New Coal Blending Approval and Enhanced RKAB Reporting under MEMR Regulation No. 6 of 2026
Authors
On 12 June 2026, the Minister of Energy and Mineral Resources ("MEMR") promulgated MEMR Regulation No. 6 of 2026 ("MEMR Reg 6/2026"), which amends MEMR Regulation No. 17 of 2025 on the Procedures for the Preparation, Submission, and Approval of Work Plans and Budgets (Rencana Kerja dan Anggaran Biaya - "RKAB") and the Reporting of Mineral and Coal Mining Business Activities ("MEMR Reg 17/2025"). The amendment supports the Government's objective of ensuring a reliable domestic coal supply for the power and industrial sectors while maintaining coal quality and protecting state revenue. It introduces, for the first time, a dedicated ministerial approval mechanism for coal blending, expands quarterly reporting obligations for mining business activities, and clarifies the authority to rectify administrative errors in RKAB approval decisions.[1]
1. Background
Coal blending (pencampuran batubara) is a common practice in the coal supply chain, used to combine coals of different qualities in order to meet a particular buyer specification. MEMR Reg 6/2026 brings this activity, for the first time, within a dedicated ministerial approval regime and subjects it to specific reporting under the RKAB framework, and also refines the mechanism for correcting errors in RKAB decisions. Enacted on 8 June 2026 and promulgated on 12 June 2026, the amendment is confined to three areas of MEMR Reg 17/2025: (i) quarterly reporting obligations, (ii) the correction of errors in RKAB decisions, and (iii) a new coal blending approval regime, while all other provisions remain unchanged and continue to apply. Each of these changes is discussed below.
2. A New Ministerial Approval Regime for Coal Blending
The most significant amendment introduced by MEMR Reg 6/2026 is the establishment of a dedicated ministerial approval regime for coal blending (pencampuran batubara). Under Article 34A(1), holders of an approved RKAB may only carry out coal blending to achieve a particular coal specification after obtaining prior approval from the MEMR.[2]
This requirement applies to holders of: (i) a Mining Business License (Izin Usaha Pertambangan - "IUP") at the Production Operation stage; (ii) a Special Mining Business License (Izin Usaha Pertambangan Khusus - "IUPK") at the Production Operation stage; (iii) a IUPK as a Continuation of Contract/Agreement Operation for Coal Commodities; and (iv) a Coal Mining Concession Work Agreement (Perjanjian Karya Pengusahaan Pertambangan Batubara - "PKP2B").
a) Application through the information system
The application for coal blending approval must be submitted to MEMR through the information system, and must be accompanied by at least the following supporting documents:[3]
- the approved RKAB of each holder that owns the base coal (Batubara induk) and the blending coal (Batubara pencampur);
- copies of the executed purchase agreement for the blending coal and the sale agreement for the blended coal;
- the certificate of analysis of the base coal and the blending coal, issued by a surveyor registered at the Directorate General of Mineral and Coal; and
- a coal blending simulation showing the coal specifications before and after blending, including calorific value (on both an as received basis and an air dried basis), sulphur content, moisture content, and ash content.
b) Evaluation, validity, and further guidance
Upon receipt of the application, MEMR will evaluate the submitted documents and either approve or reject the application. Any rejection must specify the grounds for the decision. Where approval is granted, the coal blending approval remains valid for the same period as the relevant RKAB approval.[4] Article 34B provides that further guidelines on the application, evaluation, and approval of coal blending will be set out in a Ministerial Decree (Keputusan Menteri).[5]
3. Expanded Quarterly Periodic Reporting
Article 19(2) of MEMR Reg 17/2025 previously required holders of an IUP/IUPK at the Production Operation stage, and an IUPK as a Continuation of Contract/Agreement for Coal Commodities to submit a Periodic Report (Laporan Berkala) every three months. MEMR Reg 6/2026 introduces a new reporting item covering the implementation of coal blending activities, which applies to coal commodity holders that have obtained coal blending approval.[6]
As a result of this addition, the two existing coal specific reporting items, namely (i) taxation and/or non tax state revenue treatment and (ii) Development and/or Utilisation activities for holders of IUPK as a Continuation of Contract/Agreement Operation for Coal Commodities, have been reletered without any substantive changes. Accordingly, once coal blending approval has been obtained, the implementation of such coal blending activities will become part of the holder's recurring quarterly reporting obligations.
4. Correction of Errors in RKAB Decisions
The revised Article 33 expands and clarifies the authority to correct errors in RKAB decisions. Under MEMR Reg 17/2025, the Minister or Governor was authorized to correct administrative and/or evaluation errors only in relation to the issuance of an RKAB approval. Under MEMR Reg 6/2026, this authority is expressly extended to errors made by the Minister or Governor in the process of issuing either an RKAB approval or rejection.[7] This amendment addresses the previous regulatory gap by allowing an erroneous rejection decision, and not only an erroneous approval decision, to be corrected by the competent authority. As a result, applicants are provided with greater administrative certainty in the RKAB approval process.
5. Enforcement Exposure
The reporting obligations under Article 19(2) remain subject to the administrative sanctions regime under MEMR Reg 17/2025. Failure to comply with Article 19(2) may expose the relevant holder to administrative sanctions in the form of a written warning, temporary suspension of part or all of the business activities, and ultimately, revocation of the relevant licence.[8] Under MEMR Reg 6/2026, holders of an IUP and IUPK at the Production Operation Stage, or an IUPK as a Continuation of Contract/Agreement Operations for Coal Commodities, that have obtained approval for coal blending, are now required to submit reports on the implementation of their coal blending activities on a quarterly basis. Carrying out coal blending without the MEMR's prior approval would also fall outside the sanctioned RKAB framework and should be treated as a compliance risk.
ARMA Commentary
MEMR Reg 6/2026 signals tighter oversight of coal blending, and IUP, IUPK, and PKP2B holders that blend coal to meet buyer specifications should treat MEMR approval as a precondition to blending, not a formality secured after the fact. In practice, this means keeping the RKABs of both the base-coal and blending-coal sources current and approved, assembling the supporting purchase/sale agreements and certificates of analysis before submission, and folding blending activity into the relevant RKAB and quarterly Periodic Report going forward rather than as an afterthought. Traders, off-takers, and other buyers of blended coal should likewise factor this approval requirement into supply chain and contractual due diligence. Businesses should also monitor the forthcoming Ministerial Decree under Article 34B, which is expected to settle the procedural details of the approval process, and build in additional lead time given this is a newly established regime.
Footnotes
Disclaimer:
This client update is the property of ARMA Law and intended for providing general information and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. ARMA Law has no intention to provide a specific legal advice with regard to this client update.
Related Updates
Latest Updates
