How Are Greenhouse Gas Inventories Conducted Under PERMENLHK 21/2022?

1.0 The Carbon Economic Value Framework: Linking GHG Inventory to Climate Action

Indonesia's commitment to reduce greenhouse gas emissions by 29-41% by 2030 under its Nationally Determined Contribution (NDC) requires a comprehensive system to measure, report, and verify emissions reductions. PERMENLHK 21/2022 on the Implementation of Carbon Economic Value (Tata Laksana Penerapan Nilai Ekonomi Karbon) establishes this framework by integrating greenhouse gas inventory systems with carbon trading mechanisms, performance-based payments, and carbon levies. The regulation, enacted on September 21, 2022, and effective from October 20, 2022, implements Presidential Regulation 98/2021 and creates a unified architecture for tracking emissions, certifying reductions, and enabling carbon market transactions across Indonesia's economy.

The regulation defines Greenhouse Gas Inventory (Inventarisasi Emisi GRK) as "kegiatan untuk memperoleh data dan informasi mengenai tingkat, status, dan kecenderungan perubahan Emisi GRK secara berkala dari berbagai sumber emisi dan penyerapnya" - activities to obtain data and information regarding the level, status, and trends of GHG emissions periodically from various emission sources and sinks (Pasal 1 ayat 16). This definition positions inventory as a foundational activity that feeds into all other carbon economic value mechanisms. Inventory data provides the baseline emissions, tracks actual emissions performance, and enables verification of emissions reductions claimed by business actors. The regulation recognizes that without accurate, consistent, and transparent inventory data, the entire carbon economic value system would lack credibility and effectiveness.

The Carbon Economic Value (NEK) system applies to six core sectors: energy, waste, industrial processes and product use, agriculture, forestry, and other sectors as science and technology evolve (Pasal 2 ayat 3). Within these sectors, the regulation identifies 13 sub-sectors including power generation, transportation, buildings, solid waste, liquid waste, municipal waste, industry, rice cultivation, livestock, plantations, forestry, peatland and mangrove management, and other emerging sub-sectors (Pasal 2 ayat 4). Each sector and sub-sector must conduct periodic GHG inventories to establish baseline emissions, measure actual performance, and quantify emissions reductions. This comprehensive sectoral coverage ensures that inventory methodologies can be tailored to the unique characteristics of each sector while maintaining overall consistency and comparability across the national system.

The regulation establishes four implementation mechanisms for Carbon Economic Value: carbon trading, performance-based payments, carbon levies, and other mechanisms aligned with scientific and technological developments (Pasal 3 ayat 2). GHG inventory data serves all four mechanisms. For carbon trading, inventory results determine whether business actors exceed or remain below their emission caps. For performance-based payments, inventory verifies the emissions reductions achieved against baseline scenarios. For carbon levies, inventory data identifies which goods, services, or activities contain carbon or emit carbon subject to taxation. This multi-purpose inventory system represents a significant efficiency gain, as a single measurement system serves multiple policy instruments rather than requiring separate monitoring for each mechanism.

Matrix 1.1: GHG Compounds Covered Under PERMENLHK 21/2022

Source: Pasal 58 ayat (4) PERMENLHK 21/2022

The regulation's inventory framework supports Indonesia's international climate commitments. Every GHG Emissions Reduction Certificate (SPE-GRK) issued represents one ton of CO₂-equivalent emissions reduced or sequestered (Pasal 58 ayat 5). By standardizing all greenhouse gases to CO₂-equivalent units, the system enables aggregation across different gases and sectors, facilitating national-level reporting to the UNFCCC and tracking progress toward NDC targets. The regulation also establishes protocols for recording inventory data in the National Climate Change Control Registry System (SRN PPI), creating a centralized, transparent, and publicly accessible database of emissions information. This transparency supports both domestic accountability and international reporting obligations under the Paris Agreement's Enhanced Transparency Framework.

2.0 The MRV System: Measurement, Reporting, and Verification Architecture

The regulation establishes Measurement, Reporting, and Verification (MRV) as the core operational framework for GHG inventory activities. Defined as "kegiatan untuk memastikan bahwa data dan/atau informasi Aksi Mitigasi Perubahan Iklim dan Aksi Adaptasi Perubahan Iklim telah dilaksanakan sesuai dengan tata cara dan/atau standar yang telah ditetapkan serta dijamin kebenarannya" - activities to ensure that data and/or information on Climate Change Mitigation Actions and Climate Change Adaptation Actions have been implemented according to established procedures and/or standards and their accuracy is guaranteed (Pasal 1 ayat 30). The MRV system serves as the quality assurance mechanism for all inventory data, ensuring that emissions calculations meet international standards and can withstand independent scrutiny.

The MRV architecture operates through a three-phase lifecycle: planning and documentation, implementation and monitoring, and verification and certification. During the planning phase, NEK implementers develop Design Documents for Climate Change Mitigation Actions (DRAM) that specify baseline scenarios, emissions reduction methodologies, monitoring structures, and resource requirements (Pasal 63). These planning documents undergo validation by accredited validators to ensure methodological soundness before implementation begins. During the implementation phase, NEK implementers conduct periodic measurements following approved methodologies, maintain monitoring records, and calculate emissions or emissions reductions. Finally, independent verifiers conduct verification activities to confirm the accuracy and credibility of reported data, leading to certification of emissions reductions through SPE-GRK issuance.

The regulation establishes stringent competency requirements for validators and verifiers. Both must be accredited by the National Accreditation Committee (Komite Akreditasi Nasional) and possess competency as validators and verifiers for Climate Change Mitigation Action achievements related to Carbon Economic Value (Pasal 40 ayat 2). They must demonstrate no conflict of interest through direct or indirect involvement in implementing the mitigation actions they assess. Competency qualification requires meeting at least two of four criteria: holding certificates aligned with Indonesian national work competency standards for GHG emissions reduction validation and verification; possessing at least two years of experience handling climate change issues and carbon economic value mechanisms; holding formal education in climate change or climate change-related fields; or possessing training certificates in climate change (Pasal 40 ayat 3-4). When accredited validators and verifiers are insufficient, technical experts registered in SRN PPI and meeting the same competency criteria may conduct validation and verification (Pasal 40 ayat 5-6).

The verification timeline establishes clear deadlines to prevent indefinite delays. Verification must be completed within six months from the date the implementation report is submitted to the verifier (Pasal 41 ayat 1). This timeline excludes time needed by NEK implementers to clarify data or address findings (Pasal 41 ayat 7). Verification must assess four critical elements: whether eligibility criteria established in the applied methodology have been properly satisfied; the accuracy and credibility of data used in monitoring mitigation actions; absence of double registration in other certification schemes; and no discrepancies between planned and monitored implementation of mitigation actions (Pasal 41 ayat 2). The verification report must contain a summary of verification processes and scope, verification results and assurance levels, details of verification team members and their roles, findings from desk reviews and field reviews, and report preparation dates (Pasal 41 ayat 3).

Matrix 2.1: MRV Process Flow and Validation/Verification Requirements

Source: Pasal 39-41, 63-66 PERMENLHK 21/2022

When verification results indicate non-conformity, the NEK implementer must supplement documentation according to verifier recommendations within five working days of receiving verification results (Pasal 41 ayat 4 and ayat 6). This rapid response requirement ensures that data quality issues are addressed promptly and do not create bottlenecks in the certification process. When verification results show conformity, the verifier issues a statement of emissions reduction achievement to the NEK implementer (Pasal 41 ayat 5). This verified statement becomes the foundation for applying for SPE-GRK issuance. The Director General, through the MRV technical team, reviews the application and coordinates with relevant ministers before issuing SPE-GRK within 14 working days of receiving conformity verification (Pasal 66). This streamlined timeline - six months maximum for verification, five days for non-conformity responses, and 14 days for certification - creates predictability for business actors planning carbon market participation.

The regulation integrates international methodological standards throughout the MRV system. NEK implementers must use methodologies aligned with the latest Intergovernmental Panel on Climate Change (IPCC) guidelines, international or Indonesian national standards, and prevailing laws and regulations (Pasal 60 ayat 2 huruf e). Acceptable methodologies include those established by the Director General, established by the National Standardization Agency (Badan Standarisasi Nasional), or approved by the United Nations Framework Convention on Climate Change (UNFCCC) (Pasal 60 ayat 2 huruf f). This multi-source approach provides flexibility for different sectors while maintaining methodological rigor. By referencing IPCC guidelines and UNFCCC-approved methodologies, the regulation ensures that Indonesian inventory practices remain compatible with international climate reporting standards and carbon market protocols, facilitating international carbon trading under Article 6 of the Paris Agreement.

3.0 The National Registry System: SRN PPI as Indonesia's Carbon Accounting Infrastructure

The National Climate Change Control Registry System (Sistem Registri Nasional Pengendalian Perubahan Iklim or SRN PPI) functions as Indonesia's centralized carbon accounting infrastructure. Defined as "sistem pengelolaan, penyediaan data, dan informasi berbasis web tentang aksi dan Sumber Daya untuk Mitigasi Perubahan Iklim, Adaptasi Perubahan Iklim, dan NEK di Indonesia" - a web-based management system for data and information provision regarding actions and resources for Climate Change Mitigation, Climate Change Adaptation, and Carbon Economic Value in Indonesia (Pasal 1 ayat 25). The SRN PPI serves multiple functions simultaneously: it records all NEK activities and transactions, maintains operational accounts for carbon unit holders, tracks emissions baselines and reduction targets, publishes public information on carbon markets, and generates annual reports on emissions trading and offset mechanisms.

Business actors are mandatorily required to record and report their implementation of Carbon Economic Value activities in the SRN PPI (Pasal 42 ayat 1). Ministries/agencies, regional governments, and communities may voluntarily record and report their NEK implementation in the system (Pasal 42 ayat 2). This mandatory recording for business actors ensures that commercial carbon transactions are fully transparent and traceable, while voluntary recording for other entities encourages broader participation in climate action without imposing administrative burdens on non-commercial actors. The recording covers all four NEK mechanisms: carbon trading, performance-based payments, carbon levies, and other emerging mechanisms (Pasal 42 ayat 3). This comprehensive recording creates a complete national inventory of climate mitigation actions and carbon flows, supporting both policy evaluation and international reporting obligations.

The registration process involves three sequential stages: registration of implementing parties, validation of planning reports, and verification of implementation reports (Pasal 42 ayat 4). Each stage creates a checkpoint where data quality and methodological compliance are assessed before proceeding to the next phase. For carbon trading specifically, the SRN PPI maintains separate recording protocols for emissions trading and offset mechanisms. Emissions trading records capture: carbon trading roadmaps established by relevant ministers, Upper Emission Limits (PTBAE) at the sector level, Upper Emission Limits for Business Actors (PTBAE-PU), transaction results of PTBAE-PU, monitoring and evaluation plans, verified emissions reduction achievements, SPE-GRK issuances, domestic and international carbon unit transfers, and emissions balance calculations that aggregate inventory results with carbon trading transfers (Pasal 44, 52). This granular recording enables tracking of individual business actor compliance with emission caps and aggregate tracking of sectoral emissions performance.

For offset mechanisms, the SRN PPI records: offset roadmaps established by relevant ministers or governors, baseline emissions and reduction targets, business actor project proposals, periodic emissions reduction achievements, validation and verification reports, tradeable SPE-GRK quantities, domestic and international SPE-GRK transfers, and direct trading results (Pasal 46). The registry maintains separate operational accounts for each NEK implementer that receives SPE-GRK or PTBAE-PU issuances (Pasal 53). When SPE-GRK or PTBAE-PU units are used by implementers, the Director General transfers them to cancellation accounts within the carbon registry (Pasal 54). Cancellation accounts record the quantity used, purpose of use, and the party using the units if different from the account holder (Pasal 54 ayat 2). This dual account system - operational accounts for active holdings and cancellation accounts for retired units - prevents double counting and ensures that claimed emissions reductions correspond to actual atmospheric benefits.

Matrix 3.1: SRN PPI Recording Requirements by NEK Mechanism

Source: Pasal 42-51 PERMENLHK 21/2022

The SRN PPI publishes public information on Carbon Economic Value implementation through multiple formats: graphics, tables, and distribution maps of climate adaptation and mitigation actions and resources (Pasal 56 ayat 2). Public information content includes: procedures and mechanisms for NEK implementation; information on activities/businesses implementing NEK including trading opportunities, carbon prices, and carbon markets; planning documents for mitigation actions and annual NDC achievement reports through NEK implementation; monitoring and evaluation reports on NEK implementation; and information about expert groups in the climate change field (roster of experts) (Pasal 56 ayat 3). This public information must be announced periodically at least once annually through SRN PPI (Pasal 56 ayat 4). The transparency provisions enable civil society monitoring of climate action, support business planning for carbon market participation, and facilitate international review of Indonesia's NDC implementation.

The emissions balance calculation recorded in SRN PPI provides the comprehensive national inventory figure. For emissions trading participants, the annual emissions balance equals: actual emissions from GHG inventory plus carbon units from PTBAE-PU plus emissions reduction achievements from PTBAE-PU plus SPE-GRK transferred internationally (Pasal 52 ayat 3 huruf d). For offset mechanism participants, the annual emissions balance equals: actual emissions from GHG inventory plus SPE-GRK transfers within Indonesia plus offset emissions plus international SPE-GRK transfers to partner countries (Pasal 52 ayat 4 huruf i). These balance calculations integrate inventory data (actual emissions) with carbon trading activities (transfers and offsets) to provide a comprehensive accounting of each entity's net emissions position. By aggregating these individual entity balances across all sectors, the Ministry of Environment and Forestry can calculate national emissions totals, track progress toward NDC targets, and identify sectors or sub-sectors requiring additional mitigation policies.

4.0 Inventory Methodologies and Baseline Establishment: Technical Standards for Emissions Quantification

The regulation establishes rigorous methodological standards for GHG inventory to ensure that emissions calculations are scientifically credible and internationally comparable. All inventory activities must be transparent, accurate, consistent, comprehensive, and comparable (Pasal 60 ayat 1 huruf d). These five qualities align with UNFCCC reporting principles and IPCC Good Practice Guidance, ensuring that Indonesian inventory data meets international standards for climate reporting. Transparency requires that assumptions, methodologies, and data sources are clearly documented. Accuracy requires that emissions estimates are systematically neither over nor under actual emissions as far as can be judged. Consistency requires that methodologies remain constant over time to enable trend analysis. Comprehensiveness requires that all emission sources and sinks within defined boundaries are included. Comparability requires that methodologies align with IPCC guidelines to enable cross-country comparisons.

Baseline Emissions (Baseline Business as Usual Emisi GRK) forms the foundation of inventory work, defined as "perkiraan tingkat emisi dan proyeksi GRK pada Sektor atau kegiatan yang telah diidentifikasi dalam jangka waktu yang telah ditetapkan tanpa intervensi kebijakan dan/atau teknologi mitigasi" - estimated emission levels and GHG projections for identified sectors or activities over specified time periods without policy or mitigation technology interventions (Pasal 1 ayat 15). Establishing accurate baselines is critical because all emissions reductions are measured against these reference scenarios. If baselines are inflated, claimed emissions reductions will be overstated. If baselines are too conservative, actual mitigation efforts may be undervalued. The regulation requires that baseline emissions for performance-based payment projects remain below sectoral or sub-sectoral reduction targets (Pasal 49 ayat 2 huruf a), ensuring that projects demonstrate additionality beyond business-as-usual trends.

Methodologies must be approved through formal processes. For offset mechanisms seeking SPE-GRK issuance, methodologies must be established by the Director General, established by the National Standardization Agency, or approved by the UNFCCC (Pasal 60 ayat 2 huruf f). The Director General maintains a panel of methodology experts (panel metodologi GRK) that reviews and approves methodology applications (Pasal 63 ayat 2 huruf b). This panel system ensures that novel methodologies are peer-reviewed for scientific validity before being deployed in inventory work. Approved methodologies provide standardized calculation procedures, default emission factors for common activities, monitoring protocols, quality assurance procedures, and uncertainty assessment approaches. By using approved methodologies, NEK implementers can be confident that their inventory work will be accepted by verifiers and ultimately lead to SPE-GRK certification.

For sectors or activities not covered by existing approved methodologies, the regulation allows NEK implementers to propose new methodologies based on IPCC guidelines, international standards (such as ISO 14064), or national Indonesian standards. The methodology approval process involves submitting detailed technical documentation that specifies: applicability conditions defining when the methodology can be used, baseline scenario determination procedures, project scenario determination procedures, additionality demonstration approaches, monitoring parameters and measurement protocols, quality assurance/quality control procedures, calculation formulas for emissions reductions, and uncertainty assessment methodologies. Once approved, these methodologies become part of the national methodology library available to all NEK implementers, reducing the transaction costs of inventory development and promoting consistency across similar project types.

Matrix 4.1: Inventory Calculation Components and Data Requirements

Source: Pasal 1(15-16), Pasal 60-63 PERMENLHK 21/2022 and IPCC Guidelines

The Design Document for Climate Change Mitigation Actions (DRAM) serves as the inventory work plan. DRAM content requirements include: explanation of proposed mitigation actions, application of approved methodologies, calculations of emissions reductions, environmental impact analysis, climate change resources needed, revision history, monitoring implementation structure, public consultation processes and results, bibliography, and supporting appendices (Pasal 63 ayat 2). The DRAM essentially functions as a project design document similar to those used in Clean Development Mechanism (CDM) projects under the Kyoto Protocol, providing comprehensive technical documentation that enables validators to assess project credibility. The regulation provides detailed DRAM templates in Annex II (Lampiran II) to standardize documentation across different project types and sectors.

The regulation recognizes existing international certification schemes through mutual recognition arrangements. GHG emissions reduction certificates issued by other certification bodies can be declared equivalent to SPE-GRK after mutual recognition cooperation is established with the Minister (Pasal 68 ayat 1). The mutual recognition process involves: mutually sharing information on MRV standards used, conducting conformity assessments against international or Indonesian national standards, issuing conformity assessment statements, implementing mutual recognition cooperation agreements, and publishing mutually recognized certifications in SRN PPI (Pasal 68 ayat 3). This mutual recognition pathway enables Indonesian entities that have already obtained international carbon credits (such as Verified Carbon Standard credits or Gold Standard credits) to convert those credits to SPE-GRK for use in domestic carbon trading, avoiding duplicative verification costs and facilitating international carbon market integration under Paris Agreement Article 6.

5.0 Inventory Applications Across NEK Mechanisms: From Data Collection to Climate Finance

GHG inventory data flows through all four Carbon Economic Value mechanisms, demonstrating how a unified measurement system serves multiple policy objectives. In emissions trading systems, inventory data determines compliance status. Business actors subject to Upper Emission Limits for Business Actors (PTBAE-PU) must conduct annual inventories of their actual emissions (Pasal 10 ayat 4 huruf a). If actual emissions exceed their PTBAE-PU allocation, they must purchase carbon units from other actors with surplus allocations. If actual emissions fall below their PTBAE-PU allocation, they may sell surplus allocations to deficit actors or bank them for future compliance periods. The inventory thus becomes the compliance measurement tool, with financial consequences directly linked to inventory accuracy. Business actors have strong incentives to maintain high-quality inventory systems because underestimated emissions create compliance liabilities while overestimated emissions forfeit revenue opportunities from selling surplus allocations.

For offset mechanisms, inventory data quantifies the emissions reductions eligible for SPE-GRK certification. Offset projects calculate baseline emissions, implement mitigation interventions, measure actual emissions post-intervention, and claim the difference as emissions reductions (Pasal 61 ayat 3). These claimed reductions undergo verification by accredited third parties who assess whether the inventory methodologies were correctly applied, monitoring data are credible, and calculated reductions are accurate (Pasal 65). Only verified emissions reductions receive SPE-GRK certification, which can then be sold to compliance buyers (entities subject to PTBAE-PU needing additional allocations), voluntary buyers (companies seeking to offset their carbon footprint), or international buyers (subject to corresponding adjustment requirements). The inventory quality directly affects project economics: rejected or discounted emissions reductions reduce project revenues and may render projects financially unviable.

Performance-based payments require inventory verification to trigger payment disbursements. Performance-based payment mechanisms provide incentives or payments obtained from verified emissions reduction achievements and/or validated non-carbon benefits (Pasal 1 ayat 6). Payment amounts typically correlate with verified emissions reductions, measured in tons of CO₂-equivalent. For example, if a donor agrees to pay $5 per ton CO₂e reduced, and a provincial government verifies emissions reductions of 10 million tons CO₂e through forest conservation, the payment would total $50 million. The inventory provides the measurement basis for calculating owed payments. Performance-based payment projects must document baseline emissions or reference levels that represent the highest feasible emissions level, with values below sectoral or sub-sectoral reduction targets (Pasal 49 ayat 2 huruf a). National strategies must articulate mitigation actions to reduce emissions through 2030, and safeguards must address potential negative impacts (Pasal 49 ayat 2). The Minister establishes these planning documents, which undergo validation before implementation and verification before payments are released (Pasal 49 ayat 3).

Carbon levies use inventory data to establish tax bases and identify liable parties. Carbon levies are state charges, either central or regional, imposed on goods and/or services with carbon potential or content, and/or businesses or activities with emission potential that emit carbon causing negative environmental impacts and/or affecting mitigation action performance (Pasal 1 ayat 20). Implementing carbon levies requires identifying which goods, services, or activities emit how much carbon. National or sectoral GHG inventories provide the emissions intensity data needed to set levy rates proportional to carbon content. For example, if national inventory reveals that cement production emits 0.9 tons CO₂ per ton of cement, a carbon levy of 100,000 IDR per ton CO₂ would translate to a 90,000 IDR levy per ton of cement. The Ministry of Finance conducts recording of carbon levy implementation in SRN PPI (Pasal 50 ayat 2), and the Minister uses these records to compile annual reports on NEK implementation through carbon levy mechanisms (Pasal 50 ayat 3).

Matrix 5.1: Inventory Data Flows Across NEK Mechanisms

Source: Pasal 44-71 PERMENLHK 21/2022

The regulation establishes a buffer reserve system to manage risks in carbon accounting. When conducting carbon trading, implementers must provide an emissions reduction reserve (buffer) as risk control for achieving NDC targets, sized at: 0-5% of SPE-GRK for domestic offset projects; at least 10% and up to 20% of SPE-GRK for international offset projects; and at least 20% of SPE-GRK for international offset projects outside NDC scope (Pasal 7 ayat 2). The buffer percentages for international projects are set by the Minister after coordinating with relevant ministers (Pasal 7 ayat 3) and can be adjusted periodically based on evaluation of verified annual NDC achievement reports (Pasal 7 ayat 4). If reserve buffers remain after sectoral, sub-sectoral targets are achieved for two consecutive years, partial or full reserves can be returned for subsequent carbon trading (Pasal 7 ayat 5). This buffer system addresses inventory uncertainties and the risk that some offset projects may fail to deliver promised reductions, ensuring that carbon trading does not undermine overall NDC achievement.

The regulation facilitates capacity building for inventory practitioners. Capacity enhancement activities include technical guidance on: GHG emissions inventory, emissions reduction capabilities, climate resilience improvement efforts, and provision of climate change resources (Pasal 80 ayat 2). The Ministry, relevant ministers, and regional governments are responsible for providing information on inventory implementation procedures, carbon trading opportunities and prices, mitigation action mapping, national/sectoral/regional/business actor emissions projections, annual emissions reduction achievements, non-carbon values including biodiversity and water services, and mutual benefits between mitigation and adaptation actions (Pasal 79). This information is disseminated through electronic and non-electronic media (Pasal 79 ayat 2). By building national inventory capacity, the regulation aims to reduce dependency on international consultants, improve data quality through local expertise, and create career pathways for climate professionals in Indonesia's emerging green economy.

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This article is part of the PERMENLHK 21/2022 Analysis Series:

• Article 65 (Current): How Are Greenhouse Gas Inventories Conducted Under PERMENLHK 21/2022?
• Related Analysis: Carbon Trading Mechanisms Under Indonesia's NEK Framework
• Related Analysis: Performance-Based Payments for Climate Mitigation in Indonesia
• Related Analysis: MRV Systems for Carbon Markets: Indonesia's Implementation Approach

Regulation Reference

Primary Source:
- Regulation: Peraturan Menteri Lingkungan Hidup dan Kehutanan Republik Indonesia Nomor 21 Tahun 2022 tentang Tata Laksana Penerapan Nilai Ekonomi Karbon (Minister of Environment and Forestry Regulation Number 21 of 2022 on Implementation of Carbon Economic Value)
- Enacted: September 21, 2022
- Effective: October 20, 2022
- Citation: BN 2022/NO 1064; 79 pages
- Official Source: https://peraturan.bpk.go.id/Details/235421/permen-lhk-no-21-tahun-2022
- Download: https://peraturan.bpk.go.id/Download/288901/Permen%20LHK%20Nomor%2021%20Tahun%202022.pdf

Regulatory Basis:
- Presidential Regulation No. 98 of 2021 on Carbon Economic Value Implementation for Nationally Determined Contribution Achievement and Greenhouse Gas Emissions Control in National Development

Key Definitions Referenced:
- Pasal 1 ayat (1): Nilai Ekonomi Karbon (Carbon Economic Value)
- Pasal 1 ayat (2): Gas Rumah Kaca (Greenhouse Gas)
- Pasal 1 ayat (16): Inventarisasi Emisi GRK (GHG Inventory)
- Pasal 1 ayat (30): MRV (Measurement, Reporting, and Verification)
- Pasal 1 ayat (25): SRN PPI (National Climate Change Control Registry System)

Legal Disclaimer

IMPORTANT LEGAL NOTICE

This analysis is provided for informational and educational purposes only and does not constitute legal advice, regulatory guidance, or professional consultation. While every effort has been made to ensure accuracy, readers should:

1. Consult Official Sources: Always refer to the official regulation text published by the Republic of Indonesia government for authoritative legal interpretation
2. Seek Professional Advice: Consult qualified legal counsel, environmental consultants, or carbon market specialists for specific compliance questions
3. Verify Current Status: Confirm that PERMENLHK 21/2022 remains in effect and has not been amended, superseded, or revoked
4. Consider Implementation Regulations: Review technical guidelines, ministerial decisions, and director general regulations issued to implement PERMENLHK 21/2022
5. Monitor Updates: GHG inventory methodologies and MRV protocols evolve with scientific developments and international standards

This analysis:
- Interprets PERMENLHK 21/2022 based on publicly available regulatory text
- Provides a general framework for understanding GHG inventory requirements
- Does not address specific facility-level compliance obligations
- Does not replace formal validation or verification by accredited bodies
- May not reflect subsequent amendments, implementing regulations, or ministerial decisions

Limitation of Liability: The authors and publishers assume no responsibility for errors, omissions, or consequences resulting from use of this analysis. Compliance with Indonesian GHG inventory regulations requires facility-specific assessment by qualified professionals.

Carbon Market Participation: Entities considering carbon trading, offset project development, or performance-based payment programs should engage accredited validators/verifiers and legal counsel to ensure full regulatory compliance.

For Official Guidance: Contact the Directorate General of Climate Change Control, Ministry of Environment and Forestry of the Republic of Indonesia.

This analysis was prepared by the CRPG Legal Analysis Team on November 26, 2025. Document version 1.0.

Disclaimer

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We accept no liability whatsoever for any decisions made based on this article. Readers are strongly advised to:

• Consult the official regulation text from government sources
• Seek professional legal counsel for specific matters
• Verify all information independently

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