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Siapa yang Boleh Menyusun AMDAL dan Aturan Mana yang Masih Berlaku
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Hukum Perizinan

Who is Allowed to Prepare AMDAL and Which Regulations are Still in Effect

You already know that your business plan requires AMDAL (Environmental Impact Assessment). The next question that often causes confusion is: who can prepare the documents? Preparing AMDAL is not an independent job. The competency of the preparer is regulated, and the service institution must be registered.

The problem is that the legal basis circulating in many consultant proposals is outdated. Here is the current version, complete with its number and date so you can verify it yourself.

One regulation, three matters at once

The reference is the Regulation of the Minister of Environment and Forestry Number 18 of 2021. This single document regulates three things simultaneously: certification of AMDAL competency, institutions providing AMDAL preparation services, and environmental feasibility testing.

The administrative note: established on October 14, 2021, promulgated on October 22, 2021, recorded in the State Gazette 2021 Number 1185, totaling 67 pages. Its status is still valid.

This regulation implements the mandate of Government Regulation Number 22 of 2021 concerning the Implementation of Environmental Protection and Management, which was established on February 2, 2021, and recorded in the State Gazette 2021 Number 32, Supplement Number 6634. That Government Regulation is also still valid.

Four old regulations that have been revoked

Regulation 18/2021 revokes four regulations at once. Two of them specifically concern the competency of the preparers:

  • Regulation of the Minister of Environment Number 7 of 2010, concerning the certification of competency for AMDAL document preparers and the requirements for their training institutions
  • Regulation of the Minister of Environment and Forestry Number P.65/MENLHK/SETJEN/KUM.1/7/2016, concerning the standards and certification of AMDAL preparers, State Gazette 2016 Number 1094

The other two relate to document assessment: Regulation of the Minister of Environment Number 15 of 2010 concerning the licensing of the AMDAL assessment commission, and Regulation of the Minister of Environment Number 8 of 2013 concerning environmental document assessment and the issuance of environmental permits.

The implication for you: if the consultant profile or checklist you received still references P.65/2016 as the basis, that basis was revoked six years ago. This is the cheapest check you can do before signing.

What changes in October 2025

This section is the easiest to overlook. On October 22, 2025, the Regulation of the Minister of Environment/Environmental Control Agency Number 22 of 2025 concerning the Authority to Issue Environmental Approvals will be issued, effective from October 27, 2025.

This regulation revokes part of Regulation 18/2021, specifically Articles 56, 57, and 58.

Note the word "part." Regulation 18/2021 does not entirely lapse, and the framework for competency certification and its service institutions remains intact. Only three articles are revoked. Regulation 22/2025 itself regulates the implementation of issuance, location criteria, business and activities for AMDAL preparation, environmental feasibility testing, approvals, and administrative sanctions.

So if you hold a copy of Regulation 18/2021 downloaded before the end of 2025, that copy does not yet include the revocation notes.

The name of the ministry has changed

This is a small trap that makes people think the regulations do not exist. The 2025 regulation mentioned above is issued under the name of the Ministry of Environment/Environmental Control Agency, no longer KLHK. If your search is filtered with the term KLHK only, the most recent regulations will not appear.

PP 28/2025 does not change this part

Since 2025, many believe that the entire environmental regime has been overhauled by Government Regulation Number 28 of 2025. It needs to be separated. Government Regulation 28/2025 concerning the Implementation of Risk-Based Business Licensing was established on June 5, 2025, recorded in the State Gazette 2025 Number 98, Supplement Number 7115. It revokes Government Regulation Number 5 of 2021, not PP 22/2021.

This means that the framework for environmental approvals, including the regulations on AMDAL preparer competency, does not transfer there.

Three things you can check today

  1. The number and year of the regulations cited in the consultant's proposal. If it still references P.65/2016 or Regulation of the Minister of Environment 7/2010, ask for an update.
  2. Whether the copy of Regulation 18/2021 you have marks Articles 56 to 58 as partially revoked.
  3. Whether the institution you appointed is indeed registered, not just claiming to be experienced.

Environmental regulations change quietly. Not through big announcements, but through three article numbers on the back pages of other regulations.

Sources

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