026 place governance, transparency, and integrity at the centre of forestry carbon trading. For permit holders, including both PBPH and social forestry schemes, this shifts the work from narrative reporting toward documented measurement.
What a Project Should Do About It
The regulatory reading is the easy part. The binding constraint is evidence.
Independent validation and verification sit in the middle of the SRUK registration sequence, and they test whether sampling design, data traceability and uncertainty quantification can support the claimed tonnage. Those three are decided when the monitoring plan is written, not when the auditor arrives.
Projects that stratify by real heterogeneity, such as ecosystem type, stand age, and soil condition, require fewer plots for the same precision, and narrower confidence intervals mean smaller conservative deductions.
Sources
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. Permenhut 6/2026 and 7/2026 — https://peraturan.bpk.go.id/ (must be read directly)
All regulation numbers must be verified against https://peraturan.bpk.go.id before publication.
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.
