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Big Updates: A Goodbye, a Bioeconomy, and Carbon Rules Getting Real

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Today was my last day at S&T. After 18 years. I walked in at 22 and walked out having grown up (professionally and otherwise) inside that building. I'm sad, grateful, a little bit giddy, and mostly just thankful for every single person who made those years what they were.


What's next? Stay tuned for the official announcement next week. In the meantime, the world of climate law did NOT pause, so here's what's been on my desk lately.


1. The Bioeconomy Is Having Its Moment

Bioeconomy is now formally part of the national medium-term development plan (RPJMN), and Bappenas is conducting an FGD and drafting a roadmap that stretches all the way to 2045. Indonesia doesn't have an official definition of bioeconomy yet, so the FGDs have been working on the vocabulary in parallel with the policy. The working framework has 10 principles and three criteria. To count as bioeconomy, an activity needs:


  • Value added, meaning we stop selling raw and start selling processed

  • Technology and innovation, applied along the chain

  • Better welfare, especially for the communities who've been doing this for generations


That last point came up again and again: local communities are the spearhead of the bioeconomy, because their existing practices are the foundation to build on. This ties neatly into the downstreaming (hilirisasi) agenda and Indonesia's ambition to climb the Economic Complexity Index. Stop exporting raw stuff, start exporting smart stuff.


Meet KEM and VC3


KEM (Koalisi Ekonomi Membumi) is a coalition pushing for what it calls a responsible bioeconomy: one that keeps ecological integrity intact, strengthens community welfare, and spreads the economic benefits more fairly.


Its main tool is the Value Chain Collaboration Canvas (VC3). The idea first came from the Supernova Ecosystem / Konstelasi Accelerator, and KEM has been developing it ever since. VC3 maps the whole value chain, not just the supply chain. A supply chain tracks products moving downstream. A value chain asks who creates economic, social and environmental value along the way, including the supporting actors everyone forgets. It rests on four principles: protect ecology and biodiversity, put communities at the centre as main actors (not just beneficiaries), strengthen local value addition, and enable multi-actor collaboration. Very gotong royong, very Indonesian.


And it isn't just a nice diagram. Through its Value Chain Collaboration Lab (VACIL), KEM is testing VC3 on commodities like tengkawang (illipe nut), vanilla, cacao, coffee, cubeb pepper, clove, nutmeg, palmyra (lontar), coconut and seaweed, from West Kalimantan to Lembata, Maluku and Bali. The coalition reports 95 jurisdictions committed, 55 business actors connected, and over US$5 million mobilised so far. My favourite finding, from the lontar work in East Nusa Tenggara: even when a resource is abundant in nature, long-term supply depends on social networks and trust, not just on what's growing.


My take: the bioeconomy roadmap could be the policy bridge between conservation, economic growth, and the grand downstreaming dreams that we've been talking about for years.


2. Carbon Rules Are Getting Real


The regulatory jigsaw is (almost) complete

Perpres 110/2025 replaced Perpres 98/2021 as the umbrella for carbon pricing (NEK, or Nilai Ekonomi Karbon), and 2026 has been the year the ministries rushed to write their implementing rules:


  • Forestry: Permenhut 6/2026 (offsets for FOLU) and 7/2026 (KSDAE), April

  • NDC: Permen LH 7/2026, June

  • Registry and exchange: Permen LH 10/2026 and POJK 10/2026, with the national registry (SRUK) launching on 9 July and linking straight to IDXCarbon

  • Waste: Permen LH 11/2026 (offsets), August

  • Agriculture: Permentan 18/2026 (offsets), October, though it takes effect later

  • Still in the pipeline: rules on authorisation, blue carbon, energy-sector offsets and trading, the national carbon trading roadmap, PNBP on carbon, and two industry regulations (more on those below)


The government's pitch is that a high-integrity, globally connected carbon market could be worth up to US$7.7 billion a year for Indonesia. Big number. Let's see.


IDXCarbon: three years in, the numbers are in


At IDXCarbon Talks on 21 October, OJK shared the scorecard from launch on 26 September 2023 to 19 October 2026:


1,979,208 tCO2e traded in 482 transactions, worth Rp94.03 billion, with 160 registered service users


IDX is clearly trying hard to grow the market. Registration and listing are free until at least the end of 2027, transaction fees are a tiny 0.11–0.22%, and trading hours have doubled from 6 to 12. Demand is also maturing. KADIN's Net Zero Hub (now 102 member companies) described buyers moving from cheap volume offsetting to high-integrity credits, long-term offtakes and real Scope 3 decarbonisation. Global brands are already asking their Indonesian suppliers for emissions data.


If you're a listed company and don't know where to start, IDX is running a Net Zero Bootcamp on GHG accounting (ISO 14064-1) and climate reporting (IFRS S1/S2) for its carbon exchange users.


Industry gets its own offset rulebook

On 19 October, the Ministry of Industry (through its Green Industry Center) held a public consultation on a draft regulation on carbon trading through GHG emission offsets in the industrial sector. This is the industry piece of the Perpres 110/2025 jigsaw.


The highlights:


  • Who's in: industrial companies that are NOT regulated installations under emissions trading. If you're under an emissions cap, you play in the trading system instead.

  • What counts: mitigation in industrial processes and product use (IPPU): low-carbon technology, low-carbon products, material efficiency and substitution, carbon capture and utilisation (CCU), and other actions as science evolves. It covers six gases: CO2, CH4, N2O, HFCs, PFCs and SF6.

  • The homework catch: to get a project recognised, you need to have reported your industry data to SIINas every quarter for the last four quarters. Data discipline first, credits later.

  • A 12-step journey in SRUK: from registration and project documents, through validation and verification by accredited bodies (KAN-accredited for the national SPE-GRK scheme), to the issuance of carbon units.

  • Two routes: for national SPE-GRK units, the Minister of Industry issues a recommendation and the environment ministry issues the units. For international-standard units, the Minister gives an approval, valid for six months, that you take to the international scheme.

  • Going overseas: units used for another country's NDC or international obligations (Article 6.2/6.4, compliance) need authorisation and a corresponding adjustment. Purely voluntary units that won't count towards NDCs don't.

  • Transition: units issued before Perpres 110/2025 don't need new recognition, but projects registered before it must apply for recognition.


Alongside this, Kemenperin's broader plan for carbon pricing in industry covers nine priority subsectors (cement, fertiliser, metals, pulp and paper, textiles, chemicals, ceramics and glass, food and beverage, and transport equipment). It starts with offsets and only moves towards emissions trading later, with preparation in 2026–2027 and a voluntary first phase from 2028.


Industry uses about half of Indonesia's final energy, and coal is still around 41% of the primary energy mix, so this matters. If you're in any of those nine sectors, start counting your emissions properly. Today.


3. Q4 Outlook: Big Numbers, Bigger Questions

  • Nuclear is officially on the table. The government is eyeing around 7 GW of nuclear alongside its 100 GWp solar target, with site selection expected by 2026/2027. Whatever your feelings about nuclear, the legal and safety framework for it is going to be a massive piece of work.

  • Jakarta wants investors. Governor Pramono pitched 37 projects worth about US$7 billion (around Rp115 trillion) to investors in New York in September. Urban climate finance, here we come?

  • Data centres are the new frontier. The IFC's private sector diagnostic for Indonesia flags data centres as a growth area. They're energy-hungry, so this sits right where digital growth meets the clean energy transition.


The theme for Q4, as always: realisation is what we should watch.


4. For the Weekend

Because you deserve something nice after all those acronyms:

  • How to Live on Earth, a documentary narrated by Benedict Cumberbatch. Yes, that voice, explaining how we can actually live well on this planet.

  • Can lawyers save the earth?, a BBC podcast. Obviously I'm biased, but my answer is: not alone, but we can definitely help.


Wrapping Up

So that's the update: one big personal chapter closed, and a policy landscape moving faster than ever, from bioeconomy roadmaps to carbon offsets to nuclear dreams. Thank you for reading, for sticking around, and for caring about this stuff as much as I do.


See you next week for the big announcement 🌱

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