Special Mining Business License (Izin Usaha Pertambangan Khusus "IUPK") holders are now permitted to engage in exports of metal mineral commodities, specifically copper, during the production operation stage, provided that said IUPK holders have completed the construction of metal mineral facilities ("Facilities") but are unable to operate them due to the occurrence of force-majeure events. Force-majeure events are officially designated by the Indonesian National Police Force and are taken into account in relation to insurance claim payments to Facilities.

While maintaining levies on the supply, distribution and transportation of oil-fuels (Bahan Bakar Minyak "BBM") and natural gas via pipelines, this new framework has now revised the applicable levy structure from a tiered percentage system to an updated version that follows a fixed tariff approach. The updated levy tariff now breaks down as follows: 1) For BBM: fixed tariff of 0.25% of realized monthly sales volumes per BBM type multiplied by the applicable sales price; and 2) For gas transportation: fixed tariff of 2.50% of the transportation tariff per Million Standard Cubic Feet (MSCF) multiplied by realized monthly volumes of transported natural gas.

While maintaining Biodiesel (B100) and Bioethanol (E100) on the official list of biofuels (Bahan Bakar Nabati "BBN") permitted for utilization, the new framework of Regulation 4/2025 has now incorporated the following forms of BBN onto the list: 1) Biohydrocarbon Diesel (D100); 2) Bioavtur (J100); and 3) Other types of BBN, as further stipulated by the Minister. Furthermore, Regulation 4/2025 has redefined BBN utilization activities, as originally outlined under the previous framework, through the inclusion of specific categories of both commercial and non-commercial activities relating to BBN.

The new draft regulation ("Draft Regulation") that is ultimately set to repeal and replace Regulation of the Government No. 79 of 2014 ("Regulation 79/2014") on National Energy Policy (Kebijakan Energi Nasional "KEN") introduces a wide variety of revisions to various KEN-related aspects, including: 1) The previously established KEN will be extended until 2060; and 2) Decarbonization within the energy sector and development of the green economy have now been incorporated as areas of primary KEN focus.

As Indonesia steps boldly into 2025, the marine sector is emerging as a critical battleground in the fight against climate change with the introduction of Regulation No. 1 of 2025 on Procedures for the Organization of Carbon Economic Value Within the Maritime Sector. This groundbreaking new framework charts a clear course for the implementation of Carbon Economic Value (Nilai Ekonomi Karbon/NEK) through various innovative mechanisms relating to carbon trading and performance-based payments.

The Draft Bill ("Draft Bill") on the Fourth Amendment to Law No. 4 of 2009 on Mineral and Coal Mining ("Law 4/2009") introduces revisions to a total of seven existing articles originally set out under Law 4/2009 and also includes five new articles. The various revisions that feature under the Draft Bill include: 1) New priority granting of Metal Mineral Mining Business License Areas (Wilayah Izin Usaha Pertambangan/WIUP) to private business entities (for down-streaming purposes) and universities; and 2) Rather than being guaranteed by the government, extensions and transformations of Contracts of Work (Kontrak Karya/KK) and Coal-Mining Concession Work Agreements (Perjanjian Karya Pengusahaan Pertambangan Batubara/PKP2B) into Special Mining Business Licenses (Izin Usaha Pertambangan Khusus/IUPK) as a continuation of KK/PKP2B will become optional in nature.

The offering requirements have now been adjusted, which has resulted in the revision of the types of regionally owned enterprises (Badan Usaha Milik Daerah BUMD) that are considered eligible to receive participating interest (PI) offers. Previously, the requirements mandated fully government-owned regional companies, however, this has now been revised to regional public companies in which the relevant capital is owned by a single region and has not been divided into shares. Additionally, differences between BUMD and their subsidiary companies (BUMD Subsidiaries) have now been clarified, with BUMD Subsidiaries being defined as companies whose shares are partially or entirely owned by BUMD that are established by regional governments, with participation being based on reservoir spreading.

The implementation of carbon storage activities within Carbon Storage License Areas (Wilayah Izin Penyimpanan Karbon WIPK") involves the following phases: 1) Offering and Determination of WIPK; 2) Issuance of an Exploration Permit; and 3) Issuance of a Storage Operations Permit, as well as a Transportation Permit for any business actors who specifically carry out carbon transportation activities.

Previously, Work Plans and Funding Budgets (Rencana Kerja dan Anggaran Biaya "RKAB") that were rejected could only be resubmitted once. Now however, if an RKAB is rejected after its resubmission, then it can be resubmitted in line with new conditions: 1) For the exploration phase: submissions can be made during the subsequent calendar year; 2) For the production-operation phase: submissions can be made the following year for a planned three-year period of mineral and coal mining activities.

Administrative sanctions will now be imposed upon any license and approval holders who fail to comply with their obligations. Sanctions range from written reprimands to temporary activity suspensions and, ultimately, license revocations. License holders must rectify their violations within the timeframe of three consecutive written reprimands, each of which will be sent within seven working days. Moreover, any failure to do so will result in a temporary suspension. Finally, if no improvements are made within 14 days, then the relevant water utilization license will be revoked.