ESG Consultant for インドネシア

Name: ビジネスハブアジア
Address: Plaza 3 Pondok Indah Blok A No 1 Jl. TB Simatupang, Pondok Pinang, Jakarta Selatan, Indonesia, Indonesia, Indonesia, 12310, ID
Telephone: +622150865605
Price range: $$

Indonesia has rapidly emerged as one of the world's most strategic destinations for basic metals and downstream manufacturing investment — driven by abundant mineral reserves, industrial policy reforms, and aggressive downstream processing initiatives that have made this a central pillar of Indonesia's industrial transformation strategy.

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OJK Reg. 51/2017

Mandatory sustainability reporting for listed companies & financial institutions

SPK Issued — July 2025

Indonesia adopts IFRS S1 & S2 via national sustainability standards

TKBI 3.0 — 2026

Expanded taxonomy covering agriculture, IPPU & waste sectors

Mandatory Assurance — 2026 Draft

Third-party ESG verification moving toward compulsory status

IFRS Full Integration — 2027–2028

OJK to amend POJK 51 aligning with international disclosure standards

Navigating Indonesia's ESG Regulatory Framework

Environmental, Social, and Governance (ESG) compliance in Indonesia is no longer a voluntary exercise. Under OJK Regulation No. 51/POJK.03/2017, all publicly listed companies, issuers, and financial service institutions are legally required to prepare and submit an annual Sustainability Report — either as part of their annual report or as a standalone document — to the Financial Services Authority (Otoritas Jasa Keuangan, or OJK).

As an ESG consultant specialising in Indonesia, we help foreign companies, domestic issuers, financial institutions, and State-Owned Enterprises (SOEs) design, implement, and report on their ESG obligations in a way that meets both Indonesian regulatory requirements and the expectations of international investors and lenders.

The regulatory landscape is evolving quickly. Indonesia's Sustainability Standards Board (DSK IAI) issued the Sustainability Disclosure Standards (SPK) — aligned with IFRS S1 and S2 — in July 2025. OJK is simultaneously planning the release of TKBI Version 3.0 in 2026, expanding the Indonesian Sustainable Finance Taxonomy to cover agriculture, industrial processes and product use (IPPU), and the waste sector, adding approximately 537 new KBLI classification codes.

For companies without a structured ESG programme, this regulatory momentum translates into real compliance risk. Our ESG reporting services and advisory support are designed to help organisations build the foundation they need — before mandatory timelines close in.

OJK Reg. 51/2017

OJK CL No. 16/2021

Law No. 4 of 2023

SPK (IFRS S1 & S2)

TKBI 2.0 / 3.0

Law No. 40/2007

GR No. 47/2012

MSOE Reg. 2/2023

01

Strategic Resource Base

Mandatory under OJK Reg. 51/2017 and OJK CL 16/2021. Annual Sustainability Report required with disclosures on economic, social, and environmental performance.

02

Financial Institutions (LJK)

Banks, insurers, and securities firms must submit a Sustainable Finance Action Plan (RAKB) and Sustainability Report, aligned with OJK's phased enforcement calendar.

03

State-Owned Enterprises (BUMN)

Subject to MSOE Regulation No. 2/2023, requiring ESG disclosures integrated into annual reporting frameworks and evaluated against sustainable finance metrics.

04

Foreign Investors & PMA Companies

Foreign-invested companies (PMA) in regulated sectors — particularly natural resources and manufacturing — face growing disclosure obligations under the Job Creation Law and sector-specific regulations.

05

Private Companies in Natural Resources

Under Government Regulation No. 47/2012 and Law No. 40/2007, private non-listed companies in resource extraction must disclose corporate social and environmental responsibility activities.

The Regulatory Urgency of 2026 and Beyond

Indonesia's ESG regulatory environment is not static. Several simultaneous policy developments are converging in 2026–2028, creating a compressed window for companies to align their internal systems with forthcoming mandatory requirements.

The OJK has publicly stated its intention to update OJK Reg. 51/2017 to incorporate the new SPK standards based on IFRS S1 and S2, with mandatory adoption targeted for listed companies on the main board by 2027. Simultaneously, the Ministry of Industry plans to enact its Ministerial Regulation on Industrial Decarbonisation in 2026, with implementing regulations to follow, building on the Green Industry Standards (SIH) framework under Law No. 3 of 2014.

Non-compliance with existing sustainability reporting obligations under OJK Reg. 51/2017 already carries sanctionable consequences — including written warnings from the OJK. As enforcement posture strengthens and third-party assurance requirements move toward becoming mandatory, companies that delay ESG programme development face increasing exposure.

OJK Sanctions for Non-Compliance

Administrative sanctions, including formal written warnings, are enforceable under Article 13 of OJK Reg. 51/2017. As OJK strengthens market accountability mechanisms, enforcement is expected to become more active.

Mandatory Third-Party Assurance (Emerging)

2026 OJK draft regulations propose making independent verification of sustainability reports compulsory — a shift from the current "encouraged but not required" position. Companies without audit-ready ESG data will face timeline pressure.

TKBI 3.0 Expanding Classification Scope

OJK's release of TKBI Version 3.0 in 2026 adds ~537 new KBLI codes across agriculture, IPPU, and waste sectors. Companies in these industries must reassess their financing, reporting, and risk management processes.

Investor & Lender ESG Scrutiny

International capital markets increasingly screen Indonesian issuers against IFRS S1/S2 alignment. Poor sustainability disclosure quality directly affects borrowing costs, green bond eligibility, and institutional investor access.

Industrial Decarbonisation Regulation — 2026

The Ministry of Industry is set to issue a binding Decarbonisation Regulation in 2026. Manufacturing, consumer goods, and heavy industry companies will need to demonstrate emission reduction compliance under the Industrial Decarbonisation Roadmap.

Scope of ESG Consulting Services

Our ESG advisory and reporting services cover the full compliance lifecycle — from initial materiality assessment through annual reporting, third-party assurance preparation, and strategic alignment with Indonesia's evolving taxonomy.

01

ESG Materiality Assessment

Identify which environmental, social, and governance topics are most significant to your business and stakeholders — guided by both OJK's inside-out disclosure framework and the IFRS S1/S2 double materiality approach expected under the SPK.

02

Sustainability Report Preparation

End-to-end drafting of the annual Sustainability Report in accordance with OJK Regulation No. 51/2017 and the content standards in OJK Circular Letter No. 16/2021, covering economic, environmental, social, and governance disclosures.

03

Sustainable Finance Action Plan (RAKB)

Preparation and structured submission of the Rencana Aksi Keuangan Berkelanjutan (RAKB) for financial service institutions and issuers required to submit this document to OJK.

04

GHG Emissions Inventory & Disclosure

Scope 1 and Scope 2 emissions measurement, data collection system design, and disclosure structuring for OJK reporting and TKBI taxonomy classification — with Scope 3 guidance aligned to forthcoming IFRS S2 requirements.

05

TKBI Taxonomy Alignment

Classification of business activities under Indonesia's Sustainable Finance Taxonomy (TKBI 2.0 and forthcoming 3.0), supporting green bond issuance, sustainable financing applications, and ESG rating improvement.

06

ESG Governance & Policy Framework

Development of board-level ESG governance structures, internal ESG policies, and management oversight mechanisms that satisfy OJK's "tone from the top" disclosure expectations and institutional investor due diligence criteria.

07

Third-Party Assurance Readiness

Prepare your ESG data, disclosure processes, and internal controls for independent verification in anticipation of OJK's expected mandatory assurance requirements — ensuring your reporting meets emerging audit-grade standards.

08

Regulatory Gap Analysis

A structured review of your company's current ESG disclosure and practices against OJK Reg. 51/2017, OJK CL 16/2021, the SPK framework, and sector-specific obligations — identifying gaps and prioritising remediation steps.

09

CSR & Social Responsibility Compliance

For non-listed companies, advisory on Corporate Social Responsibility (CSR) obligations under Law No. 40/2007 and Government Regulation No. 47/2012, including community development obligations for mining companies under GR 96/2021.

Key Benefits of Structured ESG Advisory

Regulatory Compliance Security

Reduce exposure to OJK administrative sanctions, written warnings, and reputational damage from non-compliant or insufficient sustainability disclosures under current and forthcoming Indonesian regulations.

Improved Access to Capital

Strengthen eligibility for green bonds, sustainable loans, and development finance from institutions aligned with ASEAN Taxonomy and TKBI standards. Improve ESG scores that international investors use in portfolio screening.

Investor-Grade Disclosure Quality

Build a transparent, data-backed ESG reporting foundation that moves beyond regulatory minimums — positioning your company for global capital markets, strategic partnerships, and institutional investor confidence.

Regulatory Change Preparedness

Stay ahead of the 2026–2028 regulatory transition — from TKBI 3.0 expansion and industrial decarbonisation requirements to the eventual full integration of IFRS S1 and S2 within OJK's updated framework.

Stakeholder Trust & Market Reputation

Demonstrate genuine ESG commitment — not just compliance — to regulators, local communities, supply chain partners, and civil society organisations whose scrutiny of corporate ESG practices is intensifying in Indonesia.

Localised, Practical Guidance

Demonstrate genuine ESG commitment — not just compliance — to regulators, local communities, supply chain partners, and civil society organisations whose scrutiny of corporate ESG practices is intensifying in Indonesia.

Step-by-Step ESG Consulting Process

1 Initial Regulatory Assessment & Scoping

We begin with a structured review of your company's legal entity type, sector, listing status, and ownership structure to determine the precise ESG obligations that apply — whether under OJK Reg. 51/2017, GR 47/2012, sector-specific regulations, or MSOE requirements for SOEs. This step defines your compliance baseline and identifies material reporting gaps.

2 Stakeholder & Materiality Mapping

We facilitate a materiality assessment process to identify the ESG topics that matter most to your organisation and its key stakeholders — from OJK and investors to employees, communities, and supply chain partners. This ensures your sustainability report reflects genuine business priorities rather than generic disclosures.

3 ESG Data Collection & Baseline Measurement

We work with your operational and finance teams to establish data collection processes for key ESG indicators — including Scope 1 and Scope 2 greenhouse gas emissions, energy and water consumption, workforce metrics, and governance disclosures. We design systems that are repeatable and audit-ready from the outset.

4 ESG Strategy & Governance Framework Development

We assist in designing board-level ESG oversight mechanisms, internal ESG policy frameworks, and management accountability structures — consistent with OJK's expectation for an explicit Board of Directors explanation within the Sustainability Report and aligned with institutional investor governance criteria.

5 Sustainability Report Drafting & Review

Our team prepares the full Sustainability Report in line with OJK Reg. 51/2017 and OJK CL 16/2021 content requirements — covering economic performance, environmental impact, social responsibility, and governance disclosures. We integrate references to UN Sustainable Development Goals and TKBI taxonomy classification where applicable.

6 OJK Submission Support

We guide your team through the formal submission process to OJK, whether the Sustainability Report is submitted as part of the Annual Report or as a standalone document. We review submission timing to ensure compliance with OJK's applicable reporting deadlines and annual submission calendar.

7 Post-Submission Review & Continuous Improvement

We conduct a post-submission evaluation to address stakeholder feedback, assess regulatory developments, and prepare your organisation for the following reporting cycle. This includes monitoring TKBI taxonomy updates, Ministry of Industry decarbonisation regulation developments, and SPK implementation milestones.

What Companies Face Without Expert ESG Advisory

ESG compliance in Indonesia is operationally demanding. Organisations navigating it without dedicated support regularly encounter avoidable bottlenecks that delay submissions and compromise disclosure quality.

Dual Regulatory Interpretation

OJK Reg. 51/2017 adopts an inside-out perspective on sustainability impact, while the newly issued SPK (IFRS S1 and S2) introduces an outside-in financial materiality lens. Companies without specialist guidance often struggle to reconcile these two frameworks within a single, coherent Sustainability Report.

Inconsistent ESG Data Infrastructure

Many organisations lack standardised internal systems for collecting and verifying Scope 1, Scope 2 emissions data, and social performance metrics. Inconsistent data quality is the most common reason Indonesian companies produce Sustainability Reports that fall below OJK's minimum content expectations.

Evolving TKBI Taxonomy Classification

The expansion of TKBI from energy to agriculture, IPPU, and waste sectors in 2026 requires businesses to reassess whether their existing KBLI codes and financing arrangements are correctly classified under the updated taxonomy — a process that requires detailed cross-referencing with OJK's technical guidance.

Third-Party Assurance Readiness Gap

As Indonesia moves toward mandatory independent verification of sustainability disclosures, many organisations are not yet audit-ready. Building the data governance and process documentation required for credible third-party assurance typically takes 12–18 months of systematic preparation.

Sector-Specific Overlay Complexity

Beyond OJK's base requirements, companies in mining, forestry, energy, and manufacturing face additional ESG obligations from sector-specific regulators — including the Ministry of Energy and Mineral Resources (ESDM), Ministry of Environment and Forestry (KLHK), and Ministry of Industry. Coordinating disclosures across these agencies adds substantial complexity.

International Standard Alignment Uncertainty

Foreign investors and international lenders often expect ESG disclosures aligned with TCFD, GRI, or SASB frameworks. Indonesia's regulatory baseline does not currently mandate these international standards, leaving companies uncertain about how far to go beyond OJK minimum requirements to satisfy global capital market expectations.

A Regulatory Partner, Not Just a Report Writer

There is a meaningful difference between a consultant who produces a Sustainability Report and one who builds the institutional capacity for long-term ESG compliance. Our approach is rooted in Indonesian regulatory practice — not imported frameworks applied generically.

Deep familiarity with OJK Regulation 51/2017, OJK CL 16/2021, and the implementation roadmap for SPK (IFRS S1 & S2) in Indonesia

Practical experience supporting listed companies, financial institutions, PMA companies, and SOEs across their first and subsequent Sustainability Report cycles

Active monitoring of TKBI taxonomy updates, Ministry of Industry decarbonisation regulations, and OJK supervisory trends

Cross-functional team combining regulatory expertise, ESG data management, and financial disclosure knowledge

Neutral, independent advisory stance — we do not manage your OJK submissions; we ensure you do so with confidence and accuracy

Ability to align Indonesian regulatory reporting with GRI, TCFD, and ISSB-based frameworks for dual-audience reporting

Established relationships with independent assurance providers, legal counsel, and sector regulators to support end-to-end compliance workflows

10+

Years in Indonesia Regulatory Advisory

150+

Sustainability Reports Supported

40+

Industry Sectors Covered

100%

OJK Submission Success Rate

よくある質問

Is ESG reporting mandatory for all companies in Indonesia, or only listed companies?

Under OJK Regulation No. 51/2017, mandatory sustainability reporting obligations apply specifically to publicly listed companies (issuers), financial service institutions (banks, insurers, securities firms), and public companies under OJK supervision. However, non-listed companies in the natural resources sector are required to prepare a corporate social and environmental responsibility plan under Government Regulation No. 47/2012 and Law No. 40/2007. All other private companies must include CSR information in their annual reports. As the Sustainability Disclosure Standards (SPK) are implemented from 2027 onward, the scope of mandatory reporting is expected to expand to private companies, though the precise thresholds have not yet been confirmed.

What are the consequences of not submitting a Sustainability Report to OJK?

Under Article 13 of OJK Regulation No. 51/2017, non-compliance with sustainability reporting obligations can result in administrative sanctions from OJK, including formal written warnings. While Indonesia does not currently have a specific greenwashing law, companies that submit incomplete or materially inaccurate disclosures are exposed to reputational risk and potential civil liability grounds. As OJK strengthens its supervisory posture — particularly with the 2026 draft regulations moving toward mandatory third-party assurance — the enforcement landscape is tightening. It is advisable not to treat these as soft obligations.

How does the new SPK (Sustainability Disclosure Standards) differ from the existing OJK Reg. 51/2017 framework?

OJK Regulation 51/2017 adopts an “inside-out” perspective — focused on how a company’s operations affect external stakeholders such as communities, ecosystems, and the environment. The Sustainability Disclosure Standards (SPK), issued by DSK IAI in July 2025 and aligned with IFRS S1 and S2, introduce an “outside-in” approach — requiring companies to assess how external sustainability risks (such as climate change, resource scarcity, and social disruption) affect their financial performance, governance, and long-term value creation. This represents a fundamentally different analytical framework. OJK plans to amend POJK 51/2017 to incorporate the SPK as the primary reporting reference, with full implementation for main board issuers expected by 2027–2028. Companies that begin aligning with SPK requirements now will have a significant head start.

What is the TKBI taxonomy and why does it matter for our financing and ESG rating?

The Taksonomi untuk Keuangan Berkelanjutan Indonesia (TKBI) is Indonesia’s Sustainable Finance Taxonomy — a classification system that categorises economic activities into green, energy transition, or non-qualifying categories. It is used by financial institutions to assess the sustainability credentials of financing portfolios and by OJK as a key indicator of sustainable performance. TKBI Version 2.0 focused primarily on the energy sector. TKBI Version 3.0, planned for release in 2026, will expand coverage to agriculture, industrial processes and product use (IPPU), and waste — adding approximately 537 new KBLI classification codes. Companies whose activities fall within these expanded sectors will need to assess their taxonomy classification to maintain access to sustainable finance products, green bond markets, and preferential financing from development finance institutions.

How long does it typically take to prepare a compliant Sustainability Report in Indonesia?

For a first-time Sustainability Report, the process typically requires 4 to 6 months from initial scoping to final submission — assuming that ESG data collection processes need to be built from scratch. Key time-consuming stages include stakeholder and materiality mapping (4–6 weeks), data collection and verification (6–10 weeks), drafting and internal review (4–6 weeks), and OJK submission preparation. For companies that already have partial ESG data infrastructure in place, the timeline can be compressed to 3–4 months. Annual reporting cycles thereafter typically require 2–3 months once systems and governance are established.

Can a foreign-invested (PMA) company in Indonesia use its global ESG report to meet OJK requirements?

Global or group-level sustainability reports — typically prepared under GRI, TCFD, or ISSB frameworks — may form a useful starting point but generally do not meet OJK’s specific disclosure requirements as set out in OJK Regulation 51/2017 and OJK Circular Letter 16/2021. The OJK framework prescribes a detailed content structure covering the Indonesian entity’s economic, environmental, social, and governance performance, including explicit Board of Directors commentary, stakeholder engagement processes, and a response to prior-year feedback. A localised Sustainability Report for the Indonesian legal entity, referencing both global standards and local regulatory requirements, is typically necessary for foreign-invested companies that are listed or classified as financial institutions in Indonesia.

Does our company need third-party assurance for its Sustainability Report?

Under current OJK Regulation 51/2017, written verification from independent parties is listed as a content element but is qualified with the phrase “if any” — meaning it is encouraged but not strictly mandatory at present. However, this is expected to change. OJK’s 2026 draft regulations propose making third-party assurance compulsory for listed companies and financial institutions, as part of OJK’s stated agenda to combat greenwashing and ensure sustainability data is treated with the same rigour as financial data. Companies should begin preparing their ESG data governance and documentation processes now to be assurance-ready when this requirement becomes mandatory.

Ready to Build a Credible ESG Programme in Indonesia?

Indonesia's ESG regulatory environment is changing on multiple fronts simultaneously. The most strategic thing a company can do right now is understand exactly where it stands — and what steps are needed to stay ahead.

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