The Third Amendment has now revised several provisions that specifically address procurements of goods and services for subsequent use by Cooperation Contract Contractors (Kontraktor Kontrak Kerja Sama KKKS). During contract preparations, KKKS must only list domestically produced goods that meet the technical standards that are set out on the Approved Manufacturer/Vendor List (AML/AVL), while all payments must be processed through state-owned banks, regionally owned banks, or national private banks. In terms of the available tender mechanisms, the Third Amendment has now shortened the award issuance deadline to three business days, extended the contract signing period to 45 business days and also now requires Special Task Force for Upstream Oil-and-Gas Business Activities (Satuan Kerja Khusus Pelaksanaan Kegiatan Usaha Hulu Minyak dan Gas Bumi/SKK Migas) approvals to be issued for any tender awards that exceed Rp. 300 billion or US$ 20 million.

This Draft Bill ("Draft Bill") is set to become the Third Amendment to Law No. 30 of 2009 on Electrical Power ("Law 30/2009") and affirms that business entities that have been granted areas for the distribution and/or sale of electrical power will be required to operate in line with the National General Electrical Power Plan (Rencana Umum Ketenagalistrikan Nasional/RUKN) and Electrical Power Supply Business Plan (Rencana Usaha Penyediaan Tenaga Listrik/RUPTL). Any failure to realize the aforementioned electrical power plans will result in the imposition of administrative sanctions that will range from written reprimands and administrative sanctions up to the revocation of issued business permits.

The Amendment has now revised the applicable Non-Tax State Revenue (Penerimaan Negara Bukan Pajak/PNBP) royalty rates that apply to holders of Special Mining Business Licenses (Izin Usaha Pertambangan Khusus/IUPK) who continue their operations under Contracts of Work (Kontrak Karya/KK) or Coal Contracts of Work (Perjanjian Karya Pengusahaan Pertambangan Batubara/PKP2B). The revised royalty rates now follow a six-tier structure, as determined in line with certain Coal Benchmark Price (Harga Batubara Acuan/HBA) thresholds.

Oil-and-gas contractors are now allowed to form partnerships in order to manage their working areas under various cooperation agreements, including operational and/or technological cooperation and oil-well production cooperation. Operational and technological cooperation may be implemented in conjunction with qualified business entities or permanent establishments ("Partners") for idle or producing wells and fields/structures. Meanwhile, oil-well production cooperation may involve Regionally Owned Enterprises (Badan Usaha Milik Daerah/BUMD), Cooperatives or Micro-, Small- or Medium-Scale Enterprises (MSME) during a temporary period that will extend until 10 June 2029, with Contractors obliged to compensate any community members who are responsible for the direct operation of any wells.

Companies are required to complete annual compliance assessments of their Oil-and-Gas Safety Management Systems (Sistem Manajemen Keselamatan Minyak dan Gas Bumi/SMKM) through a self-assessment mechanism. The results of said self-assessments should be submitted to the Director of Oil-and-Gas Engineering and Environment, who also serves as the Head of Oil-and-Gas Inspections, by a deadline of 1 March for the previous assessment year. Assessment results are rated from Outstanding to Poor across six categories based on the relevant total and core substance scores. In addition, Companies are also required to submit corrective action plans within 30 calendar days of receiving their assessment results.

This revised framework outlines various new obligations that apply to parties involved in or that are affected by the installation of electrical power transmission networks ("Transmission Networks"), specifically in terms of the provision and use of free space and minimum clearance areas ("Clearance Space"). These obligations now apply to owners of Transmission Networks, holders of land, buildings or plants lying underneath Clearance Space, and communities that engage in activities in nearby areas. Owners of Transmission Networks are required to compensate parties impacted by the construction, installation or maintenance of Transmission Networks through monetary payments, particularly when any such work results in the alteration of the relevant horizontal clearance or requires partial relocations to be completed for safety reasons.

Mineral management within the International Seabed Area (Kawasan Dasar Laut Internasional "KDLI") must be conducted in three phases: 1) Prospection; 2) Exploration; and 3) Exploitation. These activities must be carried out by the Minister or eligible business entities, including State-Owned Enterprises (Badan Usaha Milik Negara/BUMN) and private entities through domestic or foreign investment schemes in accordance with specific requirements and agreements with the International Seabed Authority. Extracted minerals that are generated through exploitation must be utilized to support Indonesias national interests, particularly through domestic downstream processing. It should also be noted that any non-compliance may result in the imposition of administrative sanctions.

Eleven new types of Non-Tax State Revenue (Penerimaan Negara Bukan Pajak "PNBP") that will now apply at the Directorate-General of Minerals and Coal have been unveiled. The parties that will be subject to mandatory PNBP payments ("Payers") under this new framework include holders of mineral and coal mining licenses, who must calculate and submit their PNBP payments through the designated electronic system for verification and monitoring by relevant authorities. Additionally, Payers may file PNBP objections or requests for leniency (keringanan) under specific circumstances (e.g. force-majeure events, financial liquidity challenges or considerations that arise from government policies). Said leniency may include deferred payments, payments in installments or payment exemptions.

Regulation of the President No. 16 of 2025 on the Indonesian Sustainable Palm-Oil Certification System ("Regulation 16/2025") expands the scope of Indonesian Sustainable Palm Oil ("ISPO") certification to include Plantation Companies, downstream industries and bioenergy enterprises. Regulation 16/2025 also introduces a clearer certification renewal timeline, requiring applications to be submitted one year prior to their expiration, and imposes stricter sustainability requirements such as traceability. Compliance deadlines have been phased as follows: 2025 for Plantation Companies, 2027 for Industries/Enterprises and 2029 for Growers.

The scope of the parties required to implement energy management has now been expanded to include: 1) Transport sector users who consume 4,000 tons or more of oil equivalent per year; 2) Industrial sector users who consume 4,000 tons or more of oil equivalent per year; and 3) Building sector users who consume 500 tons or more of oil equivalent per year. Additionally, the range of entities eligible to implement energy management now includes: 1) Transport sector users who consume less than 4,000 tons of oil equivalent per year; 2) Industrial sector users who consume less than 4,000 tons of oil equivalent per year; and 3) Building sector users who consume less than 500 tons of oil equivalent per year.