ENVIRONMENTAL ADMINISTRATIVE COERCION AFTER INDONESIA'S OMNIBUS LAW: LEGAL ACT, MATERIAL ENFORCEMENT, AND ECOLOGICAL RESTORATION

This article examines whether Indonesia's post-Omnibus Law environmental enforcement reform has strengthened the material enforceability of administrative sanctions, or has instead produced an expanded legal toolkit without a corresponding expansion in the state's capacity for physical environmental enforcement. The conceptual distinction between the legal administrative act (rechtelijk handelen) and material enforcement action (feitelijk handelen) — developed in Indonesian environmental law scholarship by Wibisana's critique of the pre-reform sanction regime — provides the analytical axis through which the article examines three verified enforcement cases following the enactment of Law No. 6 of 2023 and Ministerial Regulation No. 14 of 2024 (PermenLHK 14/2024). The findings reveal a persistent material enforcement deficit: administrative fines introduced by PermenLHK 14/2024 add important financial pressure but do not resolve the structural absence of post-sanction field verification and physical ecological restoration capacity. The article argues that environmental administrative sanctions must be understood as punitive-reparatory instruments requiring transparent, proportionate, and materially enforceable implementation, consistent with the polluter-pays principle and the sustainable development objective. Material enforcement — rather than sanction severity or formal legal completeness — is the decisive variable for environmental compliance. Four targeted reforms are proposed.