Jakarta, October 2, 2025 – The Publish What You Pay (PWYP) Indonesia coalition highlighted the challenges of oil and gas (O&G) governance in the era of energy transition — from the paradigm of national interests amid geopolitics and climate change, to regulatory issues such as the stalled revision of the Oil and Gas Law, and the proposal to establish an Oil and Gas Fund to support a just energy transition.
These points were conveyed by Aryanto Nugroho, National Coordinator of PWYP Indonesia, in response to the study “Legal Analysis and Evaluation Related to Oil and Gas” during the Focus Group Discussion (FGD) on Legal Analysis and Evaluation Related to Oil and Gas in Supporting Energy Self-Sufficiency (Asta Cita No. 2) organized by the National Legal Development Agency (BPHN), Ministry of Law and Human Rights of the Republic of Indonesia, on October 2, 2025.
The FGD served as a crucial platform to discuss the harmonization of oil and gas regulations to support national energy independence, in line with the priorities of the 2025–2029 National Medium-Term Development Plan (RPJMN), which emphasizes energy self-sufficiency, increased national reserves, domestic supply fulfillment, and the transition toward a green economy.
The event featured Dwi Agustine Kurniasih, Head of the Legal Analysis Study Team from BPHN, as well as several respondents, including Prof. Dr. Tri Hayati from the Faculty of Law, University of Indonesia; representatives from the Deputy Assistant for Oil and Gas Development, Coordinating Ministry for Economic Affairs; SKK Migas; and BPH Migas.
According to Aryanto, the main challenges in oil and gas governance stem from the complex paradigm of national interest, which is influenced by global geopolitics and Indonesia’s dependence on the sector as both a source of state revenue and a development driver. As a net oil importer (and a potential net gas importer), Indonesia faces pressure to achieve net-zero emissions, navigate the post-oil era, avoid the resource curse, and pursue socio-ecological justice. On the other hand, current regulations and policies remain focused on exploitation mechanisms without sufficient adaptation to the energy transition.
From a regulatory standpoint, challenges include the delayed revision of Law No. 22 of 2001 on Oil and Gas, which remains pending despite its importance in strengthening legal certainty and investment competitiveness. There is also misalignment between the Oil and Gas Law and the Job Creation Law, particularly regarding risk-based business licensing and the Norms, Standards, Procedures, and Criteria (NSPK). Harmonization is also required with other laws, such as the Energy Law, the Environmental Protection and Management Law, the State-Owned Enterprises Law, and the Industrial Law.
One key proposal highlighted was the establishment of a Petroleum Fund or Oil and Gas Fund, similar to a Sovereign Wealth Fund (SWF) or Natural Resource Fund (NRF). Such a fund should have clear objectives, including oil and gas infrastructure development, exploration of new reserves, equitable access, investment, long-term savings, and support for a just energy transition. Considerations regarding whether the fund should be managed at the national or regional level (in line with the Regional Endowment Fund under the Fiscal Relations Law between Central and Regional Governments/HKPD) are also important, along with the state’s fiscal capacity to manage it effectively.
Institutional challenges were also discussed, including the roles of SKK Migas, BPH Migas, Pertamina Holding, the Directorate General of Oil and Gas (Ministry of Energy and Mineral Resources), the Directorate General of Law Enforcement (Gakkum) within the same ministry, and the Aceh Oil and Gas Management Agency (BPMA). These institutions need to be more responsive to public complaints and ensure inclusive governance through greater public participation.
Transparency and accountability are equally crucial to prevent corruption. High-profile corruption cases, such as those involving Pertamina, PT Saka Energi, PGN, and LNG projects underscore the urgency of strengthening anti-corruption mechanisms. Transparency is essential to build public trust and ensure that revenues from oil and gas truly benefit the people.
Other emerging challenges include the post-oil and gas era, which will require environmental, social, and economic rehabilitation; asset management; the application of safeguards; and the mainstreaming of Gender Equality, Disability, and Social Inclusion (GEDSI) in oil and gas policies. All of these are necessary to ensure a just and sustainable energy transition.
PWYP Indonesia remains committed to promoting inclusive, transparent, and accountable oil and gas governance reforms. This harmonization effort is not only key to achieving national energy independence but also to realizing socio-ecological justice in the oil and gas sector.