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January 2, 2026
Originally published in ACTIO E-Magazine Edition 28 (December 2025). Law as of December 2025.
Indonesia’s CCS framework covers capture, transport and storage on paper, but it does not yet define where offshore CCS applies, how CO2 shipping is regulated, or how ministries coordinate at sea. The EU and Norway show what a complete framework looks like: clear spatial scope, a connected transport-to-storage chain, and one coordinated institutional structure.
Carbon capture and storage is central to Indonesia’s climate strategy, supported by Presidential Regulation No. 14 of 2024 and MEMR Regulations No. 2 of 2023 and No. 16 of 2024. Together these instruments introduce a domestic licensing structure, specify technical and environmental requirements, and outline operational responsibilities for capture, transportation, injection, storage and closure. They recognise multiple capture technologies and establish permits for carbon transport by pipeline, truck and ship — which indicates that maritime application is anticipated, even though the regulations do not explicitly refer to offshore or sub-seabed storage.
Indonesia is currently developing three major CCS hubs that function as shared carbon aggregation points: Tangguh in West Papua, positioned as the first large-scale hub capable of serving both domestic and international emissions; Sunda Asri in West Java, strategically located near major industrial clusters and designed to store up to 3 gigatons of CO2; and Masela in Maluku, intended to receive CO2 shipments from domestic sources as well as from regional neighbouring countries.
The question is how these hubs will be governed once CO2 starts moving by ship and being injected beneath the seabed. That question turns on three issues: jurisdictional zones, sea-based CO2 transport, and inter-ministerial coordination.
Indonesia’s future approach to offshore CCS will be shaped by the regime governing activities at sea. UNCLOS provides the jurisdictional basis for states to regulate carbon storage in maritime zones such as the territorial sea, exclusive economic zone and continental shelf. Indonesia is also a party to the 1972 London Convention but has not ratified the 1996 London Protocol or its 2006 amendment — the instruments that form the contemporary framework authorising the placement of carbon dioxide beneath the seabed. Several of the Protocol’s underlying principles are reflected in Presidential Regulation No. 14 of 2024, particularly through provisions regulating capture, transportation and storage in a manner consistent with international expectations for environmental and CCS deployment safety.
Indonesia’s stance on the framework is therefore mixed: UNCLOS ratified (Law No. 17 of 1985) and the London Convention 1972 ratified (Presidential Decree No. 103 of 1977), but the London Protocol 1996 and its 2006 amendment not ratified, and the IMO’s specific guidelines for assessing CO2 streams for disposal into sub-seabed formations applicable only voluntarily, as non-treaty standards. The EU Directive and Norway’s continental shelf regulations may be treated as policy references.
The European Union applies its Directive on the Geological Storage of Carbon Dioxide (Directive 2009/31/EC) to both onshore and offshore formations within the maritime zones of its member states — including the exclusive economic zone and the continental shelf. That approach establishes clarity regarding jurisdiction. Indonesia, by contrast, currently adopts a spatially neutral approach: its regulations do not specify whether CCS activities extend to the exclusive economic zone or the continental shelf.
Norway, although not a member of the European Union, has adopted a similar model through its Regulations relating to the Exploitation of Subsea Reservoirs on the Continental Shelf for the Storage of Carbon Dioxide. Offshore CCS is managed within Norway’s continental shelf petroleum framework, which allows coordinated oversight of transport operations, injection activities, risk management and monitoring — a comprehensive framework covering site selection, monitoring, liability and post-closure obligations.
Indonesia requires inter-ministerial coordination when designating a Carbon Storage Permit Area under Presidential Regulation 14 of 2024. Article 11 sets out the requirement for coordination among ministries, and Article 24 establishes the obligation to obtain a carbon transportation permit. The regulation also grounds a general basis for potential cross-border cooperation, although detailed provisions on transportation modalities are regulated in MEMR Regulation No. 16 of 2024.
Building on these comparative lessons, Indonesia needs to develop a clearer spatial mandate for CCS transportation at sea and translate inter-ministerial roles into operational procedures. That means establishing explicit jurisdictional boundaries, technical requirements for ship-based CO2 transport, and mechanisms for cross-border movements — and linking the mandates of the Ministry of Energy and Mineral Resources, the Ministry of Marine Affairs and Fisheries, the Ministry of Environment and Forestry and the Ministry of Transportation into one coordinated mechanism.
To move forward, Indonesia needs a governance architecture that operationalises international principles into clear domestic procedures: a dedicated permitting system for offshore storage, environmental and technical assessment standards for CO2 streams, and cross-border transport rules consistent with the London Protocol model. Aligning these elements early will help build a predictable, investment-ready framework that supports safe CCS deployment at sea.
A central task is determining the spatial scope of CCS operations in the exclusive economic zone and continental shelf, where Indonesia exercises specific rights and obligations under international law. Clear jurisdictional rules and institutional coordination are equally important. Strengthening these arrangements will allow Indonesia to manage offshore transport, monitoring and long-term stewardship within a coherent regulatory framework.
Does Indonesia have rules for offshore CCS yet?
Not specifically. Presidential Regulation 14 of 2024, MEMR Regulation 2 of 2023 and MEMR Regulation 16 of 2024 provide a licensing and operational foundation, but they do not explicitly address offshore or sub-seabed storage.
Where are Indonesia’s CCS hubs?
Three are developing: Tangguh in West Papua, Sunda Asri in West Java (designed to store up to 3 gigatons of CO2), and Masela in Maluku, which is intended to receive CO2 from domestic and regional sources.
Has Indonesia ratified the London Protocol on sub-seabed CO2 storage?
No. Indonesia ratified UNCLOS and the 1972 London Convention, but has not ratified the 1996 London Protocol or its 2006 amendment, which authorise sub-seabed CO2 disposal.
How do the EU and Norway regulate offshore CCS?
The EU Directive applies to storage in the EEZ and continental shelf of member states. Norway governs offshore CCS through its continental shelf petroleum framework, with coordinated oversight of transport, injection, monitoring and liability.
What coordination does Indonesian law already require?
Under Presidential Regulation 14 of 2024, Article 11 requires inter-ministerial coordination before a Carbon Storage Permit Area is designated, and Article 24 requires a carbon transportation permit.
Indonesia’s evolving framework for CCS has established the foundational elements for licensing, technical standards and operational oversight. But when examining jurisdictional zones, sea transport and inter-ministerial coordination, it is clear that several governance components will need further development as Indonesia prepares for marine-based implementation. Lessons from the EU and Norway show the value of clearly defining spatial jurisdiction in the EEZ and continental shelf, designing transport and storage as a connected regulatory chain, and building an integrated institutional structure for supervising activities at sea. Advancing these elements will help Indonesia establish a predictable and credible governance system for CCS activities at sea.
