Issuance of International Renewable Energy Certificates (I-REC(E)) for rooftop solar devices in Indonesia will continue as normal, effective immediately. This follows the release of updated regulatory guidance that supports clarity on attribute ownership in the country. The International Tracking Standard Foundation (I-TRACK Foundation) in collaboration with the Issuer for Indonesia, the Green Certificate Company (GCC), has reviewed recent developments and determined that I-REC(E) issuance may proceed for all eligible devices in line with the International Attribute Tracking Standard (Standard) and Code for Electricity (I-REC Code).
Background: Considerations of Ownership Under MEMR 2/2024
In 2024, the I-TRACK Foundation reviewed the provisions of the Ministry of Energy and Mineral Resources (MEMR) Regulation No. 2 of 2024 on Rooftop Solar Power Plants Connected to Electrical Power Networks of License Holders for the Provision of Electricity for Public Interest (“MEMR REG. 2/2024”). This regulation included language, specifically in Article 40, that, in the absence of other legal provisions, implied the carbon economic value of rooftop solar generation may be treated as belonging to the Indonesian government.
This wording prompted careful internal discussion between the I-TRACK Foundation secretariat and GCC, and in turn, increased scrutiny from the issuer when considering issuance for rooftop solar devices potentially covered by the regulation. In line with principles to preserve the integrity and credibility of environmental attributes systems, GCC refrained from issuing I-REC(E) for affected rooftop solar systems during this period, pending further clarity. Absent sufficient grounds on which to implement a formal pause in issuance, Registrants were invited to submit documentation confirming environmental attribute ownership for concerned devices. However, in most cases, such documentation was not available or conclusive, leading to a reduction in issuance volumes from rooftop solar devices in Indonesia for a fixed period.
This conservative approach aligns with established issuance protocols: where ownership of attributes is unclear, issuance is delayed until evidence is sufficient to confirm appropriate ownership of environmental attributes on which to base credible issuance for a single entity.
Regulatory Update Under MEMR 5/2025
In April 2025, GCC and the I-TRACK Foundation received updated information from market actors referring to MEMR Regulation No. 5 of 2025 (“MEMR REG. 5/2025”), which offers useful clarification regarding environmental attribute rights. Article 34 of this regulation states that (unofficial translation):
“The rights to Environmental Attributes shall be exercised in accordance with the provisions of applicable laws and regulations or as agreed upon by the parties in the Power Purchase Agreement (PPA) in the absence of such laws or regulations.”
While the I-TRACK Foundation did not receive a direct response to inquiries surrounding government preferences for how ownership should be ascribed, the issuance of MEMR REG. 5/2025 provides useful clarification. It reinforces that rights to environmental attributes may be exercised based on applicable law or contractual agreement, effectively resolving the previous ambiguity and providing a reliable basis for continued I-REC(E) issuance by GCC.
Next Steps and Continued Alignment
As a result of this clarification, GCC has resumed I-REC(E) issuance for all rooftop solar devices in Indonesia that meet I-REC(E) eligibility criteria. This includes facilities affected by MEMR REG. 2/2024, provided no additional restrictions or changes are introduced in the future or generated through ambiguous contractual ownership structures linked to commercial agreements.
The I-TRACK Foundation acknowledges the regulatory evolution and the clarity MEMR REG. 5/2025 brings to the market. The I-TRACK Foundation secretariat believes that this regulatory step contributes to enhanced market stability and private sector confidence, and shows progress toward ongoing alignment between international best practices for attribute-based systems and domestic policy.
Moving forward, the I-TRACK Foundation and GCC will remain responsive to future regulatory developments and will prioritize integrity, transparency, and alignment with national policies. National representatives and private sector actors may contact the foundation at asiasupport@trackingstandard.org for further details or to provide additional inputs at any time.