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New Mining Quota Rules in Indonesia: What Companies Must Know

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Indonesia stands at the forefront of the global mining industry. With its rich reserves of coal, nickel, bauxite, copper, and tin, the country plays a pivotal role in powering the world’s energy transition and manufacturing supply chains. However, amid increasing environmental concerns and the push for economic sustainability, the Indonesian government has taken a bold step by introducing new mining quota rules in Indonesia. These changes aim to bring greater transparency, discipline, and fairness to mineral extraction activities. As a result, businesses involved in mining must now recalibrate their legal and operational strategies to stay compliant and competitive.

Key Takeaways

  • Indonesia has revamped its mining quota regulations starting 2024, affecting IUP/IUPK holders significantly.
  • The new system prioritizes compliance, production history, and ESG commitments for quota approval.
  • Companies must follow stricter procedures and timelines to secure their production quotas legally.
  • Failure to comply may result in heavy sanctions, including permit suspension or revocation.
  • Legal advisory is crucial—navigating the system without expert guidance risks non-compliance.

Regulatory Framework Governing Mining Quotas

To understand the significance of the new policy, it is essential to examine the legal backbone. The foundation lies in Law No. 2 of 2025 (amending Law No. 4 of 2009) on Mineral and Coal Mining (known as the Minerba Law), which sets out the overarching legal regime. Complementary regulations include:

  • Government Regulation No. 25 of 2024 on Mineral and Coal Mining Activities,
  • Minister of Energy and Mineral Resources (MEMR) Regulation No. 10 of 2023 on Guidelines for Granting Mining Business Licenses, and

These regulations assign the power to issue and oversee quotas to the MEMR, working closely with the Directorate General of Mineral and Coal (Ditjen Minerba) and regional authorities in cases involving local IUP. This structured framework ensures that mining operations remain accountable, environmentally compliant, and aligned with national objectives.

The 2024–2025 Reforms: What Changed?

Beginning in 2024, the Indonesian government revamped its quota system to address key inefficiencies. Previously, quota allocation was opaque, often delayed, and susceptible to manipulation. Under the new rules, several critical changes were introduced:

  • Centralized Digital Platform (SIMBARA) for submission and tracking,
  • Quota evaluation based on performance metrics, including past realization, financial readiness, and ESG adherence,
  • Quota restrictions for non-compliant or idle permit holders.

This shift toward data-driven governance reflects Indonesia’s commitment to curbing illegal mining, enhancing fiscal accountability, and supporting downstream value addition. Importantly, the new mining quota rules in Indonesia now place the onus on companies to prove their reliability before receiving approval.

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Objectives Behind the New Mining Quota Rules

But what exactly is the government trying to achieve? Fundamentally, this reform serves four strategic purposes:

  1. Prevent Overproduction and Resource Depletion: By tightly regulating extraction volumes, the government aims to safeguard mineral reserves for future generations.
  2. Enhance Revenue Collection: Quota-based control reduces tax leakages and boosts non-tax state revenue (PNBP) from mining.
  3. Strengthen ESG Accountability: Integrating ESG criteria into quota decisions ensures that only responsible companies benefit from state resources.
  4. Align with Downstream Policy: The quota mechanism also supports the national mandate to process minerals domestically before export.

Collectively, these goals signify a paradigm shift—from production-centric regulation to performance- and sustainability-based policy.

Key Criteria for Quota Allocation

To obtain a production quota, companies must now undergo a multi-factor evaluation process. The key criteria include:

  • Accuracy in Production Realization: Companies must demonstrate at least 80% realization against the previous year’s approved RKAB.
  • Environmental Compliance: Valid AMDAL, UKL/UPL, and environmental reports are mandatory.
  • Financial Standing: The MEMR requires proof of capital adequacy and clean tax records.
  • Operational Readiness: Companies must show ongoing production or justifiable delays, such as infrastructure constraints.
  • ESG Commitments: Measures to support local communities and minimize ecological damage will be assessed.

Moreover, each of these components contributes to a composite score, which is then used to approve, reject, or adjust requested quotas.

Quota Application Process

Navigating the new mining quota rules in Indonesia requires precision and diligence. Here’s how companies can manage the application process:

  1. Update the RKAB: Start by submitting an annual or multi-year Work Plan and Budget through the e-RKAB system. Ensure that it aligns with production forecasts, environmental constraints, and economic feasibility.
  2. Submit Supporting Documents: Include environmental licenses, tax clearance, CSR records, and past quota utilization reports.
  3. Evaluation Stage: The MEMR conducts a thorough assessment involving cross-ministerial inputs if necessary.
  4. Issuance of Quota Letter: Once approved, you’ll receive a quota letter specifying allowable tonnage, timeline, and monitoring obligations.
  5. Ongoing Reporting: You must regularly upload production realization data via SIMBARA and maintain transparency throughout the mining year.

Failing to meet any step may result in rejections or significant delays.

Legal Consequences of Non-Compliance

Compliance is no longer optional—it’s a legal necessity. Under the new system, companies that fail to comply may face serious legal repercussions. These include:

  • Monetary Penalties: Fines of up to IDR 10 billion for overproduction or false reporting.
  • Permit Suspension or Revocation: Repeat offenders risk losing their IUP or IUPK altogether.
  • Blacklist Inclusion: Companies may be barred from applying for future quotas for up to three years.

Moreover, government audits may lead to criminal investigations in cases of fraudulent quota claims or environmental breaches. Legal foresight and proactive compliance are now indispensable for survival in this sector.

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Impact on Existing Mining Permits (IUP & IUPK)

The new mining quota rules in Indonesia apply universally, including existing IUP and IUPK holders. Nevertheless, transitional measures have been introduced to ease the adjustment. Companies are given:

  • 6-month compliance window to adjust operational plans,
  • Opportunity to revise their RKABs to match new formats,
  • Warning letters before sanctions, allowing rectification within specific deadlines.

Importantly, even companies with long-standing permits must realign with the new quota calculation formula, or risk quota reduction or revocation.

Environmental and Social Considerations

Mining is no longer judged solely by production metrics. Today, environmental and social responsibility is central to regulatory approval. The government now monitors:

  • Tailings and waste disposal practices,
  • Biodiversity impact mitigation,
  • Community engagement and local hiring,

These factors directly influence a company’s eligibility for full or partial quotas. Although a company may meet other technical criteria, a poor ESG score could mean reduced quotas. Therefore, integrating ESG into business operations is not just a moral choice—it’s a strategic imperative.

Challenges Companies May Face

Despite the intended improvements, the new system is not without its flaws. Businesses are likely to encounter:

  • Digital Platform Bottlenecks: SIMBARA and e-RKAB may crash during peak submission periods.
  • Ambiguous Guidelines: Certain provisions, especially regarding ESG scoring, remain vague and open to subjective interpretation.
  • Regulatory Overlap: Conflicts between national and local licensing authorities can delay approvals.
  • Increased Costs: Complying with the new standards may raise legal, operational, and audit costs.

Therefore, understanding these barriers early on allows companies to prepare mitigation strategies and seek legal support before problems arise.

Strategic Tips for Businesses to Stay Compliant

To effectively operate under the new regime, companies should:

  1. Build a Legal-Compliance Team: This helps in real-time monitoring of regulatory updates and document readiness.
  2. Engage Stakeholders Early: Include local governments and communities in planning to prevent future conflicts.
  3. Run Internal ESG Audits Annually: Demonstrate proactive commitment to social and environmental safeguards.
  4. Consult with Legal Experts Regularly: This ensures documentation and procedures are fully aligned with MEMR expectations.

Staying ahead of the curve reduces risk, maximizes operational continuity, and protects your legal standing.

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Practical Commentary from Kusuma & Partners

At Kusuma & Partners, we’ve witnessed firsthand the confusion and uncertainty many mining clients face in adapting to these sweeping changes. From unclear RKAB formats to navigating the SIMBARA system, the regulatory landscape can be daunting. Our legal professionals offer end-to-end solutions—from document preparation, compliance, quota negotiations, to dispute resolution. We understand how crucial it is to balance commercial goals with legal certainty, especially in Indonesia’s rapidly evolving mining ecosystem. If your company operates in mining, partnering with us means peace of mind and regulatory confidence.

Conclusion

In summary, the new mining quota rules in Indonesia reflect a maturing legal framework that promotes environmental integrity, operational discipline, and regulatory transparency. For companies, these rules present both a challenge and an opportunity. Those who embrace compliance, invest in ESG, and plan ahead will thrive in this new environment. However, those who ignore the legal shifts may find themselves sidelined by sanctions and setbacks.

How We Can Help

Need guidance on mining quotas, RKAB compliance, or compliance? Contact us today for tailored legal solutions that ensure you’re not just compliant—but ahead.

Fill in the form below to get our expert guidance.

“DISCLAIMER: This content is intended for general informational purposes only and should not be treated as legal advice. For professional advice, please consult with us.”

Mining quotas regulate the annual volume a company is allowed to produce.

The Ministry of Energy and Mineral Resources (MEMR) is the key authority.

Yes, including coal, nickel, bauxite, copper, and tin.

Yes, if you're found in breach of compliance or overproduction.

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