In Indonesia a mining licence decides where you may work. A second approval, renewed every year, decides how much you may produce and where inside the licence you may do it. That approval is the RKAB — the *Rencana Kerja dan Anggaran Biaya*, the Work Plan and Budget — and under the regulation now in force, physical mining work may not be carried out without it.
Most foreign readers meet the RKAB late. It appears in a data room as an approval letter whose production figure is the real ceiling on a project, or in a partner's explanation of why output fell this year but is planned to rise next year. This article sets out what the instrument is, who must file it, the calendar that governs it, the decision mechanics, and the sanctions for working outside it. Everything here is taken from Ministerial Regulation (Permen) ESDM No. 17 of 2025 and its 2026 amendment, both read on the ministry's legal database (JDIH), and from releases published by the Ministry of Energy and Mineral Resources (ESDM).
What the RKAB is, in the regulation's own words
Permen ESDM No. 17 of 2025, signed on 30 September 2025, replaced the previous RKAB regime in full — it revoked Permen ESDM No. 10 of 2023 and No. 15 of 2024 outright (Article 36). It was itself amended by Permen ESDM No. 6 of 2026, dated 8 June 2026, which added a coal-blending approval requirement.
Article 1 of Permen 17/2025 defines the RKAB as the work plan and budget for mineral and coal mining business activity, "covering the business aspect, the technical aspect and the environmental aspect". Article 3 requires it to cover one year and to serve as the guideline for carrying out the mining business, and states that it is submitted to obtain the approval of the Minister or the Governor according to their authority.
Why the rewrite happened is stated in the regulation's own preamble: falling global prices for mineral and coal commodities required measures to maintain state revenue, "one of which is re-regulating the work plan and budget at the operation-production stage every year, in order to give room to control the production and sale of mineral and coal". Read that against the regime it replaced. In a release dated 27 December 2024, ESDM described the then-current mechanism as approval for the operation-production stage "granted for a period of 3 (three) years" through the digital e-RKAB system, under Government Regulation (PP) No. 25 of 2024 and Permen 10/2023. Under Permen 17/2025 the plan is annual, and Article 35 required RKABs for 2026 and 2027 that had already been approved to be adjusted and resubmitted through the information system; where a 2026 readjustment had been applied for and not decided by the end of the year, the existing approval could still be relied on only until 31 March 2026.
Who has to file one
Article 2 of Permen 17/2025 places the obligation on the permit holder, stage by stage, and Article 2(2) requires submission through the RKAB information system.
| Holder | RKAB obligation under Permen 17/2025 |
|---|---|
| IUP, exploration stage | Must submit an exploration-stage RKAB to the Minister or Governor |
| IUPK, exploration stage | Same |
| IUP, operation-production stage | Must submit an operation-production-stage RKAB |
| IUPK, operation-production stage | Same |
| IUPK as a continuation of a Contract/Agreement | Same |
| Contract of Work (KK) and PKP2B | The same provisions apply *mutatis mutandis* (Article 31) |
| IPR (community mining) and SIPB (rock) | No RKAB is filed with the ministry; the holder reports quarterly to the Governor (Article 19(5)–(6)) |
| Hauling and selling permit, mining service business (IUJP) | Quarterly reporting only (Article 19(7)–(8)) |
The instrument is therefore not coal-specific or nickel-specific. It applies to mineral and coal permits alike, and the party that owes the filing is the permit holder — not the contractor, not the offtaker and not the minority partner.
The annual calendar
Article 4 sets two windows, one for an ongoing operation and one for a permit that arrives mid-year.
| Timing | Obligation |
|---|---|
| 1 October to 15 November each year | Submit the RKAB for the following year |
| Within 30 calendar days of the permit (or its extension) being issued in the current year | Submit the RKAB for the current year |
| Permit issued after 15 November | Submit before the end of the current year, for the following period |
For readers of this article in late September 2026: the window for 2027 opens on 1 October 2026 and closes on 15 November 2026. There is no stated extension in the regulation for a late applicant.
What goes into the file
Article 5 lists the requirements. For a production-stage RKAB they are:
- administrative documents, which Article 5(2) says are drawn from a data exchange with the integrated electronic business licensing system (OSS) rather than supplied by hand;
- a resource and reserve estimate report by a competent person for metal minerals, non-metal minerals and coal — or by an internal responsible person for rock commodities;
- proof of payment of the natural-resource non-tax state revenue into the state treasury, the producer royalty;
- digital maps of the exploration follow-up plan, the mining plan, the land-clearing plan, and of any forest estate inside the licence area;
- a kepala teknik tambang — the mine technical manager — in place;
- proof that the reclamation guarantee was placed in the year before the year of the application;
- a production level and mining locations that do not exceed the maximum capacity in the approved feasibility study and environmental permit, and that match the locations in those documents.
An exploration-stage RKAB is the same shape with the exploration documents substituted and no reserve estimate requirement. Article 5(4) adds the clause that connects the file to national policy: a metal-mineral or coal holder applying for an operation-production RKAB must state its estimated production quantity "in accordance with the needs of the national mineral and coal industry/market".
How the decision is made
Article 6 sets a schedule that runs against the ministry, not only the applicant:
| Step | Time allowed |
|---|---|
| The Minister or Governor evaluates the application | 5 working days |
| Applicant corrects deficiencies | 2 working days per correction |
| Correction rounds available | 3 |
| Decision — approval or rejection — after evaluation and corrections | 8 working days |
| If a complete application is neither approved nor rejected by then | Approval is issued automatically by the information system |
If the application is rejected, Article 7 allows one further submission. Article 14 places legal responsibility for the truth of the submitted data — and for misuse of the approval document once issued — on the holder.
Working without one, and producing above it
Article 16 prohibits a holder from carrying out mining business activity if it has not submitted an RKAB, does not yet hold approval, has been rejected, or (for a production stage) holds approval but still lacks forest borrow-and-use approval, settled land rights or marine spatial approval. What the prohibition covers is physical field work: for exploration, general survey and exploration; for production, construction, mining, processing and/or refining, development and/or utilisation, hauling and selling, and further exploration. Maintenance and upkeep, monitoring and environmental management are carved out. Article 9 adds that a holder may operate only inside the areas approved in the RKAB, must follow the approved plan, and takes nothing from RKAB approval where forest-use approval, land rights or marine spatial approval is still missing.
Article 17 is the second limit, and the one that matters commercially: a production-stage holder may not produce mineral or coal in excess of the planned production stated in its approved operation-production RKAB.
What happens to a holder that breaches
Articles 25 to 28 set the stair: a written warning, up to three times with each warning running 30 calendar days; then suspension of part or all of the business activity, which the authority grants within at most 60 calendar days after the warning period ends; then revocation.
Two breaches skip the stair (Article 29). Revocation may be imposed without a warning or suspension where a holder submits supporting documents that lack validity or legality in the RKAB evaluation, carries out mining or selling of mineral or coal without holding RKAB approval, or misuses an approved RKAB document. Over-production is treated separately and just as sharply (Article 30): suspension of the current year's activity without a prior written warning, plus a reduction of the production plan in the next RKAB by the tonnage produced in excess — with the royalty on that excess tonnage still payable.
The reporting and amendment obligations that travel with it
Approval is not the end of the year's paperwork. Article 18 requires three kinds of report, and Article 21 sets the quarterly deadline: the 15th day of the month following the end of each quarter. A production-stage quarterly report must cover RKAB execution, effluent water quality, conservation, accident and near-miss statistics, occupational disease statistics, workforce and training plans against realisation, reclamation, upkeep of boundary markers, mine water management and geotechnical monitoring, mining equipment use, the internal safety-management audit, coal blending where approved, tax and non-tax compliance for coal IUPK-continuation holders, and development or utilisation activity. Article 20 adds special reports — an environmental case, for instance, must be reported within 24 hours of the incident (Article 22(4)) — and Article 23(2) requires the holder to respond to a ministry comment within 5 working days.
Amendments during the year are capped. Article 11 allows one change request per year, filed after the quarterly report for the second quarter and no later than 31 July. Article 12 allows further changes only on defined grounds: a change in government policy on national production volume, national production volume not being met, domestic industry or energy needs not being met, an obstructing circumstance, an environmental carrying capacity that cannot bear the load, or force majeure. Two useful exceptions: a zero-production RKAB may be changed at any time once a changed feasibility study is approved or the implementing permits are complete (Article 12(2)), and the annexes — hauling and storage facilities, explosives, dormant blasting, annual liquid fuel storage, import and re-export facilities — may be changed at any time without altering the approved plan (Article 12(3)).
Where national supply policy enters the number
Because the approved figure is set by the ministry, the RKAB is the point at which national supply management reaches an individual mine. ESDM has said so directly.
A ministry release of 13 February 2026 on the 2026 RKAB adjustments quotes the Minister of Energy and Mineral Resources, Bahlil Lahadalia: "Why did we cut the RKAB? Because we are adjusting between supply and demand. This alignment of supply and demand is also considered important, not only to maintain the stability of coal commodity prices, but also to guarantee the availability of energy reserves for future generations." (Translated from Indonesian.) The same release records the Director General of Minerals and Coal, Tri Winarno, describing the market reaction to the measure: after the Minister announced production cuts on 23 December 2025, he said, the nickel price rose immediately — from Rp14,800 during the oversupply, to a peak of Rp18,800, and "now maybe around Rp17,000 something". The release gives those figures without naming the unit or the benchmark.
The most recent ministry statement we read, dated 21 September 2026, gives the revenue picture that the policy is being judged on: mineral and coal non-tax state revenue of Rp135.16 trillion for 2025 and Rp108.13 trillion to August 2026; mining sub-sector investment of USD6.7 billion in 2025; and 685,724 workers in the sub-sector as of the first half of 2026. In the same release the Minister is quoted as saying that coal and nickel prices are now "better", and that the report he had from the Director General was that coal production is lower than in 2025 while non-tax state revenue is higher than in that period — the trade the policy was designed to make.
The last published commodity breakdown
The ministry's 27 December 2024 release remains the most detailed approval-by-commodity breakdown we have read, and it describes the regime that preceded Permen 17/2025 (permits for the 2024–2026 period, as of 26 December 2024):
| Mineral permits | Count |
|---|---|
| Requests completed | 830 |
| Approved with production | 336 |
| Approved without production | 224 |
| Rejected | 262 |
| Still in evaluation | 6 |
| Awaiting a response | 2 |
| Approvals by commodity | nickel 292, bauxite 71, gold and associated minerals 54, iron 52, tin 49, copper 8, galena 6, others 28 |
| Coal permits | Count |
|---|---|
| Requests completed | 927 |
| Approved | 736 |
| Rejected | 66 |
| Returned | 120 |
| In further evaluation | 5 |
The commodity figures add up to 560 — the number of approvals granted with or without production — which is the internal check that the table is consistent. The same release records that about 1,900 permits were drawn back from provincial governments to the central government, and describes two systems that sit around this process: SIMBARA, which integrates non-tax revenue and mineral and coal trade oversight across several ministries, and a single integrated system the ministry called Minerba One, then planned for launch in early 2025.
What an investor should check
- The approval document itself, with its approved production figure, approved mining locations and validity. That figure, not the feasibility study, is this year's ceiling.
- Whether the figure is zero. Article 12(2) contemplates production-stage RKABs approved at zero production; a project in that position may change the plan once the feasibility study change is approved or the implementing permits are complete.
- The calendar. If a permit holder has not filed for the coming year by 15 November, the next year's activity depends on an approval that does not yet exist.
- The reclamation guarantee and the appointment of a kepala teknik tambang, both of which are conditions of submission, not afterthoughts.
- Forest-use approval, land rights and marine spatial approval. Article 9(1) is explicit that RKAB approval does not stand in for any of them.
- The quarterly reporting record. Article 23(2) gives five working days to answer a ministry comment; unremedied obligations are what the warning-to-suspension-to-revocation stair in Articles 25 to 28 is built for.
The rules in sequence
| Instrument | What it is |
|---|---|
| Law No. 4 of 2009, as last amended by Law No. 2 of 2025 | The mining law, in the version cited in the legal basis of Permen 17/2025 |
| PP No. 96 of 2021, as last amended by PP No. 39 of 2025 | Implementing regulation; Article 177 and Article 178 are the provisions Permen 17/2025 executes |
| PP No. 25 of 2024 | Amended PP 96/2021; the basis ESDM cited in December 2024 for three-year RKAB approval at the production stage |
| Permen ESDM No. 10 of 2023, amended by No. 15 of 2024 | Previous RKAB procedure; revoked in full by Permen 17/2025 |
| Permen ESDM No. 17 of 2025, signed 30 September 2025 | The RKAB and reporting regime described in this article |
| Permen ESDM No. 6 of 2026, dated 8 June 2026 | Amends it: coal blending now needs the Minister's approval, applied for through the information system with signed purchase and sale contracts, a certificate of analysis from a registered surveyor, and a blending simulation covering calorific value as received and on an air-dried basis, sulphur, moisture and ash; coal holders with blending approval must also report blending in their quarterly report |
Catatan Teramine
This section is Teramine's editorial assessment, not a statement from any government body and not a quotation from any source.
The change from three-year approval to an annual plan is the part of Permen 17/2025 that an investor should weigh, and it is easy to miss because the regulation reads like procedure. Its own preamble is candid about the purpose: the annual cycle exists to give the government room to control production and sales. A holder's approved tonnage therefore becomes a policy variable measured yearly rather than a fixed entitlement spread over three years — which is exactly what the ministry described in February 2026, when it said the 2026 RKABs were cut to balance supply and demand, and pointed to the nickel price move after the December 2025 announcement. There is a real benefit on the other side of that ledger, and the regulation is explicit about it: production above the approved plan draws immediate suspension and a cut to the following year's plan, but a change in *government* production policy is itself a ground on which a holder may apply to amend its RKAB mid-year (Article 12(1)). A quota cut is not, on the face of the text, a one-way door.
The second point is the automatic approval in Article 6(6). Where an application is complete and the authority has not decided within its own deadline, the information system issues the approval. We would not read that as a guarantee in practice — the evaluation itself is where completeness is tested, and Article 29 keeps revocation available without warning for documents that lack validity. But it does mean the statutory design is a timed process rather than an open-ended discretion, and a filing that is genuinely complete has a clock on the other side of the table.
Third, the coal-blending approval added in June 2026 is worth flagging separately, because it is new and operational. Blending to reach a specification now requires the Minister's approval, applied for through the system, with the quality documentation and a blending simulation attached. Nothing in the two regulations states that blending without approval is itself listed among the immediate-revocation grounds in Article 29; they state instead that it is an obligation with a reporting duty attached, and that a failure of the general kind in Article 25 attracts the warning-to-suspension-to-revocation sequence. We have not seen guidance on how it will be enforced, so we state the text and not a practice.
What we could not source, and therefore did not state: any national production quota figure for coal or nickel for 2026 or 2027 — figures circulating in media reporting are not in any document we read; the number of RKABs approved for 2026 under the current regulation; the current text of PP 25/2024, PP 39/2025 or Law No. 2 of 2025, each of which we have read only as cited in the legal basis of Permen 17/2025; the unit and benchmark behind the nickel price figures quoted by the Director General; and the current status of the Minerba One system, described in December 2024 as planned for an early-2025 launch.
Where the question is transactional, the assets are listed on the [mining marketplace](/en/marketplace). Where the question is filing for a licence you already hold — this RKAB year or the next — that work sits with our [permit services](/en/layanan-izin). The surrounding commodity and licence context is in our pieces on [coal mining in Indonesia](/en/news/coal-mining-in-indonesia), [IUP vs IUPK](/en/news/iup-vs-iupk) and [nickel mining investment in Indonesia](/en/news/indonesia-nickel-mining-investment-2026).
Sources
Every article number, deadline, quotation and definition in this text comes from the six documents below, each of which was opened and read for it.
