13 Jul 2026
Coal Blending under the RKAB Regime: Key Changes Introduced by MEMR Regulation No. 6 of 2026

Indonesia’s rules on the annual mining work plan and budget (Rencana Kerja dan Anggaran Biaya, or “RKAB”) were reformed in late 2025, when MEMR Regulation No. 17 of 2025 (“MEMR Reg. 17/2025”) replaced the long-standing MEMR Regulation No. 10 of 2023 and moved every producer onto an annual RKAB submission. Both instruments implement Government Regulation No. 96 of 2021 on the Conduct of Mineral and Coal Mining Business Activities, as most recently amended by GR No. 39 of 2025. On 12 June 2026, the Minister of Energy and Mineral Resources added a commercially significant layer to that framework through MEMR Regulation No. 6 of 2026 (“MEMR Reg. 6/2026” or the “Amendment”): now under this new regulation, coal blending (pencampuran batubara) is subject to a dedicated prior-approval regime.

This appears to reflect the Government’s intention to secure the reliability of coal supply for domestic power generation and industry. It also aims to ensure that blending, a routine commercial practice used to bring coal to a contracted specification, is carried out “accountably”, safeguarding both coal quality and state revenue. In practical terms, the Amendment gives the Ministry visibility over an activity that directly affects the calorific grade on which royalties are assessed, and the quality of coal delivered under domestic-market-obligation (“DMO”) and export contracts. 

The key changes

1. Coal blending now requires prior Ministerial approval. Under new Article 34A, holders of an Operation-Production IUP or IUPK, IUPK-as-continuation coal holders, and PKP2B holders that already hold an approved RKAB may blend coal “to meet certain coal specifications” only after obtaining the Minister’s approval, which must be applied for through the Ministry’s information system. Blending, previously conducted as an ordinary incidental aspect of production and marketing, is now a separately permitted activity. Conducting it without approval places the arrangement outside the regulatory framework and, through the new reporting obligation below, within reach of the RKAB sanction regime.

2. The application carries a substantial documentary and disclosure burden. An application must be supported, at a minimum, by: (i) the approved RKAB of each holder of the base coal (batubara induk) and the blending coal (batubara pencampur); (ii) signed copies of the purchase contract for the blending coal and the sale contract for the blended product; (iii) certificates of analysis for both coals issued by a surveyor registered with the Directorate General of Mineral and Coal; and (iv) a simulation of key specifications before and after blending — calorific value (as-received and air-dried), sulphur, moisture and ash content. The documentation requirements serve several regulatory objectives. First, by requiring both the base coal and the blending coal to originate from entities holding approved RKABs, it establishes a traceability mechanism designed to discourage the incorporation of unlicensed or illegally mined coal into blended coal products.. Second, filing signed commercial contracts potentially gives the Ministry direct visibility of pricing and counterparty terms, which may raise commercial-sensitivity concern.

3. The approval tracks the RKAB — and is therefore annual. New Article 34A(6) provides a blending approval is valid for the period of the underlying RKAB approval. Because MEMR Reg. 17/2025 moved Operation-Production RKAB onto a one-year cycle, blending approvals will in practice fall to be renewed annually alongside the RKAB. 

4. Blending becomes a standing quarterly reporting item. Article 19(2) is amended to add coal-blending implementation to the mandatory content of the quarterly periodic report for Operation-Production and CCOW or PKP2B coal holders that hold a blending approval. 

5. Implementing guidance is still to come. New Article 34B provides that the detailed procedures for applying for, evaluating and approving coal blending will be set out in a Ministerial Decree. Accordingly, although the Amendment is in force, the operational detail, including how the system for the application will work, is not yet available. 

Other amendments

The Amendment also refines Article 33, which previously allowed the Minister or Governor to correct administrative or evaluation errors only in the issuance of an RKAB approval. Article 33 now expressly extends that corrective power to errors in the issuance of a rejection as well. This is a procedural clarification that improves fairness for applicants whose RKAB was incorrectly rejected.

ABNR commentary

Based on the information currently available in MEMR Regulation No. 6 of 2026, several practical considerations may emerge for mining industry:

• Implications for coal traders and aggregators. Aggregators and traders that routinely combine coal from multiple sources to meet customer specifications are therefore likely to be among the stakeholders most directly affected and should review their existing arrangements against the new approval requirements. In particular, they should consider obtaining contractual assurances from relevant coal producers that any blending activity has been duly approved under the applicable RKAB framework and remains compliant with prevailing regulatory requirements. Given the requirement to submit purchase and sale agreements as part of the approval process, traders should also assess the potential implications of providing commercially sensitive transaction information to the authorities. Notably, the regulation does not indicate whether confidential commercial terms, including pricing information, may be redacted or submitted in extract form.

• Further implementation guidance remains awaited. The Amendment does not clarify whether approval is granted on a transaction-specific basis or as a broader authorisation covering a blending programme throughout the RKAB period. This uncertainty is particularly relevant for businesses handling rolling contracts and spot cargoes, given the apparent tension between transaction-specific supporting documents and an approval that remains valid for the RKAB period. Furthermore, the Amendment contains no grandfathering mechanism for blending activities that were already in place when it entered into force on 12 June 2026. This suggests that existing arrangements may ultimately need to be regularised, although the pending implementing decree means that the practical compliance framework has yet to be established. 

Business players and other stakeholders should monitor the issuance of the forthcoming Ministerial Decree, which is expected to provide important guidance on the practical operation of the new coal blending approval regime.

By Partner Ayik Candrawulan Gunadi (agunadi@abnrlaw.com) and Partner Mahatma Hadhi (mhadhi@abnrlaw.com), ABNR Counsellors at Law.

This ABNR client alert is intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. It does not constitute legal advice and should not be relied upon as such. ABNR accepts no liability of any kind in respect of any statement, opinion, view, error or omission that may be contained in this update. You are strongly advised to review the underlying regulations and to consult a licensed Indonesian legal practitioner before taking any action that could affect your rights and obligations under Indonesian law.

Key sources

MEMR Regulation No. 6 of 2026 (State Gazette / Berita Negara 2026 No. 384), amending MEMR Regulation No. 17 of 2025 (Berita Negara 2025 No. 743); Government Regulation No. 96 of 2021 as last amended by GR No. 39 of 2025.