Coal Blending Approval in Mining Work Plans: PERMENESDM 6/2026

The Ministry of Energy and Mineral Resources has amended its 2025 rules on mining work plans to create a licensing route for coal blending. The amending instrument, Minister of Energy and Mineral Resources Regulation 6 of 2026, amends Regulation 17 of 2025 on the procedures for preparing, submitting, and approving the annual Work Plan and Budget, known by its Indonesian abbreviation RKAB, and on the reporting of mineral and coal mining activities. It was signed in Jakarta on 8 June 2026 and enters into force on promulgation.

Issue

Indonesian mining operations run on an annual RKAB, approved by the Minister or the Governor according to their respective authority. The plan fixes what a permit holder may produce and sell in a given year. Coal buyers, however, contract for particular specifications, such as a target calorific value or a ceiling on sulphur and ash, and a single mine's output does not always meet them. Blending coal from one permit holder with coal sourced from another is the standard commercial answer, but the 2025 rules did not set out how such blending fits within an approved RKAB. Regulation 6/2026 supplies that mechanism and, in the same stroke, adds a correction power for defective RKAB decisions.

Key Provisions

Pasal 33 addresses the administrative side. Where an administrative error or an evaluation error by the Minister or the Governor occurs in the process of issuing an RKAB approval or rejection, the Minister or the Governor may correct it within their authority. The provision gives the issuing official an express basis to reopen a flawed decision rather than leaving the permit holder to challenge it.

Pasal 34A is the operative addition. Holders of an IUP or IUPK at the production operation stage, holders of an IUPK that continues a coal contract or agreement, and PKP2B holders that already hold an approved RKAB may blend coal in order to meet a particular coal specification, but only after obtaining the Minister's approval. The application is filed with the Minister through the information system and must carry, at a minimum: the RKAB approvals of both the base coal owner and the blending coal owner; copies of the signed purchase contract for the blending coal and the sale contract for the blended product; certificates of analysis for the base and blending coal issued by a surveyor registered with the directorate general responsible for mineral and coal supervision; and a simulation of the coal specification before and after blending covering calorific value on both an as-received and an air-dried basis, sulphur content, moisture content, and ash content.

The Minister evaluates the application and either approves or rejects it. An approval runs for the same period as the RKAB approval, which ties the blending permission to the annual planning cycle rather than granting it open-endedly. A rejection must state the reasons on which it rests. Pasal 34B then defers the detailed guidance on the application, evaluation, and approval of coal blending to a separate Ministerial Decision, which had not yet been issued at the time of promulgation.

Implications

Blending becomes a permissioned act rather than a matter of internal commercial arrangement. Because approval is tied to the validity period of the RKAB, permit holders will need to seek it on an annual rhythm alongside the work plan itself, and a blending arrangement negotiated mid-year will depend on both counterparties holding current RKAB approvals. The documentary requirements also pull third parties into the file: the sale and purchase contracts must be signed before the application is lodged, and the quality data must come from a surveyor on the directorate general's register rather than from the operator's own laboratory. Companies whose supply chains touch mining sites should read the blending file alongside the wider environmental compliance obligations that attach to production operations, since the same production volumes are reported into more than one supervisory system.

Regulatory Context

Regulation 6/2026 sits in a run of ministerial instruments issued during 2026 that adjust reporting and supervision duties across the resources and environment sectors, a group that also includes the supervision rules issued by the Ministry of Environment. The amendment takes effect on promulgation and carries no transitional period, so the approval requirement applies to blending conducted from that date. The scope of the practical detail left to the forthcoming Ministerial Decision under Pasal 34B is, for now, the open item.

Read the full regulation in the CRPG Law Database.

Methodology: This memo summarises the official regulation text and is not legal advice; report corrections to contact@crpg.info.

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