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October 23, 2026
by Tiyana Sigi Pertiwi
Overview
The Financial Services Authority (OJK) has officially issued OJK Regulation No. 10 of 2026 (POJK 10/2026), amending POJK No. 14 of 2023 on Carbon Trading through the Carbon Exchange. POJK 10/2026 was issued to align the provisions on carbon trading through the carbon exchange with Presidential Regulation No. 110 of 2025, which superseded several provisions of Presidential Regulation No. 98 of 2021.(1) The regulation was stipulated on 2 July 2026, promulgated 6 July 2026, and took effect on the date of its promulgation. Through Press Release SP 133/DKPU/OJK/VII/2026, OJK stated that the regulatory adjustments form part of the government’s support for strategic policies concerning the implementation of carbon economic value instruments and efforts to control greenhouse gas emissions.(2) This regulatory update by OJK is expected to provide legal certainty and strengthen domestic carbon trading infrastructure for integration with the global market.(5)
The regulation expands the types of carbon units that may be traded on the exchange, including carbon units from overseas. It also requires Carbon Units to be recorded in the Carbon Unit Registry System (Sistem Registri Unit Karbon/SRUK), which, as per OJK’s statement during its press release, replaces the National Registry System for Climate Change Control (Sistem Registri Nasional Pengendalian Perubahan Iklim/SRN PPI).(2) SRN PPI now remains as the registry for recording fulfilment of Indonesia’s Nationally Determined Contribution (NDC).(4) SRUK was launched on 9 July 2026 by the Ministry of Environment/Environmental Control Agency (KLH/BPLH) and is governed by Minister of Environment/Head of BPLH Regulation No. 10 of 2026 on the Carbon Unit Registry System.(3) Accordingly, Carbon Units traded on the exchange must now be recorded in SRUK, subject to the exception for overseas carbon units.
Further, the POJK No. 10/2026 also strengthens reporting obligations for exchange operators and the implementation of consumer protection principles for transacting parties.
Key Highlights
Carbon Units as Securities and Listing Requirements
Pursuant to Article 1 point 3, Article 3, and Article 5, Carbon Units are Securities in the form of emission reductions and/or removals certified under domestic or international certification schemes, or in the form of GHG Emission Allowances, expressed in tonnes of carbon dioxide equivalent. Carbon Units traded through the Carbon Exchange must first be listed on the SRUK and with the Carbon Exchange Operator, subject to the exception for overseas carbon units. The Carbon Units available for trading consist of GHG Emission Allowances, GHG Emission Reduction Certificates (SPE GRK) (i.e. emission reductions verified through measurement, reporting and verification (MRV) and listed in SRUK under a registry number and/or code), and non-SPE GRK.(1)
Overseas Carbon Units
The Carbon Exchange Operator may also facilitate trading of overseas carbon units not recorded in SRUK, provided that it does not conflict with prevailing laws. Such units must: (a) be registered, validated, and verified by a body accredited by an international registry system operator and/or be recorded on an overseas carbon exchange, and (b) meet other requirements set by OJK after coordination with the minister responsible for environmental protection and management. The operator must ensure the integrity, quality, and recording standards of these units. Failure to do so is subject to administrative sanctions.(1)
Carbon Exchange Trading Procedures and Supervision by OJK
The new Article 12A provides that the procedures for conducting Carbon Trading through the Carbon Exchange will be set by the OJK. Note that as of the date of this Regulatory Update article, OJK has also issued a Regulation of the Member of the Board of Commissioners of the OJK on these procedures, i.e. PADK No. 6 of 2026 on the Procedures for Conducting Carbon Trading through the Carbon Exchange, effective 24 July 2026.(6)
Further under Article 26 of this regulation, it provides that OJK is to supervise exchange operators, supporting market infrastructure, service users, Carbon Unit transactions and settlements, governance of Carbon Trading, risk management, consumer protection, and related parties, products, and activities. Additionally, the newly added Article 26(3) allows OJK’s supervision of service users to cover their sustainability governance in conducting Carbon Trading activities.(1)
Reporting Obligations for Carbon Exchange Operators
Article 31 requires Carbon Exchange Operators to submit monthly recapitulation reports of service users’ transactions no later than the fifth trading day of the following month and annual reports, including audited financial statements by an OJK-registered accountant, no later than the end of the third month after the annual financial statements’ date. Reports on service user approvals or rejections, organizational or system changes, and violations and sanctions must be submitted no later than the following trading day. Special events, such as those related to the disruption of the trading system and trading surveillance, must be reported by the end of the same trading day, while the resignations of Directors or members of the Board of Commissioners, General Meeting of Shareholders (GMS) results, and copies of GMS notarial deeds are due within two working days of, respectively, the date of resignation becoming known, the date of the GMS, and receipt of the notarial deed. OJK may also require certain reports, such as periodic Carbon Unit transaction data, to be submitted to the relevant ministries. Once OJK sets such reporting, it becomes mandatory for the operator. OJK may also postpone the resignations of Directors or members of the Board of Commissioners if they could potentially affect the operator’s performance and operation.(1)
Administrative Sanctions, Consumer Protection, and OJK Policies
Article 33 provides that violations of specified provisions, including the new SRUK recording and overseas-unit integrity obligations under Article 3(2) and (5), may be subject to administrative sanctions. Such sanctions may be in the form of written warnings, fines, business activity restrictions or suspension, revocation of business licenses, cancellation of approvals, and/or cancellation of registrations. Sanctions also apply to parties that cause such violations. OJK may impose sanctions other than a written warning without first issuing one, and fines may be imposed alone or together with other sanctions.(1)
Article 35A establishes the application of relevant consumer protection principles to all parties involved in Carbon Trading through the Carbon Exchange. Meanwhile, Article 35B authorizes OJK to provide for different policies that depart from this regulation based on certain considerations, which the elucidation lists as including supporting national policy, safeguarding the public interest, supporting industry growth, ensuring SRUK’s operational readiness, and maintaining fair competition.(1)
Tiyana Sigi Pertiwi
Knowledge Lawyer
