No Approval, No Operations: Physical Field Activities Banned for Mining Businesses Without Approved RKAB

The Director-General of Minerals and Coal (“Director-General”) has issued Circular No. 3.E/HK.03/DJB/2026 on the Obligation to Secure Approvals for Work Plans and Funding Budgets for Mineral and Coal-Mining Business Activities (“Circular 3/2026”).

As its title suggests, Circular 3/2026 has now strengthened the requirement for mineral and coal-mining businesses that are governed under existing frameworks to have their Work Plans and Funding Budgets (Rencana Kerja dan Anggaran Biaya – “RKAB”) approved by prohibiting businesses that have not secured approved RKAB from engaging in any physical field activities. In this regard, as of the date of publication of this analysis, the Ministry of Energy and Mineral Resources had reported that a total of 106 mining businesses had yet to submit their RKAB for 2026.[1]