What Energy Conservation Requirements Apply Under PP 33/2023?

Executive Summary

On June 15, 2023, Indonesia enacted Peraturan Pemerintah Nomor 33 Tahun 2023 tentang Konservasi Energi (Government Regulation No. 33 of 2023 on Energy Conservation), replacing the 14-year-old PP 70/2009. This regulation represents a fundamental shift in Indonesia's energy conservation framework by introducing lower consumption thresholds for mandatory energy management, expanding coverage to energy providers (previously exempt), and establishing comprehensive certification requirements for energy managers and auditors.

The regulation implements a dual-track approach to energy conservation: upstream management focuses on preserving energy resources, while downstream management emphasizes energy efficiency improvements across four critical sectors—energy provision, industry, transportation, and buildings. Entities meeting specified consumption thresholds must implement systematic energy management programs, conduct periodic energy audits, appoint certified energy managers, and comply with technology standards favoring domestic components.

PP 33/2023 introduces enhanced enforcement mechanisms through balanced incentives (fiscal benefits, government recognition, financing priority) and disincentives (sanctions, fines, public disclosure of non-compliance) designed to accelerate Indonesia's transition toward Net Zero Emissions by 2060. The regulation was further operationalized through Peraturan Menteri ESDM Nomor 8 Tahun 2025 tentang Manajemen Energi, which provides detailed implementation standards including ISO 50001 alignment and time-bound compliance requirements.

This analysis examines PP 33/2023's regulatory architecture, sector-specific obligations, certification requirements, and enforcement mechanisms to clarify what energy conservation requirements now apply to Indonesian energy stakeholders.

I. Legal Framework and Regulatory Context

1.1 Regulatory Foundation

PP 33/2023 was enacted on June 15, 2023, and published in Lembaran Negara Republik Indonesia Tahun 2023 Nomor 83 and Tambahan Lembaran Negara Republik Indonesia Nomor 6879. The 28-page regulation explicitly revokes PP 70/2009, which had governed energy conservation since 2009 but became inadequate for Indonesia's evolving energy security and climate commitments.

The regulation derives authority from Indonesia's energy legislation framework and responds to national commitments under the Paris Agreement and Indonesia's Enhanced Nationally Determined Contribution (NDC), which targets Net Zero Emissions by 2060. The regulatory shift reflects recognition that previous thresholds were too high to capture significant energy users and that energy providers themselves required conservation obligations.

1.2 Definitional Framework (Pasal 1)

PP 33/2023 Pasal 1 establishes critical definitions that shape the regulation's application:

"Konservasi Energi adalah upaya sistematis, terencana, dan terpadu guna melestarikan sumber daya energi dalam negeri serta meningkatkan efisiensi pemanfaatannya."

(Energy Conservation means systematic, planned, and integrated efforts to preserve domestic energy resources and improve efficiency of their utilization.)

The regulation introduces several new defined terms not present in PP 70/2009, including:

• Konservasi Sumber Daya Energi (Energy Resource Conservation): upstream conservation activities focused on resource preservation
• Efisiensi Energi (Energy Efficiency): ratio of energy output to input in a system or process
• Penghematan Energi (Energy Saving): reduction of energy consumption through behavioral changes and operational adjustments
• Proyek Efisiensi Energi (Energy Efficiency Project): initiatives aimed at reducing energy consumption through technology implementation or process improvement
• Penyediaan Energi (Energy Provision): activities related to energy supply, conversion, transmission, and distribution
• Penyedia Energi (Energy Provider): entities engaged in energy provision activities—a newly regulated category
• Manajemen Energi (Energy Management): systematic approach to improving energy performance including policy, planning, implementation, measurement, monitoring, and review
• Audit Energi Berstandar Investasi (Investment-Grade Energy Audit): comprehensive energy audits meeting standards suitable for investment decision-making

The regulation also modifies existing definitions to broaden scope:

• Pengguna Energi (Energy User): expanded to include entities consuming energy in final form (previously more narrowly defined)
• Peralatan Hemat Energi (Energy-Efficient Equipment): clarified to include appliances, machinery, and devices meeting specified energy performance standards
• Menteri (Minister): clearly designated as the Minister of Energy and Mineral Resources (ESDM)

These definitional changes expand regulatory reach and establish clearer categorization of regulated entities.

1.3 Scope of Regulation (Pasal 2-5)

Pasal 2 establishes that energy conservation applies across all energy management stages:

"Konservasi Energi dilaksanakan pada seluruh tahap pengelolaan Energi."

(Energy Conservation is implemented at all stages of Energy management.)

This comprehensive scope includes both upstream (hulu) and downstream (hilir) energy sectors.

Pasal 3 specifies upstream management objectives:

"Pengelolaan sisi hulu bertujuan untuk melestarikan Sumber Daya Energi."

(Upstream management aims to preserve Energy Resources.)

Upstream conservation addresses resource extraction, production, and primary conversion activities according to sector-specific regulations governing oil and gas, coal, geothermal, and other energy resources.

Pasal 4 defines downstream management focus:

"Pengelolaan sisi hilir bertujuan untuk meningkatkan Efisiensi Energi."

(Downstream management aims to increase Energy Efficiency.)

Downstream conservation encompasses energy provision activities and energy utilization across four sectors explicitly regulated by PP 33/2023:

1. Transportasi (Transportation) - Pasal 31
2. Industri (Industry) - Pasal 32
3. Rumah Tangga (Households) - Pasal 33
4. Bangunan Gedung (Buildings) - Pasal 34

Pasal 5 outlines the regulation's substantive coverage:

1. Pelaksanaan Konservasi Energi (Implementation of Energy Conservation)
2. Kemudahan, insentif, dan disinsentif (Facilitation, incentives, and disincentives)
3. Data dan informasi (Data and information)
4. Pembinaan dan pengawasan (Guidance and supervision)

This four-pillar structure provides the regulatory framework analyzed in subsequent sections.

II. Energy Conservation Implementation Requirements

2.1 Energy Conservation Programs (Pasal 6-15)

Pasal 6 establishes the core implementation mechanism:

"Konservasi Energi dilaksanakan melalui suatu Program Konservasi Energi yang dilaksanakan oleh Penyedia Energi, Pengguna Sumber Energi dan/atau Pengguna Energi."

(Energy Conservation is implemented through an Energy Conservation Program conducted by Energy Providers, Energy Source Users, and/or Energy Users.)

This provision creates mandatory obligations for three categories of regulated entities based on consumption thresholds discussed in Section III below.

Energy conservation programs must include several mandatory components established in subsequent articles:

2.1.1 Energy Management (Manajemen Energi)

Pasal 7 requires entities meeting threshold criteria to implement systematic energy management comprising:

• Penunjukan Manajer Energi (Appointment of Energy Manager) - Energy managers must hold valid competency certificates obtained through standardized testing under Indonesia's competency assessment framework. The Standar Kompetensi Kerja Nasional Indonesia (SKKNI) 2023-033 establishes competency standards for energy managers.
• Penyusunan Program Efisiensi Energi (Development of Energy Efficiency Programs) - Organizations must prepare documented energy efficiency programs with measurable targets, timelines, and resource allocations.
• Pelaksanaan Audit Energi Secara Berkala (Periodic Energy Audit Implementation) - Regular energy audits must be conducted by certified internal or external energy auditors to identify conservation opportunities and measure performance.
• Pelaksanaan Rekomendasi Hasil Audit Energi (Implementation of Energy Audit Recommendations) - A critical new requirement under PP 33/2023 mandates that entities must implement audit recommendations within three years of audit completion, creating time-sensitive compliance obligations absent from PP 70/2009.

2.1.2 Technology Implementation (Pasal 13)

The regulation requires application of energy-efficient technologies, with a notable domestic content provision:

"Penerapan teknologi efisiensi Energi harus menerapkan tingkat komponen dalam negeri."

(Application of energy efficiency technology must apply domestic component levels.)

This provision aligns energy conservation with Indonesia's industrial policy objectives by favoring domestically-produced energy-efficient equipment and technologies, subject to technical feasibility and availability.

2.1.3 Energy Services Industry (Pasal 17-22)

PP 33/2023 establishes a framework for commercial energy conservation services (usaha jasa Konservasi Energi) comprising five categories:

1. Pelaksanaan Audit Energi Berstandar Investasi (Pasal 18) - Investment-grade energy audits meeting standards for financing decisions
2. Pembiayaan Proyek Efisiensi Energi (Pasal 19) - Energy efficiency project financing, including Energy Service Company (ESCO) models
3. Pelaksanaan pekerjaan instalasi dan/atau pembangunan serta monitoring dan pengawasan Proyek Efisiensi Energi (Pasal 20) - Installation, construction, monitoring, and supervision of efficiency projects
4. Pengoperasian, pemeliharaan, dan perbaikan instalasi Energi (Pasal 21) - Operation, maintenance, and repair of energy installations
5. Pengukuran dan verifikasi kinerja Energi (Pasal 22) - Measurement and verification of energy performance

This framework professionalizes energy conservation services and creates market mechanisms to support compliance, particularly for entities lacking in-house expertise.

2.2 Government Implementation Requirements (Pasal 37-38)

PP 33/2023 extends conservation obligations to government entities:

Pasal 37 mandates that both central government (Pemerintah) and regional governments (Pemerintah Daerah) must implement energy conservation in their operations, including government buildings, vehicle fleets, and energy procurement.

Pasal 38 requires budget allocation for conservation activities:

"Pemerintah dan Pemerintah Daerah mengalokasikan anggaran untuk pelaksanaan Konservasi Energi."

(The Government and Regional Governments allocate budgets for implementing Energy Conservation.)

This fiscal commitment ensures public sector leadership in conservation efforts and provides resources for capacity building, technology deployment, and monitoring systems.

2.3 Public Participation (Pasal 45)

The regulation recognizes community roles in energy conservation:

"Masyarakat berperan dalam pelaksanaan Konservasi Energi."

(The community plays a role in implementing Energy Conservation.)

Public participation mechanisms include:

• Using energy-efficient technologies in households
• Reducing household energy consumption through behavioral changes
• Utilizing mass transportation systems
• Building energy-saving awareness in workplaces and residential areas
• Participating in government conservation campaigns and programs

This provision connects institutional requirements with societal behavior change necessary for achieving national energy intensity reduction targets.

III. Sector-Specific Obligations and Thresholds

3.1 Threshold-Based Mandatory Compliance

PP 33/2023 establishes consumption-based thresholds measured in Ton Oil Equivalent (TOE) or Ton Setara Minyak per year. These thresholds significantly differ from PP 70/2009, creating broader regulatory coverage:

These lower thresholds capture significantly more entities within mandatory compliance frameworks. For example, the building sector threshold reduction from 1,500 to 500 TOE encompasses commercial buildings, hotels, hospitals, and educational institutions previously exempt.

3.2 Energy Provider Obligations (Penyedia Energi)

Energy providers consuming ≥6,000 TOE annually face comprehensive conservation requirements:

Mandatory Energy Management System: Energy providers must establish documented energy management systems aligned with international standards, particularly ISO 50001 (Energy Management Systems) as specified in implementing regulations.

Energy Performance Monitoring: Continuous monitoring of energy consumption patterns, intensity metrics, and efficiency improvements across provision activities (generation, conversion, transmission, distribution).

Technology Standards: Application of best available technologies economically achievable (BATEA) in energy provision infrastructure, subject to technical and economic feasibility assessments.

Reporting Requirements: Regular reporting of energy consumption, conservation measures implemented, energy intensity trends, and savings achieved to the Ministry of Energy and Mineral Resources (ESDM).

The inclusion of energy providers represents PP 33/2023's most significant expansion compared to PP 70/2009, recognizing that supply-side efficiency improvements yield substantial national energy savings. For context, Indonesia's electricity system technical losses averaged approximately 8-9% in recent years; reducing these losses through provider-side conservation contributes materially to national energy security.

3.3 Industrial Sector Obligations (Pasal 32)

Industrial facilities consuming ≥4,000 TOE annually must implement:

Process Optimization: Systematic analysis and optimization of energy-intensive industrial processes, including heat recovery, waste energy utilization, and process integration.

Equipment Efficiency Standards: Replacement or retrofit of energy-consuming equipment (motors, boilers, compressors, furnaces, chillers) with high-efficiency alternatives meeting specified performance standards.

Energy Monitoring Systems: Installation of sub-metering and monitoring systems enabling real-time tracking of energy consumption by process, production line, or department.

Production Efficiency Metrics: Establishment of energy intensity indicators (energy consumption per unit of production) with baseline measurements and improvement targets.

The 4,000 TOE threshold captures medium and large industrial facilities across sectors including cement, steel, petrochemicals, pulp and paper, textiles, food processing, and manufacturing. According to Ministry of Industry data, the industrial sector accounts for approximately 36% of Indonesia's final energy consumption, making industrial conservation critical to national energy intensity reduction.

3.4 Transportation Sector Obligations (Pasal 31)

Transportation sector entities consuming ≥4,000 TOE annually face specific conservation requirements:

Fleet Efficiency Management: Systematic fleet management programs including fuel-efficient vehicle procurement, maintenance optimization, route planning, and driver training.

Technology Adoption: Progressive adoption of energy-efficient transportation technologies including hybrid vehicles, electric vehicles (EVs), compressed natural gas (CNG) vehicles, and advanced logistics systems.

Fuel Management Systems: Implementation of fuel monitoring, consumption tracking, and efficiency measurement systems across vehicle fleets.

Modal Shift Initiatives: For applicable entities, programs encouraging shift from private vehicles to public transportation, mass transit systems, or non-motorized transport.

This category primarily affects:
- Large transportation and logistics companies
- Public transportation operators (bus rapid transit, rail systems)
- Aviation and maritime operators meeting threshold criteria
- Mining and plantation companies operating significant vehicle fleets
- Government transportation agencies

The threshold reduction from 6,000 to 4,000 TOE expands coverage to mid-sized logistics firms and regional transportation operators previously exempt.

3.5 Building Sector Obligations (Pasal 34)

Buildings consuming ≥500 TOE annually must comply with conservation requirements:

Building Energy Management Systems (BEMS): Implementation of automated or semi-automated systems for monitoring and controlling building energy consumption, particularly for HVAC (heating, ventilation, air conditioning), lighting, and mechanical systems.

Energy-Efficient Equipment Standards: Compliance with minimum energy performance standards (MEPS) for building equipment including air conditioners, lighting systems, elevators, pumps, and other installations.

Building Envelope Performance: Maintenance and periodic assessment of building envelope performance (insulation, windows, shading) to minimize heating/cooling energy requirements.

Occupant Behavior Programs: Initiatives to promote energy-conscious behavior among building occupants, including awareness campaigns, visual feedback systems, and operational guidelines.

Green Building Certification: While not explicitly mandatory under PP 33/2023, the regulation encourages pursuit of green building certifications (EDGE, LEED, Green Ship, etc.) that systematize energy performance improvements.

The 500 TOE threshold encompasses:
- Commercial office buildings (typically >5,000-10,000 m²)
- Shopping malls and retail centers
- Hotels (typically >100-150 rooms)
- Hospitals and healthcare facilities
- Educational institutions (universities, large schools)
- Government buildings meeting size criteria
- Industrial facilities' administrative buildings

For reference, a typical 10,000 m² office building in Jakarta with standard HVAC and equipment might consume 200-400 TOE annually, meaning buildings significantly above this size or with energy-intensive operations (data centers, laboratories, hospitals) generally exceed the 500 TOE threshold.

3.6 Household Sector (Pasal 33)

While households are not subject to mandatory threshold-based compliance, PP 33/2023 Pasal 33 encourages voluntary conservation through:

• Procurement and use of energy-efficient household appliances (refrigerators, air conditioners, lighting, washing machines) meeting energy labels and standards
• Behavioral energy-saving practices (turning off unused equipment, optimizing air conditioner settings, using natural lighting)
• Participation in government energy efficiency programs and subsidies
• Adoption of distributed renewable energy (rooftop solar PV)

The regulation establishes a framework for household energy efficiency standards, labeling schemes, and public awareness campaigns implemented through ministerial regulations and technical standards.

IV. Certification, Audit, and Competency Requirements

4.1 Energy Manager Certification

PP 33/2023 mandates certified energy managers for all entities subject to mandatory energy management:

Competency Certification Requirement: Energy managers must possess valid competency certificates (sertifikat kompetensi) issued by accredited Professional Certification Bodies (Lembaga Sertifikasi Profesi/LSP) under Indonesia's National Professional Certification Board (Badan Nasional Sertifikasi Profesi/BNSP).

Competency Standard: SKKNI 2023-033 establishes national competency standards for energy managers, covering:
- Energy management system design and implementation
- Energy performance measurement and monitoring
- Energy audit interpretation and action planning
- Energy efficiency technology evaluation
- Regulatory compliance management
- Team coordination and stakeholder engagement

Professional Responsibilities: Certified energy managers bear responsibility for:
- Developing organizational energy policies and objectives
- Preparing annual energy management plans and budgets
- Coordinating periodic energy audits
- Implementing audit recommendations and tracking progress
- Reporting energy performance to management and regulators
- Ensuring compliance with PP 33/2023 and implementing regulations

Continuing Education: Certification maintenance requires periodic professional development and recertification according to BNSP standards, ensuring energy managers remain current with evolving technologies, regulations, and best practices.

4.2 Energy Audit Requirements

Audit Frequency and Scope: Entities subject to mandatory energy management must conduct periodic energy audits by certified internal or external energy auditors. While PP 33/2023 does not specify exact frequencies, implementing regulations typically require audits at 2-3 year intervals depending on sector and consumption levels.

Auditor Certification: Energy auditors must hold valid competency certificates from accredited LSPs. Auditor certification programs assess competencies including:
- Energy systems analysis and measurement
- Baseline establishment and performance benchmarking
- Energy balance calculations and thermal analysis
- Energy conservation opportunity identification
- Economic evaluation and investment analysis (for investment-grade audits)
- Audit reporting and recommendations

Audit Deliverables: Energy audits must produce documented reports including:
- Current energy consumption baseline and intensity metrics
- Energy flow analysis and major consumption sources
- Identified energy conservation opportunities (ECOs)
- Technical feasibility and economic analysis of ECOs
- Prioritized recommendations with implementation timelines
- Projected energy savings and payback periods

Investment-Grade Audits (Pasal 18): For financing energy efficiency projects, audits must meet investment-grade standards (Audit Energi Berstandar Investasi) providing sufficient technical and financial detail to support lending decisions or Energy Service Company (ESCO) contracts.

4.3 Three-Year Implementation Requirement

A critical enforcement mechanism introduced in PP 33/2023 mandates:

Time-Bound Compliance: Penyedia Energi, Pengguna Sumber Energi, and Pengguna Energi must implement energy audit recommendations within three years of audit completion.

This provision creates enforceable deadlines absent from PP 70/2009, where entities could indefinitely delay implementing audit findings. The three-year window recognizes that capital-intensive efficiency projects require budgeting, procurement, and installation timelines while preventing indefinite deferrals.

Compliance Verification: Subsequent audits verify implementation of prior recommendations, creating accountability loops. Entities failing to implement recommendations within prescribed timelines face potential disincentives (discussed in Section V).

Flexibility Mechanisms: While the three-year requirement is mandatory, implementing regulations may provide limited exceptions for:
- Projects rendered technically or economically infeasible due to changed circumstances
- Projects requiring longer technical implementation (e.g., major industrial retrofits)
- Projects postponed due to demonstrated force majeure conditions

Such exceptions require documented justification submitted to regulatory authorities.

V. Incentives, Disincentives, and Enforcement

5.1 Incentive Framework

PP 33/2023 establishes a comprehensive incentive system to encourage energy conservation compliance and exceed minimum requirements:

5.1.1 Government Recognition and Awards

Entities demonstrating exceptional energy intensity reductions or conservation achievements receive formal recognition through:
- Ministry of ESDM energy conservation awards
- Public acknowledgment in government communications and events
- Inclusion in best practice case studies and government publications

Such recognition provides reputational benefits, competitive advantages in government procurement, and stakeholder credibility.

5.1.2 Fiscal Incentives

The regulation authorizes various fiscal incentives including:

Tax Benefits: Potential corporate income tax reductions, tax holidays, or accelerated depreciation for energy efficiency investments, subject to Ministry of Finance regulations and coordination with tax authorities.

Import Duty Relief: Reduction or exemption of import duties (bea masuk) for energy-efficient equipment and technologies not available domestically or where domestic products do not meet technical requirements. This addresses the domestic content requirement in Pasal 13 while recognizing technological gaps.

Value-Added Tax (VAT) Treatment: Possible VAT exemptions or reductions for energy efficiency equipment and services, reducing upfront investment costs.

Implementation of specific fiscal incentives requires coordination across ministries (ESDM, Finance, Industry, Trade) through implementing regulations and ministerial decrees.

5.1.3 Financing Access and Priority

Green Financing Priority: Entities with strong energy management systems and demonstrated conservation achievements gain priority access to:
- Government-supported green financing programs
- Development bank lending facilities (e.g., PT SMI, regional development banks)
- International climate finance mechanisms
- Concessional loan programs for energy efficiency

Risk Mitigation: Financial institutions increasingly incorporate energy performance into credit risk assessments. Certified energy management systems (particularly ISO 50001) and compliance with PP 33/2023 improve creditworthiness and potentially reduce borrowing costs.

5.1.4 Technical Support Programs

Government provides preferential access to:
- Pilot programs for emerging energy efficiency technologies
- Capacity building and training programs
- Technical assistance for energy management system implementation
- Energy efficiency technology demonstration projects
- Knowledge sharing platforms and peer learning networks

5.2 Disincentive and Sanction Framework

PP 33/2023 introduces disincentives for non-compliance:

5.2.1 Administrative Sanctions

Entities failing to comply with mandatory requirements face administrative measures including:

Written Warnings: Initial non-compliance triggers formal written warnings specifying deficiencies and required corrective actions with timelines.

Public Disclosure: Publication of non-compliant entities on government websites or public communications, creating reputational risks and stakeholder pressure.

Operational Restrictions: Potential restrictions on business licenses, permits, or approvals for non-compliant entities, particularly for expansions or new projects.

5.2.2 Financial Penalties

While PP 33/2023 establishes the framework for financial disincentives, specific penalty amounts and calculation methods are detailed in implementing regulations (particularly Permen ESDM 8/2025). Penalties may be structured as:
- Fixed fines for specific violations
- Per-TOE penalties calculated based on excess consumption or efficiency shortfalls
- Escalating penalties for repeated or continuing violations

5.2.3 Subsidy and Incentive Exclusion

Non-compliant entities become ineligible for:
- Government energy subsidies or procurement preferences
- Incentive programs described in Section 5.1
- Participation in government-supported energy efficiency initiatives
- Public recognition or certification programs

5.2.4 Enforcement Escalation

The regulation establishes escalating enforcement responses:
- First-time minor violations: Warnings and technical assistance to achieve compliance
- Repeated or significant violations: Administrative sanctions and penalties
- Willful or egregious non-compliance: Operational restrictions and maximum financial penalties

Enforcement authority rests primarily with the Ministry of ESDM, with coordination mechanisms for sector-specific oversight (Ministry of Industry for industrial facilities, Ministry of Transportation for transport operators, etc.).

5.3 Monitoring and Supervision (Pembinaan dan Pengawasan)

Regulatory Oversight: The Ministry of ESDM conducts ongoing monitoring of regulated entities through:
- Energy consumption data reporting and verification
- Periodic compliance audits and inspections
- Review of energy management documentation
- Verification of energy manager and auditor certifications
- Assessment of audit recommendation implementation

Data and Information Systems: PP 33/2023 mandates government agencies, state-owned enterprises, and regulated entities to provide access to, distribute, and exchange energy conservation data. This creates transparency and enables evidence-based policy adjustments.

Coordination Mechanisms: Inter-agency coordination ensures consistent enforcement across sectors, particularly for entities regulated by multiple ministries (e.g., industrial facilities subject to both ESDM and industrial sector regulations).

VI. Implementation Through Permen ESDM 8/2025

6.1 Regulatory Development

To operationalize PP 33/2023, the Ministry of ESDM issued Peraturan Menteri ESDM Nomor 8 Tahun 2025 tentang Manajemen Energi (Ministerial Regulation on Energy Management) implementing provisions from Pasal 12, Pasal 49, Pasal 53, and Pasal 61 of PP 33/2023.

Permen ESDM 8/2025 provides detailed technical standards, procedures, and compliance requirements that elaborate the framework established by PP 33/2023.

6.2 ISO 50001 Alignment

Permen ESDM 8/2025 explicitly aligns Indonesia's energy management requirements with ISO 50001:2018 (Energy Management Systems - Requirements with Guidance for Use), the international standard for organizational energy management.

Benefits of ISO 50001 Certification:

Simplified Compliance: Entities certified to ISO 50001 demonstrate systematic energy management meeting or exceeding PP 33/2023 requirements, streamlining regulatory compliance verification.

Enhanced Incentive Access: ISO 50001 certification strengthens eligibility for government incentives, green financing, and procurement preferences.

International Recognition: ISO 50001 provides globally-recognized demonstration of energy management capability, benefiting entities engaged in international trade or supply chains with sustainability requirements.

Operational Benefits: Beyond regulatory compliance, ISO 50001 implementation yields:
- Sustained energy cost reductions
- Improved operational efficiency
- Better resource allocation through data-driven decisions
- Enhanced organizational culture around energy stewardship
- Risk mitigation related to energy price volatility and supply security

6.3 Enhanced Compliance Requirements

Permen ESDM 8/2025 strengthens the compliance framework compared to previous regulations (particularly Permen ESDM 14/2012, the prior implementing regulation):

Explicit Chapters: The ministerial regulation includes dedicated chapters on:
- Financing mechanisms for energy efficiency projects
- Competency certification requirements and procedures
- Incentive and disincentif provisions with implementation details
- Supervision and enforcement procedures

Strengthened Enforcement Regime: Compared to 2012 regulations, Permen ESDM 8/2025 establishes more robust monitoring, verification, and penalty frameworks, signaling government commitment to enforcement rather than voluntary compliance.

Technical Standards: The regulation incorporates updated technical standards for:
- Energy performance measurement and verification (M&V protocols)
- Baseline establishment and energy intensity calculations
- Energy management system documentation requirements
- Audit methodologies and reporting formats

6.4 Strategic Objectives

Permen ESDM 8/2025 explicitly connects energy management requirements to national strategic goals:

National Energy Intensity Reduction: Indonesia targets progressive reduction in energy intensity (energy consumption per unit of GDP), contributing to economic competitiveness and resource security.

Greenhouse Gas Emissions Reduction: Energy conservation directly reduces fossil fuel consumption and associated GHG emissions, supporting Indonesia's Enhanced NDC commitments under the Paris Agreement.

Net Zero Emissions 2060: Energy efficiency improvements across sectors constitute a foundational pillar of Indonesia's pathway to Net Zero Emissions by 2060, complementing renewable energy deployment and other decarbonization strategies.

Energy Security: Reducing energy demand through conservation lessens dependence on imported fuels, strengthens energy self-sufficiency, and enhances resilience against global energy market volatility.

VII. Comparative Analysis: PP 33/2023 vs PP 70/2009

7.1 Key Regulatory Changes

7.2 Increased Regulatory Coverage

The threshold reductions substantially increase the number of regulated entities:

Industrial Sector: The reduction from 6,000 to 4,000 TOE potentially captures an additional 30-40% of industrial facilities, including medium-sized manufacturers previously exempt.

Building Sector: The reduction from 1,500 to 500 TOE (67% decrease) dramatically expands coverage to include typical large office buildings (>10,000 m²), medium hotels (100-200 rooms), and educational/healthcare facilities, potentially tripling the number of regulated buildings.

Transportation Sector: The 4,000 TOE threshold brings regional logistics companies, provincial transportation operators, and medium-sized fleet operators into mandatory compliance.

Energy Providers: Previously entirely exempt, energy providers now face the highest threshold (6,000 TOE) but comprehensive requirements recognizing their critical role in national energy efficiency.

7.3 Enhanced Accountability Mechanisms

PP 33/2023 introduces several accountability improvements:

Time-Bound Implementation: The three-year requirement for implementing audit recommendations creates specific, verifiable compliance obligations replacing the previous open-ended framework.

Certification Standards: Mandatory BNSP-accredited certification for energy managers and auditors professionalizes the field and ensures minimum competency levels.

Public Disclosure: Authorization to publicly disclose non-compliant entities leverages reputational mechanisms for compliance.

Balanced Enforcement: The combination of expanded incentives and clear disincentives creates both positive motivation and consequences for non-compliance.

VIII. Practical Compliance Guidance

8.1 Determining Applicability

Step 1: Calculate Annual Energy Consumption

Entities must calculate total energy consumption in TOE (Ton Oil Equivalent) or Ton Setara Minyak across all energy forms:

Example Conversion Factors:
- Electricity: 1 MWh = 0.086 TOE
- Natural Gas: 1,000 m³ = 0.90 TOE
- Diesel: 1 kiloliter = 0.86 TOE
- Coal: 1 ton = 0.429-0.714 TOE (depending on calorific value)
- LPG: 1 ton = 1.10 TOE

Organizations should aggregate consumption across all facilities and energy sources annually.

Step 2: Identify Applicable Category

Based on total TOE and primary activity:
- ≥6,000 TOE in energy provision activities → Energy Provider obligations
- ≥4,000 TOE in industrial activities → Industrial obligations
- ≥4,000 TOE in transportation activities → Transportation obligations
- ≥500 TOE in building operations → Building obligations

Step 3: Assess Current Compliance Status

Evaluate existing practices against mandatory requirements:
- Is a certified energy manager appointed?
- Have energy audits been conducted within required timeframes?
- Are audit recommendations documented and implemented?
- Do energy management systems meet requirements?
- Are required reports submitted to authorities?

8.2 Compliance Roadmap for New Entrants

Phase 1: Immediate Actions (Months 1-3)

1. Formal Energy Consumption Calculation: Document annual energy consumption in TOE with supporting data
2. Regulatory Notification: If exceeding thresholds, notify relevant authorities (typically provincial ESDM office)
3. Appoint Interim Energy Manager: Designate responsible personnel (certification to follow)
4. Baseline Assessment: Conduct preliminary energy assessment to understand consumption patterns

Phase 2: System Development (Months 3-12)

1. Energy Manager Certification: Enroll designated personnel in LSP certification programs for energy managers
2. Initial Energy Audit: Engage certified auditors for comprehensive baseline audit
3. Energy Management System Design: Develop documented energy management system (policies, procedures, responsibilities)
4. Monitoring Infrastructure: Install sub-metering and monitoring systems for energy tracking
5. Staff Training: Conduct awareness and training programs for relevant personnel

Phase 3: Implementation (Months 12-24)

1. Implement Quick Wins: Execute low-cost, high-return energy conservation measures identified in audit
2. Develop Capital Projects: Prepare business cases and budgets for capital-intensive efficiency projects
3. Establish Reporting Systems: Implement internal energy performance reporting and external regulatory reporting
4. Pursue ISO 50001 (Optional but recommended): Begin ISO 50001 certification process for enhanced compliance and benefits

Phase 4: Continuous Improvement (Ongoing)

1. Implement Audit Recommendations: Execute audit recommendations within three-year timeline
2. Periodic Re-audits: Conduct subsequent audits at required intervals (typically 2-3 years)
3. Performance Monitoring: Track energy intensity, consumption trends, and savings achieved
4. Technology Updates: Evaluate and deploy emerging energy-efficient technologies
5. Certification Maintenance: Maintain energy manager/auditor certifications and ISO 50001 if certified

8.3 Common Compliance Challenges and Solutions

Challenge 1: Energy Manager Certification Availability

Issue: Limited availability of accredited LSP certification programs, particularly outside major cities.

Solutions:
- Utilize online/remote certification programs where available
- Coordinate with industry associations for group training and certification
- Engage consultants or service providers for interim support while developing internal capacity
- Plan certification timelines well in advance recognizing potential waiting periods

Challenge 2: Audit Cost and Resource Requirements

Issue: Investment-grade energy audits can be expensive, particularly for smaller entities near thresholds.

Solutions:
- Explore government technical assistance programs that may subsidize audits
- Develop internal audit capacity for preliminary assessments, using external certified auditors for compliance audits
- Consider shared auditor costs for multi-facility organizations
- Prioritize audits for highest consumption facilities first

Challenge 3: Implementing Capital-Intensive Recommendations

Issue: Audit recommendations may include equipment replacements or retrofits requiring significant capital investment.

Solutions:
- Prioritize recommendations by payback period, implementing quick wins first
- Utilize Energy Service Company (ESCO) models where ESCOs finance projects through energy savings
- Access green financing programs with favorable terms for energy efficiency
- Phase implementations across the three-year window, coordinating with capital budget cycles
- Document technical or economic infeasibility for recommendations that cannot be implemented

Challenge 4: Data Collection and Monitoring

Issue: Many facilities lack sub-metering or monitoring systems for granular energy consumption tracking.

Solutions:
- Implement progressive metering installation, prioritizing major energy consumers
- Utilize manual data collection systems initially while developing automated systems
- Engage energy management software platforms for data aggregation and analysis
- Leverage IoT and smart metering technologies for cost-effective monitoring

Challenge 5: Maintaining Compliance Over Time

Issue: Initial compliance efforts may deteriorate without sustained management attention.

Solutions:
- Integrate energy performance into organizational KPIs and management review processes
- Establish energy committees or working groups with cross-functional participation
- Pursue ISO 50001 certification providing systematic continuous improvement framework
- Conduct internal audits and management reviews at regular intervals
- Maintain organizational commitment through visible leadership support and resource allocation

8.4 Leveraging Compliance for Competitive Advantage

Organizations should view PP 33/2023 compliance not merely as regulatory burden but as strategic opportunity:

Cost Reduction: Energy efficiency improvements directly reduce operating costs, improving competitiveness and profitability. Average industrial energy costs constitute 10-30% of production costs; systematic management can yield 15-30% energy savings.

Sustainability Credentials: Demonstrated energy management enhances corporate sustainability profiles, increasingly valued by:
- Investors and financial institutions incorporating ESG (Environmental, Social, Governance) criteria
- Customers with sustainability procurement requirements
- Employees and talent attracted to responsible employers
- Communities and stakeholders concerned with environmental stewardship

Operational Excellence: Energy management systems drive broader operational improvements including waste reduction, process optimization, and data-driven decision-making transferable across organizational functions.

Regulatory Anticipation: Proactive compliance with PP 33/2023 positions organizations advantageously for anticipated future regulations including carbon pricing, emissions reporting, and climate disclosure requirements.

Market Differentiation: Energy efficiency achievements provide marketing differentiation, particularly in sectors where sustainability increasingly influences customer choices and brand value.

IX. Sector-Specific Implementation Considerations

9.1 Industrial Sector

Energy-Intensive Industries: Sectors like cement, steel, petrochemicals, pulp and paper face particular focus given high energy consumption. These industries should:
- Benchmark performance against international best practices
- Evaluate emerging technologies (waste heat recovery, process integration, advanced controls)
- Consider combined heat and power (CHP) opportunities
- Explore industrial symbiosis where waste energy from one process serves another

Manufacturing: Discrete manufacturing facilities (automotive, electronics, machinery) should focus on:
- Compressed air system optimization (often 20-30% energy waste)
- Motor system efficiency (variable speed drives, rightsizing)
- Lighting retrofits (LED conversion)
- HVAC optimization in manufacturing and office areas

Small and Medium Enterprises (SMEs): While many SMEs fall below thresholds, larger SMEs approaching 4,000 TOE should proactively prepare for compliance and leverage efficiency improvements for cost competitiveness.

9.2 Building Sector

Commercial Buildings: Office buildings, retail centers, and mixed-use developments should prioritize:
- Building Management System (BMS) optimization
- HVAC system efficiency (chillers, air handling units, controls)
- Lighting systems (LED, occupancy sensors, daylight harvesting)
- Envelope improvements (window films, insulation, shading)
- Tenant engagement programs for behavioral change

Hotels: Hospitality facilities face unique challenges balancing guest comfort with efficiency:
- Guestroom energy management systems (occupancy-based controls)
- Kitchen and laundry equipment efficiency
- Swimming pool and spa heating optimization
- Renewable energy integration (solar water heating, rooftop PV)

Hospitals: Healthcare facilities require 24/7 operations with stringent environmental controls:
- Medical equipment energy efficiency where compatible with clinical requirements
- Specialized HVAC requirements (operating theaters, isolation rooms)
- Backup power systems and emergency preparedness
- Balancing energy efficiency with patient safety and care quality

Educational Institutions: Universities and large schools should:
- Integrate energy conservation into facilities management
- Leverage energy management as educational opportunity
- Pursue campus-wide energy performance contracting
- Engage students and faculty in conservation initiatives

9.3 Transportation Sector

Logistics and Freight: Companies operating truck fleets should focus on:
- Fleet modernization with fuel-efficient vehicles
- Driver training programs for eco-driving techniques
- Route optimization and logistics efficiency
- Consideration of alternative fuels (CNG, LNG, electric vehicles for appropriate applications)
- Aerodynamic improvements and tire management

Public Transportation: Urban transit operators should:
- Transition to energy-efficient bus fleets (hybrid, electric, CNG)
- Optimize route scheduling and vehicle utilization
- Implement fuel management and monitoring systems
- Coordinate with urban planning for transit-oriented development reducing overall transportation energy demand

Aviation and Maritime: Operators meeting thresholds should:
- Optimize operational procedures (continuous descent approaches, speed optimization)
- Invest in fleet modernization with more efficient aircraft/vessels
- Improve ground operations efficiency (ground power units, towing)
- Explore alternative fuels and propulsion technologies as they mature

Corporate Fleets: Large organizations operating vehicle fleets for employee transportation or operations should:
- Implement fleet right-sizing and utilization optimization
- Establish vehicle procurement standards favoring efficiency
- Promote carpooling, shuttle services, and remote work where feasible
- Consider electric vehicle adoption for appropriate duty cycles

9.4 Energy Providers

Electricity Generation: Power producers should focus on:
- Improving generation efficiency (heat rate improvements, capacity factor optimization)
- Reducing auxiliary power consumption at generating stations
- Optimizing maintenance scheduling to minimize efficiency degradation
- Transitioning generation mix toward higher-efficiency technologies

Transmission and Distribution: Grid operators should prioritize:
- Technical loss reduction through infrastructure upgrades (conductor replacement, transformer efficiency)
- Commercial loss reduction (metering accuracy, theft prevention)
- Reactive power management and voltage optimization
- Grid modernization supporting distributed generation and demand response

Oil and Gas: Upstream and midstream operators should address:
- Flare reduction and gas recovery
- Energy efficiency in processing facilities
- Pipeline compression efficiency
- Field operations optimization

Renewable Energy: While generally efficient, renewable energy providers should:
- Optimize operations and maintenance reducing downtime
- Improve auxiliary power consumption (especially for solar PV inverters, wind turbine controls)
- Enhance forecasting and grid integration reducing curtailment

X. Future Regulatory Developments and Trends

10.1 Anticipated Regulatory Evolution

Sector-Specific Technical Standards: Expect development of detailed technical standards for energy-intensive equipment and processes, potentially including:
- Minimum Energy Performance Standards (MEPS) for industrial equipment (motors, boilers, compressors)
- Building energy codes with prescriptive or performance-based requirements
- Vehicle fuel economy standards for commercial fleets
- Energy efficiency requirements for public procurement

Emissions Integration: Progressive integration between energy conservation regulations and emissions frameworks, particularly:
- Linking energy intensity improvements with GHG emission reduction targets
- Coordination with potential carbon pricing or cap-and-trade mechanisms
- Alignment with climate disclosure requirements (e.g., following Task Force on Climate-related Financial Disclosures - TCFD)

Digital Integration: Leveraging digital technologies for monitoring and compliance:
- Online energy consumption reporting platforms
- Automated compliance verification systems
- Digital energy management platforms
- IoT and smart metering for real-time monitoring

Threshold Adjustments: Potential future reductions in consumption thresholds to expand coverage as national energy intensity reduction targets progress and as capacity for compliance grows.

10.2 International Alignment

Indonesia's energy conservation framework increasingly aligns with international standards and practices:

ISO 50001 Adoption: Growing recognition of ISO 50001 as global standard for energy management, with PP 33/2023 implementation facilitating broader certification.

Best Practice Exchange: Participation in international energy efficiency forums (ASEAN Energy Cooperation, Asia-Pacific Economic Cooperation, International Energy Agency) informing regulatory evolution.

Trade Considerations: As international trade increasingly incorporates sustainability criteria (carbon border adjustments, supply chain due diligence), Indonesian energy conservation compliance may facilitate market access and competitiveness.

Climate Finance Access: Demonstrated energy conservation policies and implementation strengthen Indonesia's access to international climate finance for energy efficiency projects and programs.

10.3 Technology Trends Influencing Compliance

Artificial Intelligence and Machine Learning: AI-driven energy management systems optimizing complex operations in real-time, particularly for industrial processes and large buildings.

Internet of Things (IoT): Proliferation of low-cost sensors enabling granular energy monitoring and sub-metering previously cost-prohibitive.

Blockchain for Energy Tracking: Potential applications of blockchain for transparent, verifiable energy consumption and savings tracking, particularly for carbon credit or renewable energy certificate systems.

Electric Vehicles: Expanding EV adoption requiring integration with building and grid energy management, creating both challenges and opportunities for conservation.

Distributed Energy Resources: Growth of rooftop solar, battery storage, and microgrids changing building and facility energy profiles and creating new conservation opportunities.

Advanced Materials: Development of high-efficiency equipment, improved insulation materials, and smart windows enhancing conservation potential.

Conclusion

PP 33/2023 represents a comprehensive evolution of Indonesia's energy conservation regulatory framework, addressing gaps in PP 70/2009 through expanded coverage, lower compliance thresholds, enhanced accountability mechanisms, and balanced incentive-disincentive structures. The regulation positions energy conservation as a critical pillar of Indonesia's energy security strategy, economic competitiveness, and climate commitments toward Net Zero Emissions by 2060.

Key takeaways for regulated entities include:

1. Significantly Expanded Coverage: Threshold reductions for industry (33%), transportation (33%), and buildings (67%), plus new coverage of energy providers, substantially increase the number of entities subject to mandatory energy management requirements.
2. Time-Bound Compliance: The three-year requirement for implementing audit recommendations creates enforceable deadlines replacing previous open-ended frameworks, demanding proactive planning and resource allocation.
3. Professionalized Requirements: Mandatory BNSP-accredited certification for energy managers and auditors raises professional standards and ensures minimum competency levels across the energy management workforce.
4. Strategic Enforcement: The combination of meaningful incentives (fiscal benefits, financing access, government recognition) and clear disincentives (sanctions, public disclosure, operational restrictions) creates both motivation and consequences shaping compliance behavior.
5. International Standards Alignment: Explicit connection to ISO 50001 through implementing regulations facilitates international recognition, best practice adoption, and harmonization with global sustainability frameworks.
6. Multi-Sectoral Approach: Sector-specific obligations for energy provision, industry, transportation, and buildings recognize unique characteristics and conservation opportunities across economic activities.

Organizations subject to PP 33/2023 should approach compliance as strategic opportunity rather than mere regulatory burden, leveraging energy management systems to reduce costs, enhance competitiveness, strengthen sustainability credentials, and prepare for anticipated future regulations addressing climate and emissions. Proactive implementation, professional capacity development, and systematic continuous improvement position entities advantageously in Indonesia's energy transition.

The regulatory framework's success ultimately depends on effective enforcement, adequate government support for capacity building and financing, continued development of professional certification infrastructure, and organizational commitment to systematic energy management. As Indonesia progresses toward its 2060 Net Zero Emissions target, energy conservation under PP 33/2023 constitutes a foundational element of the broader transformation required across economic sectors.

Official Source: PP No. 33 Tahun 2023 - BPK Peraturan

Related Regulations:
- Peraturan Menteri ESDM Nomor 8 Tahun 2025 tentang Manajemen Energi
- PP No. 70 Tahun 2009 (Revoked)

Additional Resources:
- Indonesia Environment & Energy Center - PP 33/2023 Overview
- DQS Indonesia - Permen ESDM 8/2025 Analysis

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