Business

Environmental Supervision in Business Zones Is Overhauled

By Saka Wibisono & Partners  |  November 9, 2026

About the Regulation

Minister of Environment/Head of the Environmental Control Agency Regulation No. 14 of 2026 governs the supervision of Detailed Environmental Management Plans (Rencana Pengelolaan Lingkungan Hidup or RKL) and Detailed Environmental Monitoring Plans (Rencana Pemantauan Lingkungan Hidup or RPL), collectively referred to as Detailed RKL-RPL, as well as environmental administrative sanctions in zones.

The regulation came into force on 2 November 2026, repealing Minister of Environment and Forestry Regulation No. P.15/MENLHK/SETJEN/PLA.4/7/2020. The previous regulation covered business actors in Special Economic Zones (KEK) only. Regulation 14/2026 extends supervision to KEK, industrial estates, and Free Trade Zones and Free Ports (KPBPB).

New Status of the Detailed RKL-RPL

Under Regulation 15/2020, a business actor’s Detailed RKL-RPL in a KEK referred to the business entity’s environmental permit. The document was reviewed and approved by the business entity, and its implementation was treated as part of the KEK operator’s environmental permit. Permits already held by business actors also had to be integrated and synchronized with the operator’s permit.

Regulation 14/2026 changes this arrangement. The Detailed RKL-RPL is now each business actor’s own environmental approval. It takes the form of an environmental management commitment statement ratified by the zone manager and serves as a prerequisite for the business actor’s licensing.

For business actors and activities in industrial estates within the Batam KPBPB, supervision is carried out by the Minister and/or the Head of the Batam KPBPB Concession Agency.

Supervisors and Zone Environmental Officers

Supervision is carried out by officials acting within their respective authorities, including the Minister, governors, regents or mayors, and heads of KPBPB Concession Agencies. Environmental Supervisory Officials (PPLH) conduct the supervision. If the competent authority does not yet have a PPLH, it may work with PPLH from the Ministry of Environment/Environmental Control Agency.

The regulation also requires zone managers to appoint Zone Environmental Officers from among their employees or workers. Appointed workers must have an employment agreement with a minimum term of three years. These officers supervise the implementation of Detailed RKL-RPL in KEK and KPBPB, and monitor activities in industrial estates.

Each Zone Environmental Officer must have an appointment letter and a certificate obtained through training conducted by the Ministry or an accredited training institution. The officer must also be registered with the Ministry. Zone managers must appoint these officers no later than six months after Regulation 14/2026 was promulgated.

Zone Environmental Officers may inspect:

  • Detailed RKL-RPL documents and relevant business licenses.
  • Production facilities.
  • Water and air pollution control facilities.
  • Hazardous and toxic waste (B3) management.

They may also interview relevant parties and take photographs at the relevant locations.

Supervision and Reporting Procedures

KEK operators and KPBPB Concession Agencies must supervise business actors in their zones at least once every six months, by examining reports and/or conducting site inspections.

Each supervision must be documented in minutes signed by the officer and the business actor. A report must then be prepared containing a legal analysis and a conclusion on whether the business actor is compliant.

If a zone manager does not conduct supervision, the Minister may step in. If the manager is unable to conduct supervision, the Minister may do so upon the manager’s request.

PPLH may conduct direct supervision based on:

  • Periodic reports submitted by business actors.
  • Written reprimands that have not been followed up.
  • Public complaints.
  • Serious violations.
  • Environmental pollution and/or damage.

Indirect supervision is conducted based on reports submitted by the zone manager.

Zone managers must also report on their environmental approvals and business actors’ Detailed RKL-RPL to the approval issuer and the Minister at least once every six months. Environmental approval reports are submitted through the Ministry’s information system. Detailed RKL-RPL reports may be submitted electronically or non-electronically.

Reprimands and Follow-Up for Non-Compliance

If a business actor is found to be non-compliant, the KEK operator or Head of the KPBPB Concession Agency must issue a written reprimand within three days of identifying the non-compliance. The Minister must receive a copy.

If the business actor fails to comply within the deadline set out in the reprimand, the zone manager must report the matter to the Minister. For a KEK, the report must also be sent to the KEK Administrator.

The new regulation no longer sets a three-day period for business actors to comply with a reprimand. It also no longer requires reports to be submitted within one day of pollution or serious violations. Those incidents now trigger direct supervision by PPLH.

Administrative Sanctions

Regulation 14/2026 governs environmental administrative sanctions and supervision procedures. The article explains that an unaddressed written reprimand may trigger direct PPLH supervision, and that non-compliance may lead to administrative sanctions.

The article does not specify the types of sanctions, fine amounts, or the complete stages for imposing them. For the consequences of a specific violation, the relevant provisions of Regulation 14/2026 should be consulted directly.

Actions to Consider

Zone managers should appoint and certify Zone Environmental Officers within the six-month deadline, establish procedures for supervision at least every six months, prepare formats for inspection minutes and supervision reports, and set up processes for issuing reprimands and reporting through the Ministry’s information system.

Business actors should review their Detailed RKL-RPL obligations, keep relevant documents ready for inspection, meet applicable reporting requirements, and promptly address written reprimands.

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