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Coal Blending Requires Ministerial Approval: Understanding the New Requirements under MEMR Regulation No. 6 of 2026 for IUP and PKP2B Holders

9 September 2026

MCO News Network: Muh. Chandra Putra Kusumah

Regulation Updates, Energy & Natural Resources

The Ministry of Energy and Mineral Resources issued Minister of Energy and Mineral Resources Regulation No. 6 of 2026 on 12 June 2026 to amend and introduce several provisions under Minister of Energy and Mineral Resources Regulation No. 17 of 2025 concerning the reporting of mining activities and the issuance of Work Plans and Budgets in the mineral and coal mining sector. The amendments also introduce requirements for obtaining approval for coal blending activities, which must be fulfilled by mining business actors prior to conducting Coal Blending.

Coal Blending Requires Ministerial Approval: Understanding the New Requirements under MEMR Regulation No. 6 of 2026 for IUP and PKP2B Holders

On 12 June 2026, the Ministry of Energy and Mineral Resources (“MEMR”) promulgated and brought into effect MEMR Regulation No. 6 of 2026 concerning the Amendment to MEMR Regulation No. 17 of 2025 concerning the Procedures for the Preparation, Submission, and Approval of Work Plans and Budgets and the Procedures for Reporting the Implementation of Mineral and Coal Mining Business Activities (“MEMR Regulation No. 6 of 2026”). The regulation updates provisions concerning the reporting of mining business activities, administrative and/or evaluation corrections in the issuance of Work Plan and Budget (“RKAB”) decisions, and introduces a new mechanism for obtaining approval for coal blending activities.


Regulatory Comparison

This regulation was issued to amend and introduce several provisions previously regulated under MEMR Regulation No. 17 of 2025 concerning the Procedures for the Preparation, Submission, and Approval of Work Plans and Budgets and the Procedures for Reporting the Implementation of Mineral and Coal Mining Business Activities (“MEMR Regulation No. 17 of 2025”). The key amendments and additions are as follows:


  1. Additional Contents of Periodic Reports for the Production Operation Stage (Article 19)

    Article 19 of MEMR Regulation No. 6 of 2026 introduces additional reporting obligations for Business Actors concerning the implementation of Coal Blending activities, taxation and/or Non-Tax State Revenue (“PNBP”), as well as coal development and/or utilization activities.


  2. Authority to Correct RKAB Decisions (Article 33)

    Article 33 of MEMR Regulation No. 6 of 2026 expands the authority of the Minister or Governor to make corrections where administrative and/or evaluation errors occur in the issuance of RKAB approvals or rejections. Previously, such authority was limited to corrections made in the issuance of RKAB approvals.


  3. Coal Blending Approval Procedure (Article 34A)

    Article 34A of Minister of Energy and Mineral Resources Regulation No. 6 of 2026 requires Business Actors to apply for Coal Blending approval through the information system, accompanied by supporting documents, including contractual documents, quality test results, and coal specification simulation data. This specific mechanism was not previously regulated under MEMR Regulation No. 17 of 2025.


Additional Reporting Obligations under Periodic Reports

Pursuant to Article 19(2) of MEMR Regulation No. 6 of 2026, holders of a Mining Business License (“IUP”)at the Production Operation stage, a Special Mining Business License (“IUPK”) at the Production Operation stage, or an IUPK as a Continuation of a Contract/Agreement are required to prepare and submit Periodic Reports every 3 (three) months to the Minister or Governor in accordance with their respective authority. In submitting such reports, Business Actors must include the following additional information:

  1. The implementation of coal blending activities by permit holders that have obtained approval for coal blending (vide Article 19(2)(l));

  2. The implementation of provisions concerning taxation treatment and/or PNBP by holders of an IUPK as a Continuation of a Contract/Agreement (Article 19(2)(m)); and

  3. Development and/or utilization activities by holders of an IUPK as a Continuation of a Contract/Agreement (Article 19(2)(n)).


Correction of Administrative and/or Evaluation Errors in RKAB Decisions

Article 33 of MEMR Regulation No. 6 of 2026 provides that the Minister or Governor, in accordance with their respective authority, may correct administrative and/or evaluation errors occurring in the process of issuing RKAB approvals or rejections. This provision expands the scope of Article 33 of MEMR Regulation No. 17 of 2025, which previously only provided for corrections in the issuance of RKAB approvals.


Coal Blending Approval

MEMR Regulation No. 6 of 2026 introduces new requirements for Business Actors prior to conducting Coal Blending activities. Pursuant to Article 34A(1) and (2), holders of an IUP at the Production Operation stage, an IUPK at the Production Operation stage, an IUPK as a Continuation of a Contract/Agreement for the coal commodity, or a Coal Mining Concession Work Agreement (“PKP2B”) that have obtained RKAB approval are required to obtain approval from the Minister before conducting coal blending to meet certain coal specifications.

Furthermore, pursuant to Article 34A(3), the application for such approval must be submitted through the information system and must at least include the following documents:

  1. RKAB approval for each relevant permit holder owning the base coal and blending coal;

  2. Copies of the agreement/contract for the purchase of blending coal and the agreement/contract for the sale of blended coal, duly signed by the relevant parties;

  3. Quality test certificates (certificate of analysis) for the base coal and blending coal issued by a surveyor registered with the relevant Directorate General; and

  4. Simulation data of coal specifications before and after blending, including calorific value under as received and air dried basis conditions, sulfur content, moisture content, and ash content.


The Minister will subsequently evaluate the application before determining whether to approve or reject the coal blending application (Article 34A(4) and (5)). In the event that the application is rejected, the Minister is required to provide the applicant with the reasons for such rejection (Article 34A(7)).

 

Conclusion

Mining Business Actors in the mineral and coal sector should take note of the amendments introduced under MEMR Regulation No. 6 of 2026. These amendments include additional information that Business Actors must report in their Periodic Reports, a new mechanism for correcting administrative and/or evaluation errors in the issuance of RKAB rejections, as well as approval requirements applicable to Business Actors intending to conduct Coal Blending activities. Accordingly, these amendments expand the reporting obligations applicable to Business Actors while establishing clearer requirements for conducting Coal Blending activities.

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