How Does UU 6/2023 Amend Environmental and Permit Provisions?

1.0 Introduction: The Environmental Compliance Paradigm Shift Under Job Creation Law

Undang-Undang Nomor 6 Tahun 2023 tentang Penetapan Peraturan Pemerintah Pengganti Undang-Undang Nomor 2 Tahun 2022 tentang Cipta Kerja Menjadi Undang-Undang (Law Number 6 of 2023 on Establishment of Government Regulation in Lieu of Law Number 2 of 2022 on Job Creation as Law, hereinafter "UU 6/2023") represents one of Indonesia's most significant environmental regulatory reforms since the enactment of UU 32/2009 on Environmental Protection and Management. Enacted on March 31, 2023, UU 6/2023 ratifies PERPPU 2/2022, which fundamentally restructures Indonesia's environmental compliance framework by replacing the traditional "izin lingkungan" (environmental permit) system with an integrated "persetujuan lingkungan" (environmental approval) framework that embeds environmental compliance directly into business licensing procedures. This legislative transformation addresses longstanding regulatory inefficiencies where businesses obtained environmental permits and business licenses through separate, sequential processes that created procedural delays, administrative redundancy, and enforcement gaps when violations occurred.

The environmental provisions within UU 6/2023's 1,127-page omnibus law structure primarily amend Undang-Undang Nomor 32 Tahun 2009 tentang Perlindungan dan Pengelolaan Lingkungan Hidup (Law Number 32 of 2009 on Environmental Protection and Management, hereinafter "UU 32/2009"), Indonesia's foundational environmental protection statute. Article 42 of the UU 6/2023 Lampiran introduces comprehensive amendments to UU 32/2009 that transform the legal terminology, administrative procedures, and institutional framework governing environmental compliance across all business sectors in Indonesia. The core innovation replaces the stand-alone environmental permit (izin lingkungan) with environmental approval (persetujuan lingkungan) integrated as a prerequisite condition within the unified business licensing (Perizinan Berusaha) system administered through Indonesia's Online Single Submission (OSS) platform.

This integration creates a fundamentally different compliance architecture. Under the previous UU 32/2009 framework prior to UU 11/2020 amendments, businesses obtained environmental permits (izin lingkungan) from environmental agencies as separate administrative decisions, then separately obtained sectoral business licenses from ministries or regional governments. This dual-pathway system created enforcement challenges: when businesses violated environmental requirements and environmental permits were revoked, business licenses often remained valid because they were issued by different authorities under separate legal bases. Under UU 6/2023's integrated framework, environmental approval becomes embedded within business licensing, meaning that environmental violations triggering approval revocation automatically invalidate the business license itself, creating unified enforcement pathways that strengthen environmental compliance.

The environmental provisions within UU 6/2023 maintain the three-tiered environmental assessment system established under UU 32/2009—AMDAL (Analisis Mengenai Dampak Lingkungan Hidup/Environmental Impact Assessment) for high-impact activities, UKL-UPL (Upaya Pengelolaan Lingkungan Hidup - Upaya Pemantauan Lingkungan Hidup/Environmental Management and Monitoring Efforts) for medium-risk activities, and SPPL (Surat Pernyataan Kesanggupan Pengelolaan dan Pemantauan Lingkungan Hidup/Environmental Management and Monitoring Capability Statement) for low-risk activities. However, UU 6/2023 streamlines the administrative procedures for conducting these assessments, particularly AMDAL, through standardized timelines, centralized assessment teams replacing regional assessment commissions, and digital submission processes through the OSS system. These procedural simplifications address business community concerns about assessment delays while maintaining substantive environmental protection standards through risk-based regulatory approaches.

This comprehensive Regulatory Matrix Analysis examines the specific environmental and permit provisions amended by UU 6/2023, focusing on five critical dimensions: the definitional and terminological transformations from permits to approvals; the institutional restructuring of environmental assessment procedures; the integration of environmental compliance with business licensing; the streamlined AMDAL procedures and timelines; and the enforcement implications of unified environmental-business licensing architecture. Understanding these amendments is essential for businesses operating in Indonesia, environmental practitioners navigating compliance pathways, and policymakers implementing Indonesia's commitment to balancing investment facilitation with environmental sustainability.

2.0 Key Definitions and Scope: From Environmental Permits to Environmental Approvals

Article 42 angka 1 of UU 6/2023 Lampiran introduces comprehensive definitional amendments to Pasal 1 of UU 32/2009, fundamentally transforming the legal terminology governing environmental compliance. The most significant definitional change replaces "izin lingkungan" (environmental permit) with two new terms: "Persetujuan Lingkungan" (Environmental Approval) and "Keputusan Kelayakan Lingkungan Hidup" (Environmental Feasibility Decision). This terminological shift reflects a conceptual transformation in how Indonesian environmental law characterizes the relationship between environmental compliance and business authorization.

The new Pasal 1 angka 35a (inserted by Article 42 angka 1) defines "Persetujuan Lingkungan" as:

"Keputusan Kelayakan Lingkungan Hidup atau pernyataan Kesanggupan Pengelolaan Lingkungan Hidup yang telah mendapatkan persetujuan dari Pemerintah Pusat atau Pemerintah Daerah."

(Environmental Feasibility Decision or Environmental Management Capability Statement that has received approval from the Central Government or Regional Government.)

This definition establishes that environmental approval consists of two pathways: Environmental Feasibility Decisions issued for activities undergoing AMDAL assessment (high-impact activities), and Environmental Management Capability Statements issued for activities submitting UKL-UPL forms (medium-risk activities). Low-risk activities requiring only SPPL (self-declarations) do not obtain environmental approval per se, but rather submit capability statements that satisfy environmental compliance obligations without government pre-approval.

Pasal 1 angka 36 (as amended) redefines "Analisis mengenai dampak lingkungan hidup" (AMDAL) as:

"Analisis mengenai dampak lingkungan hidup, yang selanjutnya disebut Amdal, adalah kajian mengenai Dampak Penting pada Lingkungan Hidup dari suatu usaha dan/atau kegiatan yang direncanakan, untuk digunakan sebagai prasyarat pengambilan keputusan tentang penyelenggaraan usaha dan/atau kegiatan serta termuat dalam Perizinan Berusaha atau persetujuan Pemerintah."

(Environmental Impact Assessment, hereinafter called AMDAL, is an assessment of Significant Impacts on the Environment from a planned business and/or activity, to be used as a prerequisite for decision-making regarding business and/or activity implementation and contained in Business Licensing or Government approval.)

The critical addition here is "serta termuat dalam Perizinan Berusaha atau persetujuan Pemerintah" (and contained in Business Licensing or Government approval), which explicitly integrates AMDAL into business licensing architecture. Under the previous definition, AMDAL served as a prerequisite for environmental permits, which were separate from business licenses. The amended definition establishes AMDAL as a prerequisite contained within business licensing itself, creating the legal basis for integrated environmental-business compliance.

Pasal 1 angka 37 (as amended) redefines "Upaya pengelolaan lingkungan hidup dan upaya pemantauan lingkungan hidup" (UKL-UPL) as:

"Upaya pengelolaan lingkungan hidup dan upaya pemantauan lingkungan hidup, yang selanjutnya disebut UKL-UPL, adalah rangkaian proses pengelolaan dan pemantauan Lingkungan Hidup yang dituangkan dalam bentuk standar untuk digunakan sebagai prasyarat pengambilan keputusan serta termuat dalam Perizinan Berusaha atau persetujuan Pemerintah bagi Usaha dan/atau Kegiatan yang tidak memiliki Dampak Penting terhadap Lingkungan Hidup."

(Environmental Management Effort and Environmental Monitoring Effort, hereinafter called UKL-UPL, is a series of environmental management and monitoring processes documented in standard form to be used as decision-making prerequisites and contained in Business Licensing or Government approval for Business and/or Activity that does not have Significant Impacts on the Environment.)

Again, the addition of "serta termuat dalam Perizinan Berusaha atau persetujuan Pemerintah" integrates UKL-UPL directly into business licensing, eliminating the separate permit pathway. These definitional changes establish the legal foundation for integrated environmental-business licensing, transforming environmental compliance from a separate regulatory track into an embedded condition of business authorization.

Matrix 2.1 below compares the definitional framework before and after UU 6/2023 amendments, highlighting the conceptual transformation from stand-alone environmental permits to integrated environmental approvals embedded within business licensing.

Matrix 2.1: Definitional Transformation Under UU 6/2023 Environmental Amendments

Matrix 2.2: Three-Tiered Environmental Assessment System Under UU 6/2023

3.0 Core Requirements and Provisions: Integrated Environmental-Business Licensing Framework

Article 42 angka 3 of UU 6/2023 Lampiran fundamentally amends Pasal 36 of UU 32/2009, which governs the mandatory requirement for environmental compliance instruments. The amended Pasal 36 establishes the integration of environmental approval with business licensing through three critical provisions.

The amended Pasal 36 ayat (1) states:

"Setiap usaha dan/atau kegiatan yang wajib memiliki Amdal atau UKL-UPL wajib memiliki Persetujuan Lingkungan."

(Every business and/or activity required to have AMDAL or UKL-UPL must have Environmental Approval.)

This provision maintains the mandatory nature of environmental compliance—businesses cannot avoid environmental assessment requirements—but transforms the compliance output from "izin lingkungan" (environmental permit) to "Persetujuan Lingkungan" (Environmental Approval). The significance lies in the integration: environmental approval is not a separate permit obtained from environmental agencies, but rather an approval embedded as a prerequisite condition within the business licensing decision issued through the OSS system.

The new Pasal 36 ayat (3) inserted by UU 6/2023 establishes the integration mechanism:

"Persetujuan Lingkungan sebagaimana dimaksud pada ayat (1) merupakan persyaratan untuk penerbitan Perizinan Berusaha dan/atau persetujuan Pemerintah."

(Environmental Approval as referred to in paragraph (1) constitutes a requirement for issuance of Business Licensing and/or Government approval.)

This provision creates the legal foundation for integrated environmental-business licensing. Businesses cannot obtain business licenses (Perizinan Berusaha) or government approvals for their activities without first satisfying environmental approval requirements. The approval process occurs within the unified OSS platform, where businesses submit environmental assessment documents (AMDAL documents or UKL-UPL forms) electronically as part of their business license applications. Environmental agencies review these submissions and issue environmental approval decisions within the OSS system, which then triggers business license issuance by sectoral ministries or regional governments.

The amended Pasal 36 ayat (4) addresses activities not requiring AMDAL or UKL-UPL:

"Setiap usaha dan/atau kegiatan yang tidak wajib dilengkapi dengan Amdal atau UKL-UPL wajib memiliki Surat Pernyataan Kesanggupan Pengelolaan dan Pemantauan Lingkungan Hidup."

(Every business and/or activity not required to be equipped with AMDAL or UKL-UPL must have Environmental Management and Monitoring Capability Statement.)

SPPL serves as the environmental compliance instrument for low-risk activities, primarily micro and small enterprises. Unlike AMDAL and UKL-UPL requiring government review and approval, SPPL functions as a self-declaration where businesses certify their environmental management commitments. Businesses submit SPPL declarations through the OSS system as part of business license applications, satisfying environmental compliance obligations without requiring pre-approval from environmental agencies.

Article 42 angka 4 amends Pasal 37 of UU 32/2009, which previously specified that environmental permits (izin lingkungan) were issued by ministers, governors, or regents/mayors based on authority distribution. The amended Pasal 37 deletes this provision entirely, reflecting the transformation from stand-alone environmental permits issued by designated authorities to integrated environmental approvals embedded within business licensing decisions. Environmental approval authority now follows business licensing authority—whoever issues the business license (Central Government for national strategic projects, provincial governments for cross-district activities, district/city governments for local activities) also determines environmental approval based on environmental agency recommendations within the OSS system.

Article 42 angka 5 amends Pasal 38 of UU 32/2009, replacing the environmental permit application procedures with environmental approval procedures. The amended Pasal 38 establishes that businesses submit environmental approval applications through the OSS system (sistem OSS) by uploading AMDAL documents (Kerangka Acuan, ANDAL, RKL-RPL) or UKL-UPL forms. The OSS system automatically routes these submissions to designated environmental agencies (Central Government's Ministry of Environment and Forestry for national-level activities, provincial environmental agencies for provincial-level activities, district/city environmental agencies for local activities) based on activity classification and location. Environmental agencies review submissions for administrative completeness and technical adequacy, then issue approval or rejection decisions within the OSS system.

Matrix 3.1 below details the core provisions establishing integrated environmental-business licensing under UU 6/2023, comparing the previous stand-alone permit system with the new integrated approval framework.

Matrix 3.1: Integration of Environmental Approval with Business Licensing Under UU 6/2023

Matrix 3.2: Environmental Assessment Requirements by Activity Risk Level

4.0 Implementation Framework: Streamlined AMDAL Procedures and Institutional Restructuring

UU 6/2023's environmental provisions introduce significant procedural streamlining for AMDAL assessment, addressing longstanding business community concerns about assessment delays while maintaining substantive environmental protection standards. Article 42 angka 6 through angka 10 of UU 6/2023 Lampiran amend Pasal 39 through Pasal 43 of UU 32/2009, restructuring AMDAL preparation, assessment, and approval procedures.

The amended Pasal 39 ayat (1) maintains that AMDAL documents consist of three components: Kerangka Acuan (Terms of Reference/scoping document), ANDAL (Environmental Impact Analysis), and RKL-RPL (Environmental Management and Monitoring Plans). However, UU 6/2023 streamlines the preparation process by standardizing terms of reference formats and eliminating redundant documentation requirements. The Kerangka Acuan defines assessment scope through public consultation (konsultasi publik) where potentially affected communities and other stakeholders identify environmental concerns that the ANDAL must address. The ANDAL provides comprehensive scientific assessment of predicted environmental impacts using baseline studies, impact modeling, and significance evaluation. The RKL-RPL specifies concrete mitigation measures to prevent or minimize negative impacts and monitoring procedures to verify implementation effectiveness.

Article 42 angka 7 amends Pasal 40 of UU 32/2009, which previously established regional AMDAL Assessment Commissions (Komisi Penilai AMDAL) comprising government representatives, independent experts, and community representatives at provincial and district/city levels. UU 6/2023 replaces these regional commissions with centralized Environmental Feasibility Assessment Teams (Tim Uji Kelayakan Lingkungan Hidup) formed by the Central Government's Ministry of Environment and Forestry. This centralization aims to improve assessment consistency, technical quality, and efficiency by creating specialized expert teams with standardized assessment procedures rather than relying on regional commissions with varying expertise levels.

The amended Pasal 40 specifies that Environmental Feasibility Assessment Teams consist of certified environmental experts (ahli bersertifikat) appointed based on technical competence in relevant environmental disciplines. Teams review AMDAL documents submitted through the OSS system, evaluate whether predicted impacts are adequately assessed and proposed mitigation measures are technically sound, conduct field verification if necessary, and issue Environmental Feasibility Decisions approving or rejecting the activity. Approval decisions specify mandatory conditions that businesses must implement, which become binding obligations enforceable through administrative sanctions if violated.

Article 42 angka 8 amends Pasal 41 of UU 32/2009, introducing standardized timelines for AMDAL assessment. The amended provision specifies maximum assessment durations to prevent indefinite delays: Environmental Feasibility Assessment Teams must complete AMDAL reviews within specified timeframes (to be detailed in implementing regulations) from submission of administratively complete documents. If teams do not issue decisions within these timeframes, applications are deemed approved (dianggap disetujui), creating regulatory certainty for businesses. This "deemed approved" mechanism addresses historical delays where assessment commissions took months or years to review AMDAL documents without clear deadlines.

Article 42 angka 9 amends Pasal 42 of UU 32/2009, which previously addressed AMDAL document adequacy. The amended Pasal 42 maintains requirements that AMDAL documents must meet scientific standards, use valid assessment methodologies, and provide accurate baseline data. However, UU 6/2023 streamlines adequacy verification by establishing that environmental agencies conduct administrative completeness checks and technical adequacy assessments simultaneously rather than sequentially. If documents are incomplete or technically inadequate, agencies provide written feedback specifying deficiencies, and businesses resubmit corrected documents within specified timeframes. This iterative process replaces the previous practice where incomplete submissions resulted in outright rejections requiring entirely new applications.

Article 42 angka 10 amends Pasal 43 of UU 32/2009, addressing public participation in AMDAL processes. The amended provision maintains requirements for public consultation during Kerangka Acuan preparation and opportunities for public comment on draft AMDAL documents. However, UU 6/2023 refines public participation scope by distinguishing between "masyarakat terdampak langsung" (directly affected communities) and "masyarakat potensial terdampak" (potentially affected communities). Public consultation requirements now focus on directly affected communities—those whose living environments, livelihoods, or cultural practices are directly impacted by proposed activities—rather than broader potentially affected communities whose connection to impacts may be indirect or speculative.

This refinement addresses criticism that previous public consultation requirements created opportunities for non-affected parties to delay projects through participation processes, while ensuring that communities genuinely impacted by activities retain meaningful input into environmental assessment. Directly affected communities receive notification of proposed activities, participate in scoping consultations defining environmental concerns for assessment, review draft AMDAL documents and provide written comments, and receive responses explaining how their concerns were addressed in final Environmental Feasibility Decisions. This participatory framework balances procedural efficiency with substantive community engagement.

Matrix 4.1 below details the streamlined AMDAL procedures introduced by UU 6/2023, comparing previous procedural requirements with the new standardized timelines, centralized assessment teams, and refined public participation scope.

Matrix 4.1: Streamlined AMDAL Procedures Under UU 6/2023 Amendments

Matrix 4.2: AMDAL Document Components and Requirements Under UU 6/2023

5.0 Practical Implications: Enforcement, Compliance Pathways, and Regulatory Certainty

The integration of environmental approval with business licensing under UU 6/2023 creates profound enforcement implications that fundamentally strengthen Indonesia's environmental compliance regime. Under the previous framework where environmental permits (izin lingkungan) and business licenses (izin usaha) were separate administrative decisions issued by different authorities, enforcement challenges arose when businesses violated environmental requirements. Environmental agencies could revoke environmental permits, but sectoral business licenses often remained valid because they were issued independently by ministries or regional governments under separate legal bases. This created scenarios where businesses continued operating despite environmental permit revocations, defeating the purpose of environmental enforcement.

UU 6/2023's integrated framework resolves this enforcement gap through architectural unification. Environmental approval becomes embedded as a prerequisite condition within business licensing itself—not a separate permit, but rather an essential component of the business license decision. When businesses violate environmental approval conditions (failing to implement approved RKL-RPL mitigation measures, exceeding pollution limits specified in approval decisions, conducting activities outside approved scope), environmental agencies can impose graduated administrative sanctions through the OSS system that directly affect business license validity.

PP 22/2021, which implements UU 32/2009 as amended by UU 6/2023, establishes the administrative sanctions framework. Article 76 of PP 22/2021 specifies graduated sanctions for environmental violations: written warnings, administrative fines, suspension of environmental approval (freezing business license validity), revocation of environmental approval (automatic business license cancellation), and facility closure. These sanctions escalate based on violation severity and business compliance history. The integration mechanism means that environmental approval suspension automatically suspends business licensing—businesses cannot legally operate when their environmental approval is suspended, regardless of business license technical validity. Environmental approval revocation automatically revokes business licensing, eliminating the previous scenario where environmental permits were revoked but business licenses remained valid.

This unified enforcement architecture creates stronger compliance incentives. Businesses recognize that environmental violations directly threaten their operational authorization, not merely their environmental permit status. This alignment of environmental and business licensing consequences strengthens voluntary compliance because businesses cannot avoid environmental obligations by maintaining business licenses while losing environmental permits. The OSS system integration enables real-time enforcement—environmental agencies impose sanctions through the OSS platform, which automatically updates business license status, notifies businesses of sanctions, and prevents transaction processing (permits, certificates, operational authorizations) until violations are corrected.

The streamlined AMDAL procedures and standardized assessment timelines introduced by UU 6/2023 create enhanced regulatory certainty for businesses navigating environmental compliance. The previous framework's indefinite assessment periods created planning uncertainty—businesses submitted AMDAL documents without knowing when assessment commissions would complete reviews, leading to months or years of delays in some cases. The "deemed approved" mechanism introduced by UU 6/2023 (applications deemed approved if Environmental Feasibility Assessment Teams exceed statutory assessment deadlines) creates accountability for environmental agencies and planning certainty for businesses. While specific assessment timelines await implementing regulations, the statutory requirement for defined deadlines represents significant procedural improvement over previous indefinite review periods.

The centralization of AMDAL assessment through Environmental Feasibility Assessment Teams formed by the Central Government addresses regional inconsistencies in AMDAL review quality. Previous regional assessment commissions varied significantly in technical expertise, assessment rigor, and procedural consistency across provinces and districts. Some commissions comprised highly qualified environmental experts conducting thorough reviews, while others lacked specialized expertise and applied inconsistent standards. Centralized teams enable the Central Government to appoint certified experts with specialized technical competence in relevant environmental disciplines (air quality modeling, aquatic ecology, social impact assessment, etc.), improving assessment consistency and technical quality nationwide. This centralization also enables knowledge transfer and capacity building—expert teams develop standardized assessment protocols, evaluation criteria, and decision-making frameworks that improve overall AMDAL quality.

The refinement of public participation scope to focus on directly affected communities (masyarakat terdampak langsung) rather than broadly defined potentially affected communities (masyarakat potensial terdampak) balances procedural efficiency with substantive community engagement. The previous broader participation scope created scenarios where parties without direct connections to proposed activities participated in consultation processes, sometimes raising concerns unrelated to actual environmental impacts or delaying projects through prolonged participation procedures. By focusing participation on communities whose environments, livelihoods, or cultural practices are directly impacted, UU 6/2023 ensures that environmental assessments receive input from genuinely affected stakeholders while preventing non-affected parties from misusing participation mechanisms to obstruct legitimate development.

This refinement does not eliminate public participation—directly affected communities retain meaningful involvement in scoping consultations, draft AMDAL reviews, and written comment opportunities. Environmental agencies must identify directly affected communities through criteria including geographic proximity to activity sites, resource dependencies impacted by proposed activities (water sources, fishing grounds, forest products), and cultural connections to affected areas (traditional territories, sacred sites, customary resource management areas). Communities satisfying these criteria receive formal notification of proposed activities, invitations to participate in scoping consultations, access to draft AMDAL documents for review, and responses explaining how their concerns were addressed in final Environmental Feasibility Decisions. This participatory framework maintains substantive community engagement while improving procedural efficiency.

For businesses, the integrated environmental-business licensing framework under UU 6/2023 creates clear compliance pathways through the OSS system. Businesses access the OSS platform (www.oss.go.id), classify their planned activities using standardized business classification codes (KBLI codes), and determine environmental assessment requirements based on activity type, scale, and location. The OSS system automatically identifies whether activities require AMDAL, UKL-UPL, or SPPL based on ministerial regulations specifying thresholds and criteria. Businesses then upload required environmental assessment documents (AMDAL documents, UKL-UPL forms, or SPPL declarations) through the OSS platform as part of business license applications.

Environmental agencies receive notifications through the OSS system when businesses submit environmental assessment documents, conduct reviews using standardized checklists and evaluation criteria, and issue approval or rejection decisions through the OSS platform. Approval decisions trigger business license issuance by sectoral authorities within the OSS system, enabling businesses to obtain both environmental approval and business licensing through unified digital processes. This integration eliminates the sequential processes previously requiring separate applications to environmental agencies and business licensing authorities, reducing approval timelines from months to weeks in many cases.

Matrix 5.1 below details the enforcement implications of integrated environmental-business licensing, comparing previous enforcement challenges with the unified enforcement architecture under UU 6/2023. Matrix 5.2 outlines practical compliance pathways for businesses navigating environmental approval requirements through the OSS system.

Matrix 5.1: Enforcement Implications of Integrated Environmental-Business Licensing Under UU 6/2023

Matrix 5.2: Practical Compliance Pathways Through OSS System Under UU 6/2023

Regulation Reference

Full Citation:
Undang-Undang Nomor 6 Tahun 2023 tentang Penetapan Peraturan Pemerintah Pengganti Undang-Undang Nomor 2 Tahun 2022 tentang Cipta Kerja Menjadi Undang-Undang

English Translation:
Law Number 6 of 2023 on Establishment of Government Regulation in Lieu of Law Number 2 of 2022 on Job Creation as Law

Short Citation:
UU 6/2023

Amended Regulation:
Undang-Undang Nomor 32 Tahun 2009 tentang Perlindungan dan Pengelolaan Lingkungan Hidup (Law Number 32 of 2009 on Environmental Protection and Management)

Key Environmental Provisions:
Article 42 of UU 6/2023 Lampiran (amendments to UU 32/2009 Pasal 1, 36-43)

Implementing Regulation:
Peraturan Pemerintah Nomor 22 Tahun 2021 tentang Penyelenggaraan Perlindungan dan Pengelolaan Lingkungan Hidup (Government Regulation Number 22 of 2021 on Environmental Protection and Management)

Legal Basis:
UUD 1945 (Pasal 5 ayat (1), Pasal 20, Pasal 22 ayat (2)); PERPPU 2/2022; Putusan Mahkamah Konstitusi Nomor 91/PUU-XVIII/2020

Official Source: https://peraturan.bpk.go.id/Details/246523/uu-no-6-tahun-2023

Related Regulations:
- UU 32/2009 (Environmental Protection and Management Law - as amended)
- PP 22/2021 (Environmental Approval Implementation Regulation)
- OSS System Regulations (Online Single Submission)

Constitutional Court Decision:
Putusan Mahkamah Konstitusi Nomor 91/PUU-XVIII/2020 (declared UU 11/2020 conditionally unconstitutional, leading to PERPPU 2/2022 and subsequent UU 6/2023)

Regulatory Status:
Active (Berlaku) - Effective March 31, 2023

Note on Partial Invalidity:
Constitutional Court Decision No. 39/PUU-XXI/2023 declared certain non-environmental provisions of UU 6/2023 partially invalid, but did not affect the environmental amendments discussed in this analysis.

Legal Analysis by the CRPG Regulatory Framework Team | Analysis Date: November 26, 2025 | Regulation Status: Active (Berlaku)

LEGAL DISCLAIMER: This article is provided for informational and educational purposes only and does not constitute legal advice, legal opinion, or professional consultation. The analysis presented herein is based on the authors' interpretation of UU 6/2023 and related environmental regulations as of the publication date and may contain errors, omissions, or inaccuracies despite reasonable efforts to ensure accuracy. Laws and regulations are subject to amendment, judicial interpretation, and administrative clarification that may affect the applicability or interpretation of the provisions discussed. This article does not create an attorney-client relationship between the authors, the Center for Regulation, Policy and Government (CRPG), and any reader. Readers should not act or refrain from acting based solely on the information contained in this article without seeking appropriate legal counsel from qualified Indonesian legal practitioners licensed to practice environmental law, administrative law, and regulatory compliance. The application of environmental approval requirements under UU 6/2023 depends on specific business contexts including activity classification, location, scale, and sectoral regulations, all of which require case-specific legal analysis and OSS system navigation. Neither the authors nor CRPG assume any liability for actions taken or not taken based on information in this article, nor for any direct, indirect, incidental, consequential, or punitive damages arising from use of or reliance on this material. For specific legal guidance on environmental compliance, AMDAL procedures, business licensing integration, or enforcement matters under UU 6/2023, consult with qualified legal counsel familiar with Indonesian environmental law, the OSS system, and sectoral business licensing requirements.

Article 94 of 100 | REGPRIMA Protocol | Cross-Cutting Framework Series

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