28th October 2025
OVERVIEW
Indonesia’s mineral and coal regulatory framework has undergone significant reform with the enactment of Law No. 2 of 2025 on the Fourth Amendment to Law No. 4 of 2009 on Mineral and Coal Mining (“Indonesia Mining Law”).
To implement these legislative changes, the government issued Government Regulation No. 39 of 2025 on the Second Amendment to Government Regulation No. 96 of 2021 concerning the Implementation of Mineral and Coal Mining Business Activities (“Second Amendment to GR No. 96/2021”). This regulation provides more clarity on its mechanisms and implementation, intends to strengthen regulatory certainty and align implementation practices with the broader reforms under Indonesia Mining Law.
The Second Amendment to GR No. 96/2021 introduces key adjustments to licensing, management, and domestic prioritization, among other areas. Mining sector stakeholders should carefully review these changes and ensure timely compliance with the updated requirements. To support this, Michael C. Bangun (Partner), Faris Al Hakim (Associate), and Rania Nasir (Associate) from IMCOLaw, have prepared this article outlining the key provisions introduced under the Second Amendment to GR No. 96/2021, accompanied by a summary table comparing the recent amendments with the previous regulation.