Pertanggungjawaban Hukum dalam Penyelenggaraan Sistem Registri Unit Karbon di Indonesia

he development of Indonesia’s carbon economic value regime has positioned the Carbon Unit Registry System (SRUK) as legal and administrative infrastructure connecting carbon-unit recording, issuance, utilization, transactions, and double-counting prevention. The entry into force of Presidential Regulation No. 110 of 2025 and Regulation of the Minister of Environment/Environmental Control Agency No. 10 of 2026 makes SRUK administration directly relevant to the legal status and recognition of carbon units. This study aims to analyze the allocation of legal liability in the administration of SRUK and the legal consequences of errors in carbon-unit recording and transactions. The study employs normative legal research using a statutory and conceptual approach based on primary and secondary legal materials. The findings show that positive law functionally allocates responsibility among the relevant minister, certification-scheme owners, independent validation and verification bodies, responsible business and activity entities, and the SRUK operator, whose expressly regulated responsibility focuses on system security and registry functions. The findings further show that required transaction recording has direct legal consequences because unrecorded transactions are deemed invalid and not recognized for NDC compliance, while errors originating from source data, verification, or issuance recommendations cannot automatically be attributed to the SRUK operator. In conclusion, SRUK legal liability should follow each actor’s authority, sphere of control, and type of error so that liability boundaries and remedial mechanisms remain accountable.

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Publication Details

Journal
Legal Note
Published
2026-10-30
DOI
https://doi.org/10.70716/legalnote.v2i4.426
Primary Topic
Indonesian Legal and Regulatory Studies
Type
article
Field-Weighted Citation Impact
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article

Pertanggungjawaban Hukum dalam Penyelenggaraan Sistem Registri Unit Karbon di Indonesia

Andri Gunawan Wibisana, Mas Achmad Santosa, Zefanya Albrena Sembiring
Legal Note
Indonesian Legal and Regulatory Studies
article

Pertanggungjawaban Hukum dalam Penyelenggaraan Sistem Registri Unit Karbon di Indonesia

Andri Gunawan Wibisana, Mas Achmad Santosa, Zefanya Albrena Sembiring
article en

Abstract

he development of Indonesia’s carbon economic value regime has positioned the Carbon Unit Registry System (SRUK) as legal and administrative infrastructure connecting carbon-unit recording, issuance, utilization, transactions, and double-counting prevention. The entry into force of Presidential Regulation No. 110 of 2025 and Regulation of the Minister of Environment/Environmental Control Agency No. 10 of 2026 makes SRUK administration directly relevant to the legal status and recognition of carbon units. This study aims to analyze the allocation of legal liability in the administration of SRUK and the legal consequences of errors in carbon-unit recording and transactions. The study employs normative legal research using a statutory and conceptual approach based on primary and secondary legal materials. The findings show that positive law functionally allocates responsibility among the relevant minister, certification-scheme owners, independent validation and verification bodies, responsible business and activity entities, and the SRUK operator, whose expressly regulated responsibility focuses on system security and registry functions. The findings further show that required transaction recording has direct legal consequences because unrecorded transactions are deemed invalid and not recognized for NDC compliance, while errors originating from source data, verification, or issuance recommendations cannot automatically be attributed to the SRUK operator. In conclusion, SRUK legal liability should follow each actor’s authority, sphere of control, and type of error so that liability boundaries and remedial mechanisms remain accountable.

Legal Note
University of Indonesia (ID)
Openalex Percentile: Top 3%
Indonesian Legal and Regulatory Studies
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