BPH Migas Sets Fixed Reporting Deadlines for Natural Gas Pipeline Regulatory Accounts
The Downstream Oil and Gas Regulatory Agency (Badan Pengatur Hilir Minyak dan Gas Bumi, or “BPH Migas”) has issued Regulation No. 4 of 2026 on Regulatory Accounts for Business Entities Engaged in Natural Gas Pipeline Transportation (“Regulation 4/2026”). The regulation replaces and repeals BPH Migas Regulation No. 21/P/BPH MIGAS/III/2011 (“Regulation 21/2011”). It was stipulated on 26 October 2026 and came into force on 30 October 2026.
Regulation 4/2026 broadens the reporting regime, sets fixed annual submission deadlines, and establishes a process for BPH Migas to verify and, where necessary, correct reported figures.
Who Is Covered and What Must Be Reported
Regulation 21/2011 applied to certain natural gas transportation activities on transmission pipelines. Regulation 4/2026 extends the regime to natural gas transportation through pipelines more generally, including integrated transmission and distribution systems.
The reporting obligation applies to business entities holding a Special Right for Natural Gas Pipeline Transportation and/or a Special Right for a Distribution Network Area that also hold a Natural Gas Pipeline Transportation Business License.
A Regulatory Account report must be prepared for each pipeline segment, pipeline network, Access Arrangement, and/or area. Regulatory Accounts are accounts prepared in accordance with economic principles, including asset valuation and depreciation, and differ from accounts prepared for financial reporting and tax purposes.
Separating Transportation Activities
Business entities must separately report revenue, expenses, assets, and other relevant parameters relating to natural gas pipeline transportation, distinguishing them from other business activities. The report must refer to the audited annual financial statements for the same period.
Regulation 21/2011 included accounting guidelines and report formats in its appendix. Regulation 4/2026 instead provides that the Head of BPH Migas will issue technical guidelines on Regulatory Account reporting and verification.
Annual Financial Statements and Reporting Deadlines
Audited annual financial statements must be submitted by 31 May each year. Regulatory Account reports must be submitted by 30 June.
If a registered Public Accountant has not issued the audited financial statements by 31 May, the business entity must submit an interim Regulatory Account report based on unaudited financial statements by 30 June. It must then submit a final report based on the audited financial statements by 31 July.
The regulation requires submissions to be made online through BPH Migas’s application system. If the system is unavailable, physical and digital copies may be used as a fallback.
A parent entity must submit both its consolidated annual financial statements and its own annual financial statements. The financial statements must include, at a minimum, a balance sheet, an income statement, a cash flow statement, a statement of changes in equity, and notes to the financial statements.
Where relevant, the notes must include segment information on transportation revenue, expenses, and assets. Business entities that cannot yet provide this information must do so no later than when they submit their audited financial statements for the 2029 financial year.
BPH Migas Verification
Regulation 4/2026 establishes a verification process. BPH Migas may review supporting documents and, where necessary, conduct field visits to pipeline transportation facilities. The verification assesses whether reports are submitted on time, follow the required format, and correctly separate and allocate transportation accounts, expenses, and assets.
Business entities should retain supporting documents for their reported figures and allocations. If an entity cannot adequately explain or support recorded values, BPH Migas may correct the Regulatory Account entries. Verification results must be recorded in minutes signed by BPH Migas’s Director of Natural Gas and the business entity’s directors, or by an authorised representative holding a power of attorney signed by the directors.
Warnings and Other Sanctions
A business entity that violates the requirements to prepare and submit Regulatory Account reports or to submit audited financial statements may receive up to three consecutive written reprimands. Each reprimand allows a compliance period of no more than one month.
If the entity remains non-compliant after the third reprimand period expires, BPH Migas will revoke its Special Right and/or propose that the Minister of Energy and Mineral Resources revoke its Business License. Revocation of a Special Right does not release the entity from its outstanding obligations.
Transitional Rule
Regulatory Account reports for the financial year preceding the promulgation of Regulation 4/2026 must still be completed under Regulation 21/2011.
What Business Entities Should Do
Business entities should align their audit schedules with the 31 May deadline and prepare their Regulatory Account reports for submission by 30 June. They should also plan for the interim and final reporting deadlines if audited financial statements are not available by 31 May, maintain supporting documents for cost and asset allocations, and prepare the required transportation segment information ahead of the 2029 deadline.
They should also monitor the technical guidelines to be issued by the Head of BPH Migas, which will provide further detail on reporting and verification requirements.