Many explanations about Indonesia's carbon market still refer to the National Registry System for Climate Change Control, abbreviated as SRN PPI, as the place where carbon units are recorded. That reference has changed. Since July 6, 2026, carbon units traded on the carbon exchange must be recorded in the Carbon Unit Registry System, abbreviated as SRUK.
Registration is mandatory, exchange is optional
This part is often misunderstood. Presidential Regulation Number 110 of 2025 Article 59 paragraph (1) states that every carbon trade must be recorded in SRUK. Paragraph (2) states that carbon trading can also be recorded on the carbon exchange. The word "can" in the second paragraph is not a mere editorial oversight: registration in the registry is mandatory, while the exchange is an additional channel.
The same Presidential Regulation provides three definitions that separate the roles of each:
- SRUK: a system for providing and managing data and information related to carbon units at the level of economic value instrument implementation.
- Carbon exchange: a system that regulates the recording of carbon trades and the ownership status of carbon units.
- SPE GRK: evidence of emission reductions by businesses or activities that have undergone measurement, reporting, and verification, and are recorded in SRUK in the form of a registration number or code.
The third definition explains why the order cannot be reversed. The certificate only exists after the verification process is completed and the registration number is issued. Without that number, nothing can be traded in the secondary market.
Six key changes brought by POJK 10 of 2026
POJK Number 10 of 2026 was established on July 2, 2026, and promulgated on July 6, 2026, taking effect on the date of promulgation. This regulation amends POJK 14 of 2023 in six ways:
- Carbon units traded on the carbon exchange must be recorded in SRUK, replacing SRN PPI.
- Expansion of the scope of carbon units.
- Regulation of the trade of carbon units from abroad that are not recorded in SRUK.
- Establishment of specific reporting obligations by carbon exchange organizers to the relevant ministries.
- Consumer protection principles in the financial services sector apply to all parties involved in carbon trading through the exchange.
- Facilitation of the trade of carbon units still recorded in the electronic system at the relevant ministries until SRUK operates.
The sixth point has a clear deadline. This facilitation is valid for a maximum of three months after the promulgation of the POJK, thus the window closes on October 6, 2026.
Domestic and international, the requirements are not the same
Domestic carbon trading consists of two forms: greenhouse gas emission trading and greenhouse gas emission offsets. For emission trading, the organization is under the relevant minister according to sector and sub-sector, through the preparation and establishment of regulated installations and the setting of emission caps. This means that entities with established emission caps are in a different position than voluntary buyers.
International trading is stricter. Some pathways require authorization and corresponding adjustment, which is the adjustment of carbon unit records in the NDC to avoid double counting after the units are transferred abroad.
Three things you can check now
- Check whether your contracts, internal procedures, or training materials still mention SRN PPI. The system name needs to be updated, and the reference to Presidential Regulation 98 of 2021 within it has been revoked.
- Ensure your company's position is clear: whether it is an entity with regulated emission caps or a voluntary buyer. The obligations of both are different.
- For units planned to be transferred abroad, trace the authorization pathway from the beginning, not after a buyer is found.
The broader framework of carbon economic value and its relation to national climate targets is discussed separately in this article. If you prefer to see a verbal explanation about the primary and secondary markets, there is also a short clip available.
Sources
- Amendment to POJK Number 14 of 2023 on Carbon Trading Through Carbon Exchanges (POJK 10 of 2026), Financial Services Authority
- Press Release SP 133/DKPU/OJK/VII/2026: OJK Issues New POJK on Carbon Trading Through Carbon Exchanges
- Presidential Regulation Number 110 of 2025 on the Implementation of Economic Value Instruments and National Greenhouse Gas Emission Control, JDIH BPK
- Text of Presidential Regulation Number 110 of 2025, JDIH Ministry of Coordinating for Infrastructure and Regional Development
- OJK Refines Carbon Exchange Regulations, Must Be Registered in SRUK, CNBC Indonesia