In an effort to strengthen governance in the mining sector and accelerate the transition toward clean energy, the Government of Indonesia has issued two key regulations: Government Regulation No. 15 of 2022 (“GR 15/2022”) and Minister of Energy and Mineral Resources Regulation No. 10 of 2025 (“MEMR Regulation 10/2025”). These two regulations reflect the government’s commitment to sustainably managing natural resources while simultaneously pursuing national decarbonization targets.
GR 15/2022 aims to clarify the procedures for managing state revenues from both tax and non-tax sources in the coal mining business. The regulation specifically provides formulas for revenue calculation and outlines other tax obligations that must be fulfilled by coal mining companies.
Meanwhile, MEMR Regulation 10/2025 sets forth a roadmap for the early retirement of coal-fired power plants (PLTU) as part of a strategy to achieve net-zero emissions by 2060 or earlier. One of the key strategies is to accelerate early retirement of PLTUs based on specific criteria, and to ban the construction of new coal-fired power plants, except for those exempted under Presidential Regulation No. 112 of 2022.
GR 15/2022 applies to holders of Mining Business Licenses (IUP), Special Mining Business Licenses (IUPK), IUPK holders as a continuation of previous contracts/agreements, and Contract of Work (PKP2B) holders, whether their contracts stipulate income tax obligations under the PKP2B terms or refer to income tax obligations in accordance with prevailing tax laws governing mining business activities.
According to Article 4 paragraph (1) of GR 15/2022, taxable objects in the mining sector include income received or earned by mining taxpayers, whether derived from business or non-business sources, under any name and in any form. Article 5 paragraph (1) further stipulates that the amount of taxable income is determined based on gross income from the taxable objects described in Article 4, minus the costs incurred to obtain, collect, and maintain that income, in accordance with applicable income tax regulations.
In Article 2 paragraph (1) of MEMR Regulation 10/2025, it is stated that the energy transition in the power sector is carried out to reduce greenhouse gas emissions, decrease dependence on fossil fuels, and achieve commitments to sustainable development goals.
The energy transition in the power sector is to be implemented through measures such as cofiring biomass at coal-fired power plants, accelerating the reduction of oil-fueled power generation, retrofitting fossil-fuel plants, limiting new PLTU additions, boosting the development of variable renewable energy, ensuring new power capacity additions come only from new and renewable energy sources, producing green hydrogen (H₂) or green ammonia (NH₃), developing nuclear power generation, expanding or upgrading the national power grid and smart grid infrastructure, and/or accelerating the retirement of PLTU.
These two regulations not only reinforce Indonesia’s commitment to responsible natural resource management but also demonstrate the country’s seriousness in supporting the global agenda to combat climate change. Moreover, they reflect the Indonesian government’s policy direction to strike a balance between natural resource utilization and environmental responsibility. While the mining sector is being regulated for greater transparency and accountability, the power sector is being guided toward a greener energy future. This approach affirms Indonesia’s resolve to meet its climate targets without compromising national economic interests.
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Author:
Dewi Susanti