ESG In APAC 2025 ' Indonesia

• Published date: 02 October 2025
• Subject Matter: Corporate/Commercial Law, Environment, Corporate Governance, Environmental Law, Climate Change, Waste Management
• Law Firm: SSEK Law Firm
• Author: Ms Ira Eddymurthy and Michael Carl

YEAR IN REVIEW

(1 July 2024 to 30 June 2025)

• Sustainability disclosure standards based on IFRS S1 and S2 have been finalised by the Indonesian Sustainability Standards Board. Full implementation will begin 1 January 2027, with a three-year transition period. The standards mandate climate-related disclosures, while reporting on other sustainability topics (beyond climate) remains voluntary.
• Local content rules for solar power projects have been temporarily relaxed for eligible projects.
• The Roadmap for the Energy Transition in the Power/Electricity Sector has been issued, setting out a path to reduce emissions retire coal-fired power plants early, and boost renewable energy transition. In parallel, Indonesia's mandatory emission trading system is due to expand to cover more power plants later this year.

A. ESG Reporting

1. Are there legal or regulatory requirements for companies to make ESG disclosures in your jurisdiction?

Yes, ESG disclosures are mandatory for publicly listed companies and financial institutions.

2. What are the key legislative and regulatory sources for ESG disclosure requirements and to whom do they apply?

1. Financial Services Authority (Otoritas Jasa Keuangan or OJK) Regulation No. 51/POJK.03/2017 of 2017 regarding the Implementation of Sustainable Finance for Financial Service Institutions, Issuers (Emiten), and Public Companies (dated 27 July 2017) (OJK Reg. 51/2017) This regulation generally imposes the obligation for financial service institutions, issuers and public companies to implement sustainable finance and to submit a Sustainability Report, either as part of their annual report or as a stand-alone report, annually to the OJK and to make the report publicly accessible.¹
2. OJK Circular Letter No. 16/SEOJK.04/2021 regarding the Form and Substance of the Annual Report of Issuers (Emiten) and Public Companies (dated June 29, 2021) (OJK CL 16/2021). OJK CL 16/2021 governs the form and content of ESG disclosures in the annual reports of publicly listed companies and issuers. For example:
   
   1. the annual report shall include a list of industry associations (national or international) related to the implementation of sustainable finance;²
   2. the annual report shall disclose, among other things, the actions taken by the company as part of its social and environmental responsibility. This disclosure shall be the Sustainability Report as per OJK Reg. 51/2017. The relevant explanations must at least include:
      
      • the company's sustainability strategy;
      • a summary of the company's sustainability efforts (economic, social, and environmental);
      • brief profile of the publicly listed company;
      • Board of Directors' remarks;
      • sustainable governance;
      • sustainable performance;
      • written verification from independent party(ies), if any;
      • feedback from readers, if any; and
      • response of the publicly listed company to the feedback from the previous year's report.
3. OJK Regulation No. 17 of 2023 regarding the Implementation of Governance for General Banks (dated 14 September 2023) (OJK Reg. 17/2023) mandates that banks must prepare and publish a sustainability report guided by OJK Reg 51/2017.³
4. The Minister of State-Owned Enterprises (MSOE) Regulation No. PER-2/MBU/03/2023 of 2023 regarding Guidelines for the Organization and Significant Corporate Activities of State-Owned Enterprises (dated 24 March 2023) (MSOE Reg 2/2023). State-owned enterprises (SOEs) are required to prepare reports on a quarterly and annual basis through their Board of Directors containing, among other information, reports on the implementation of their social and environmental programs.⁴ These reports must also be made accessible to the public.⁵ A sustainability report may be drafted as part of the aforementioned publicized annual report.⁶
5. Presidential Regulation No. 60 of 2023 regarding the National Strategy on Business and Human Rights (dated 26 September 2023) (PR 60/2023). This regulation requires the Regional Business and Human Rights Task Force, the National Business and Human Rights Task Force, and the Ministry of Law and Human Rights (MOLHR) to report on the implementation and outcome for Business and Human Rights Actions (BHAM Action).
   BHAM Action refers to strategies and steps that elaborate on the National Strategy on Business and Human Rights, which serve as guidelines for stakeholders, e.g. government organs, institutions agencies and business actors, to improve the protection, respect and remedy of human rights. This reporting is to take place in the following sequence:
   
   1. The Regional Business and Human Rights Task Force reports the outcome of the BHAM Action implementation to the National Business...