SRUK is Live - What's next?

Last week, representing ACEXI, I sat in a room at the MPR complex for an audience with Pak Eddy Soeparno. If the name isn't familiar: Pak Eddy is Deputy Speaker of the MPR RI and one of the most consistent voices in our parliament on energy transition, climate action, and the carbon economy. He is the main promotor of the Renewable Energy Bill (RUU EBET) and the Climate Change Management Bill (RUU Pengelolaan Perubahan Iklim) (MPR RI), as well as carbon economy policies.

Our conversation covered stakeholder updates, the next steps for consolidation, and where we might collaborate. Let me unpack the parts worth sharing.

SRUK is launched — so what's next?

Stakeholders waited a long time for this. The Carbon Unit Registry System (SRUK) finally went live this month under Minister of Environment Regulation No. 10 of 2026, the implementing rule mandated by Presidential Regulation No. 110 of 2025 on Carbon Economic Value. Around the same time, OJK Regulation No. 10 of 2026 made SRUK the single reference point for trading on the Carbon Exchange.

But a registry is infrastructure, not a destination. The launch answers "where do we record carbon?" — not "is there a real market for it?" The next target everyone in the room agreed on is market fostering: deliberately building the ecosystem so Indonesia actually has a functioning market and a commodity product that is high-integrity, not just a ledger with thin volume. Registry first, liquidity and credibility next.

Sectoral rules run in parallel — but Pak Eddy's focus is the Climate Change Bill

While sectoral regulations move ahead ministry by ministry, one of Pak Eddy's main focus is now on the RUU Pengelolaan Perubahan Iklim, which sits in the 2026 Priority Prolegnas (national legislation program). In principle, this bill would give Indonesia the legal foundation for climate governance, rather than the current patchwork of executive-level Perpres, Permen, and POJK.

Based on the public drafting so far, the bill is expected to:

• Serve as the primary legal basis for responding to the climate crisis in a coordinated, sustainable way (Bijak Memantau);

• Work through two approaches — mitigation (controlling emission sources across sectors like energy and industry) and adaptation (social resilience and economic readiness) — with an explicit emphasis on climate justice for vulnerable groups;

• Regulate carbon governance, climate finance, and the energy-transition mechanism, and require carbon footprints — from corporations up to the state itself — to be monitored, recorded, and calculated, with sanctions for violations;

• Establish a dedicated Climate Change Management Agency (Badan Pengelolaan Perubahan Iklim) at the national level.

There's a live structural debate on this: whether to pass this as a standalone law or fold it into a revision of Law No. 32 of 2009 on Environmental Protection and Management (UU PPLH). Legal scholars are genuinely split on the merge-versus-separate question. (Hukumonline · Kompas Lestari) And civil society — WALHI and the Aruki alliance among them — has flagged that the current draft leans market-oriented and is still soft on corporate accountability and state obligation. Those are fair critiques, and the kind that should shape the draft rather than derail it.

The idea of a standalone carbon body

Connected to all of this is a proposal that keeps resurfacing: forming a dedicated national carbon body to centralise governance — one authority to certify, record, and oversee, so that claims and transactions stop being scattered across systems and investor trust can actually build. The argument is that a clear, single institution is what a credible green economy needs. (Liputan6)

Whether that body arrives through the RUU (as the BPPI) or as its own institution is part of what still has to be worked out. Either way, the direction of travel is toward consolidation.

Meanwhile, the money moved: BPDLH shifts to the Coordinating Ministry for Food

Here's a development with real consequences for anyone waiting on climate finance. The Environmental Fund Management Agency (BPDLH) — which holds roughly Rp22 trillion (about US$1.33 billion) in environmental funds — is being restructured, with its steering committee moving under the Coordinating Ministry for Food Affairs, having previously sat within the environmental/economic coordination line. (Kemenko Pangan)

The candid part: Coordinating Minister Zulkifli Hasan has openly acknowledged that this Rp22 trillion largely cannot be disbursed yet because the governing rules are too difficult to work with — prompting a revision of the underlying Presidential Regulation to finally get the money flowing to communities and green development. (Liputan6) When the financing plumbing itself is stuck, no amount of registry infrastructure makes the market feel real on the ground.

Closing thoughts

Reading it all back, the honest summary is: we still have a lot of homework. SRUK is a genuine milestone, and the legislative and institutional pieces are finally moving. But amongst lawyers, there are still foundational legal questions remain the hardest, for example, carbon unit as an intangible movable object (benda bergerak tidak berwujud), it's recognize as a security (efek), and — underneath everything — the question of ownership and how title transfers cleanly from one hand to the next, can become a security under our security laws? One interesting note is that Renewable Energy Certificates (RECs) — a close cousin of the carbon unit. Rather than being treated as a security, the REC has been regulated as a commodity, traded on the futures exchange under Bappebti's rules, with ICDX as its exchange.

So we have two closely related green instruments living in two entirely different legal universes — one leaning security, the other commodity. How the law eventually reconciles that will tell us a great deal about the market we're actually building. Interesting, isn't it?

That's the work. I'm grateful ACEXI has a seat at the table for it — and I'll keep sharing what I learn, from the intersection of law, climate, and the ground beneath it.