This is the second part of a two-part article examining Indonesia’s new carbon trading regulation, POJK Number 10 of 2026. While Part 1 explored the transition to the SRUK registry system, the expansion of eligible carbon units, and the opening of the market to foreign carbon credits, this second instalment focuses on the regulation’s remaining reforms: integrated reporting obligations, stronger consumer protection, and measures to facilitate the transition to the new electronic trading system. Together, these changes are intended to enhance transparency, strengthen market integrity, and support the development of a more mature and globally connected Indonesian carbon market.
by Roffie Kurniawan
Integrated reporting obligations
In an effort to bolster governance, POJK 10/2026 introduces important updates to the Integrated Reporting Obligations for carbon trading in Indonesia. The Financial Services Authority, or OJK, aims to enhance the transparency of the carbon exchange to match that of the stock market with these changes.
The updates broaden the reporting requirements for the carbon exchange. Previously, reports were mainly directed at OJK and kept internally. Now, the carbon exchange operator is required to submit specific reports to relevant government ministries, such as the Ministry of Environment and Forestry (KLHK) and potentially the Ministry of Finance.
This adjustment ensures that trading data is aligned with the national greenhouse gas (GHG) inventory and contributes to tracking Indonesia’s Nationally Determined Contributions (NDCs). A significant change involves integrating the trading system with the SRUK.
This integration ensures that all transactions involving carbon units—including issuance, transfer, and retirement—are automatically tracked and reported in real-time. This real-time reporting eliminates the need for manual batch submissions and enhances transparency.
Moreover, these integrated reporting obligations support national carbon accounting by directly feeding trades into Indonesia’s national emissions data, preventing double counting. Such accountability is crucial for international buyers seeking assurance that credits are legitimate according to Article 6 of the Paris Agreement, thus establishing a more credible market.
These updates come with several benefits. First, they offer greater oversight as both OJK and KLHK can monitor the market in real-time. This level of transparency is crucial for foreign buyers who need to know each credit truthfully reflects a reduction of one ton of CO2 equivalent and isn’t duplicated.
Additionally, aligning carbon trading with the national GHG control framework—as per Perpres 110/2025—ensures that market activities are connected to government climate targets.
The changes significantly impact market participants. The Carbon Exchange must develop IT systems that integrate with SRUK and consistently submit reports to government ministries. Sellers and project developers will face stricter monitoring, reporting, and verification (MRV) requirements, which means their data will be more accessible to the government.
On the other hand, buyers will gain increased confidence in tracking the origins and lifecycle of the credits they purchase.
These reforms demonstrate that the carbon exchange—traditionally regarded as a financial market—is now intricately linked to Indonesia’s national climate data system through mandatory and integrated reporting obligations.
Consumer protection enforcement in carbon trading
The introduction of POJK 10/2026 marks a transformative phase in Indonesia’s carbon trading market, elevating consumer protection standards by classifying carbon credits as financial products under the OJK (Financial Services Authority). This shift introduces comprehensive enforcement measures to safeguard participants within the carbon market.
The regulation pivots from focusing solely on trading mechanics to embedding financial consumer protection principles into carbon trading. Market participants must now adhere to these principles, which cover transparency, fair treatment, detailed information dissemination, and robust dispute resolution mechanisms.
The regulation underscores four key protections. Firstly, transparency mandates that exchanges and brokers disclose crucial data—prices, fees, carbon unit origin, project specifics, and risks—eliminating hidden information. Secondly, fairness and non-discrimination ensure equal market access for all trading parties.
Thirdly, data security commitments require safeguarding personal and company trading data. Lastly, a well-defined dispute resolution mechanism focuses on addressing issues like faulty credits or fraudulent activities. The OJK’s empowered role in overseeing, auditing, and correcting any lapses in consumer protection rules builds trust among domestic and international market players.
By aligning with capital market standards, the regulation enhances Indonesia’s market credibility and protects vulnerable groups like farmers and small enterprises from exploitative practices.
Participants are now held to higher responsibilities. Carbon exchanges must implement standard operating procedures for risk management and complaint handling, ensuring thorough disclosure. Sellers are tasked with providing accurate and verifiable project data. Buyers benefit from clear information channels and assured recourse for discrepancies, facilitating effective ESG reporting.
Electronic transition facilitation
The world of carbon trading often experiences rapid regulatory changes. However, the OJK aims to ease these transitions with a new regulation under POJK 10/2026, known as Electronic Transition Facilitation. This regulation is designed to maintain market stability and continuity during system upgrades.
A crucial element of this regulation is the introduction of a three-month transition period for electronic systems. As the new SRUK system is implemented, projects with units registered in the previous Ministry system can still trade on the Carbon Exchange. This approach improves upon the prior regulation, POJK 14/2023, which presumed the SRN PPI system was ready for immediate deployment.
Recognising the need for SRUK to fully mature operationally, OJK has wisely instituted a temporary measure. During this transition, trading is supported in several practical ways. Projects are not forced to pause trading as they await SRUK migration. Existing units with valid electronic records from KLHK remain tradable, ensuring continued market activity.
Additionally, this period provides crucial time for integrating the Carbon Exchange with SRUK systems, allowing developers to connect and migrate data seamlessly over three months. Once the transition period ends, only units documented within SRUK will be eligible for issuance, transfer, or retirement on the exchange—without exception. The new regulation’s ability to prevent market disruptions ensures continuous liquidity and averts a potential trading halt until SRUK is fully operational.
Compliance risks are consequently minimised; companies holding credits in the old system avoid unexpected liquidity shortages. This approach effectively aligns technological advancements with policy updates. Market participants experience varied implications according to their current status. Projects holding credits in the previous system should seize this period to migrate to SRUK while keeping trading activities ongoing.
Carbon exchanges face the challenge of supporting both old and new records throughout this phase. Conversely, new projects should register directly with SRUK to simplify future operations. In essence, by implementing a three-month transitional framework, OJK facilitates ongoing operations and stability in the carbon trading sector.
This strategy exemplifies OJK’s commitment to updating technological systems without disrupting market dynamics—akin to replacing an engine while ensuring the car continues to run smoothly.
POJK 10/2026 aims to transform the carbon exchange from a pilot initiative into a credible, liquid market integrated with government efforts. This development is intended to support Indonesia in achieving its 2030 emissions targets.
Initially, the main purpose was that ‘now Indonesia has a carbon exchange’. The amended POJK regulation is now sending a message to the world that “Indonesia now has a carbon exchange that is transparent, offers more products, safeguards users, and connects globally.”
Banner photo: A stunning aerial view of a dense green forest canopy in Chukai, Malaysia. Pok Rie/Pexels.com
