Compliance Steps for Businesses Under the New Sanctions Rule: PERMENLH 6/2026

PERMENLH 6/2026 changes the day-to-day obligations of any firm that holds an environmental approval or a business licence. Because it revokes the earlier Permen LHK 14/2024 under Pasal 84 and takes effect on the date of its promulgation under Pasal 85, operators should treat its requirements as live. This memo sets out what the regulation expects of regulated businesses.

The Issue

The transition is clean rather than phased. Pasal 84 declares the 2024 predecessor revoked and of no further force, and Pasal 85 brings the new rules into effect on promulgation, without a separate grace period in the body of the instrument. From that date, supervision plans, inspection records, and sanction decisions are governed by the new framework, and an operator's prior compliance history carries forward into it.

Key Provisions

Several duties fall directly on the operator. Reporting is continuous: Pasal 9 draws inspection data from operator reports and the online single submission system (Sistem OSS), and Pasal 32 requires inspection reports to be uploaded to that same platform, so a firm's filings feed its own compliance record. Pasal 33 prohibits obstructing supervision in any form, including withholding or falsifying data. Where government coercion (paksaan pemerintah) is ordered, Pasal 42 requires the operator to maintain a remediation guarantee fund that the state can draw on if the operator fails to act.

Money obligations are equally specific. Pasal 51 requires an operator that has been fined to submit proof of payment, and warns that an unpaid fine is transferred to the state-receivables agency for collection. Because Pasal 45 pegs the principal fines to the value of the investment, a firm's documentation of its fixed and working capital becomes directly relevant to any future penalty.

Compliance status itself is a managed variable. Pasal 30 assigns each inspected activity a status of compliant or non-compliant, and Pasal 19 and Pasal 20 make that status, including a firm's rating under the Proper performance program, a factor in how often it is inspected. A consistent record of compliance reduces inspection intensity, while repeat breaches and a poor rating raise it.

Implications

The regulation gives operators defined rights alongside these duties. Pasal 66 grants a right to object to a sanction decision, but Pasal 67 requires the objection to reach the issuing authority within seven days, and Pasal 69 confirms that the sanction continues to run while the objection is reviewed. Pasal 54 allows a firm to seek an exemption from the daily late penalty where a natural disaster, permit processing, or the unavailability of suitable technology caused the delay, subject to the good-faith test in Pasal 55.

Practically, a firm should confirm that its environmental approval and licence remain consistent with its actual operations, since Pasal 45 attaches a five-percent charge to unpermitted expansions or changes. It should keep its reporting current in the licensing system, preserve evidence of investment value, and treat the 30-day window in Pasal 39 for a written warning as the first and cheapest opportunity to correct a breach before escalation begins.

Regulatory Context

The compliance burden mirrors the parent regulations the instrument implements, PP 22/2021 and PP 28/2025, which place environmental obligations inside the risk-based licensing system. Pasal 75 commits each authority to evaluate its enforcement record at least once a year, which means the data operators file will also shape how supervision evolves. For regulated businesses, the safest reading is that the regulation rewards current, accurate filings and early correction, and penalises silence and delay.

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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