Mining activities can be a big threat to environmental sustainability. This is due to mining activities that can change land topography and leave an impact in the form of mine pits. To restore the function of land and environmental ecosystems, business actors are required to implement reclamation and post-mining activities. Reclamation and post-mining become a whole component of mining activities as a form of implementation of good mining practices. Reclamation and post-mining must be planned before performing mining activities, including placing the reclamation and post-mining fund through a joint account between business actors and the government as the licensor (both central and provincial government). The placement of reclamation and post-mining fund functions as a manifestation of the company’s responsibility and commitment to manage and overcome environmental impacts, both from exploration, production, and post-mining phase activities. This policy brief outlines several issues related to the placement of reclamation and post-mining fund, whether in terms of company compliance, weakness in the process, disbursement, and coordination function between central and provincial governments. This policy brief also describes the impact of disobedience or not overcoming problems related to the placement of reclamation and post-mining fund. This brief also provides recommendations, both in policy as well as institutional aspects to improve the whole mining governance.

1. November 2018
1 | POLICY BRIEF www.pwyp-indonesia.org
HTTPS://PWYP-INDONESIA.ORG
PolicyBrief
Table of contents
• Findings
• Recommendation
• Background
• Low Compliance of Reclama-
tion Fund Placement
• Reclamation Fund Placement
and Potential State Losses
• Ineffective Law and Regulation
Enforcement
• Data and Administration of
Fund Placement
• Coordination between the
Central and Provincial Gov-
ernment in Disbursing the
Funds
• Weak of Supervision Function
Due to Limited Capacity of
Mine Inspector
• Reference
60% or 1,569 from 2,579
IUP holders (domestic
investors) don't deposit
reclamation fund
(Directorate General of
Mineral and Coal, July
2018)
Findings
1. 60% or 1,569 out of 2,579 IUP holders (domestic investors) do not deposit
reclamation fund (Directorate General of Mineral and Coal (Ditjen Minerba),
July 2018).
2. The capacity of supervisory staff is still minimal in terms of implementing
reclamation and post-mining. Of the 7,464 existing IUPs, there are only 260
mine inspectors as a supervisory staff. There are limitations and constraints in
managing the budget for mine inspectors to support the implementation of
oversight function. Therefore, it’s difficult to monitor the implementation of
reclamation and post-mining.
3. Low compliance in the reclamation and post-mining funds placement is
potentially causing a burden on the state budget, which if it’s prolonged, it can
actually lead to state losses.
4. The transition process from regency /city experiences a number of constraints,
both in handing over authentic documents and disbursing the funds of
reclamation and post-mining.
5. Enforcement of violations related to the obligation of reclamation and
post-mining fund placement is still weak. Application of sanctions, both
administratively or criminal, has not been applied firmly and effectively to the
IUP holders that has not met the reclamation and post-mining requirements.
Recommendations
1. Improving the licensing through strict enforcement of regulations
2. Curbing IUPs that have not placed reclamation and post-mining fund and
followed by an effective and continual law enforcement.
3. Increasing the number of mine inspectors for a stronger reclamation and post-
mining monitoring.
4. Accelerating the transferring process of reclamation and post-mining fund
from the district/city for a more effective fund disbursement.
Compliance of Reclamation and Post-Mining Fund
Placement in Indonesia
By: Andri Prasetiyo, Liza Mashita Ramadhania
Reviewed by: Maryati Abdullah
“

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Background
Mining activities can be a big threat to environmental sus-
tainability. This is due to mining activities that can change
land topography and leave an impact in the form of mine
pits. To restore the function of land and environmental eco-
systems, business actors are required to implement recla-
mation and post-mining activities. Reclamation and post-
mining become a whole component of mining activities as
a form of implementation of good mining practices.
Reclamation and post-mining must be planned before per-
forming mining activities, including placing the reclama-
tion and post-mining fund through a joint account between
business actors and the government as the licensor (both
central and provincial government). The placement of rec-
lamation and post-mining fund functions as a manifesta-
tion of the company's responsibility and commitment to
manage and overcome environmental impacts, both from
exploration, production, and post-mining phase activities.
Until now, the implementation was in fact often far from
expectations, there are still numerous mine pits in Indone-
sia that has not been restored. The environmental changes
caused by mining activity still leave a handful of problems.
For example, mining activity has resulted in degradation
and conversion of land around 100,000 hectares (Mong-
abay, June 2018). Meanwhile, floods and damaged water
systems hit several villages in Samarinda, East Kaliman-
tan due to the negligence of reclamation and post-mining.
Most of the mining permits are in Samarinda located near
residential areas, and not rarely do residents complain of
flooding and pollution around the residential area.
Moreover, lots of ex-mine pits (whether in the post-mining
as well as the production phase) is overlooked without be-
ing reclaimed. Even until this report was in a process of
writing, a pit of coal mines in East Kalimantan has caused
31 victims who live around the mining area. The increase
of this death rate reflects that many parties - both from the
business side as well as the government tend to ignore the
situation. Victims and economic as well as social losses are
only resolved through mediation alone, without law en-
forcement, there will be no significant results to improve
the implementation of the reclamation and post-mining
obligation in this sector.
Therefore, mining management that is prioritizing the sus-
tainable principles must be implemented, so that environ-
mental sustainability aspects are maintained. The obligation
for reclamation and post-mining is regulated by Ministerial
Regulation (Permen) Number 26 of 2018 concerning Im-
plementation of Good Mining Principles and Mineral and
Coal Mining Supervision, where it regulates requirement
of fund deposit for reclamation and post-mining as part
from the application for a mining business permit (IUP).
Though in fact the regulation has not yet been implement-
ed maximally – seeing the fact that the compliance of IUP
holder is still low in a matter of placing reclamation and
post-mining funds (Korsup Minerba KPK, 2014). This has
made efforts to restore ex-mining land become difficult to
be achieved, thus this shall cause serious impacts on envi-
ronmental and social aspects.
This policy brief outlines several issues related to the place-
ment of reclamation and post-mining fund, whether in
terms of company compliance, weakness in the process,
disbursement, and coordination function between cen-
tral and provincial governments. This policy brief also
describes the impact of disobedience or not overcoming
problems related to the placement of reclamation and post-
mining fund. This brief also provide recommendations,
both in policy as well as institutional aspects to improve
the whole mining governance.

3. 3 | POLICY BRIEF www.pwyp-indonesia.org
Low Compliance of Reclamation Fund Placement
The company compliance to deposit the reclamation and post-mining fund is still very low. As an illustra-
tion, until June 2018, out of a total of 2,579 IUPs were recorded in 33 provinces, there are still 1,569 IUPs that
have not complied with the obligation to place reclamation fund or about 60% of the total existing IUP. This in-
dicates poor compliance, with only 1,010 of 2,579 IUPs placing guarantee funds (Ditjen Minerba, July 2018).
Table 1
IUP that has not fulfilled the Obligation of Reclamation Fund
Province
Total of IUPs that has not been
fulfilled obligation of reclama-
tion fund
Aceh 13
Banten 4
Bengkulu 9
DI Yogyakarta 1
Gorontalo 14
Jambi 40
West Java 27
Central Java 4
East Java 4
West Kalimantan 75
South Kalimantan 62
Central Kalimantan 118
East Kalimantan 147
North Kalimantan 10
Bangka belitung 337
Riau Island 27
Lampung 13
Province
Total of IUPs that has not been
fulfilled obligation of reclama-
tion fund
Maluku 6
North Maluku 103
West Nusa Tenggara 16
East Nusa Tenggara 85
Papua 17
West Papua 15
Riau 13
West Sulawesi 3
South Sulawesi 29
Central Sulawesi 102
Southeast Sulawesi 176
North Sulawesi 8
West Sulawesi 40
South Sumatera -
Bengkulu
1
North Sumatera 6
Total 1525
Source: Ministry of Energy and Mineral Resources (ESDM), 2018 (recompiled)
This problem shows that mining governance facing seri-
ous problems, which will have an impact on social and
environmental conditions. The operation of IUP without
placing reclamation and post-mining fund is a portrait of
the weak licensing process and poor monitoring system.
The company that has violated regulations and standards
of mining activity is actually allowed to slip off from the
procedure, even continue to freely carry out its opera-
tions. In fact, the absence of reclamation and post-mining
fund made the status of the IUPs as Non-Clean and Clear
(CNC), which means the activities automatically must be
stopped until obtaining CNC status or otherwise the IUP
must be revoked.

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Reclamation Fund Placement and Potential State Losses
The Director General of Mineral and Coal of Energy and
Mineral Resources (Dirjen Minerba) (July 2018) has re-
corded that there were almost 8 million hectares of mine
pits that have not been reclaimed and this non-compli-
ance can create potential large state losses. For example,
there are findings that stated a state loss due to the min-
ing sector in North Kalimantan which allegedly reached
201 billion rupiahs caused by 45 companies who have not
deposited post-mining fund guarantees (Tribun Kaltim,
March 2018). In fact, 45 of these companies also in arrears
of non-tax revenue payment obligations. This condition is
also found in Aceh, where about 4 hectares of mine pits
in the Nagan Raya District are not reclaimed since 2012
(Tribun Aceh, July 2018).
Potential state losses due to the low level of fund place-
ment for reclamation and post-mining are also described
through the 2015 EITI Reconciliation Report. EITI Indo-
nesia requires mining companies to report data on recla-
mation and post-mining funds as one component of the
company’s financial information. However, the fact that
out of 123 mining companies that are included in the rec-
onciliation report in 2015, only 38 companies have sub-
mitted data on the payment of reclamation fund and 11
companies for post-mining fund. This shows that mining
companies still reluctant to open the information about
reclamation and post-mining fund.
Figure 1
Provisions for Reclamation Fund Placement
Source: Extracted from Appendix VI ESDM Ministerial Decree No. 1827 K / 30 / MEM / 2018
(PWYP Indonesia, 2018)
Table 2
Summary of the Reclamation and Post-Mining Fund Reported in the 2015 EITI Reconciliation Report
Form of Funds Rupiah (in millions) USD (in thousands)
Reclamation Fund 389,432 61,584
Post-Mining Fund 49,837 12,710
TOTAL 439,269 74,294
Source: EITI 2015 (recompiled)
The absence of reclamation and post-mining funds have harmed the safety and economic activities of surrounding com-
munities. For instance, agricultural and livestock activities. The state budget are then utilized to address those social and
environmental impacts. Thus, it leads to a huge burden for state budget and even impose a detrimental impact to the state.

5. 5 | POLICY BRIEF www.pwyp-indonesia.org
Figure 2
Provisions for Post-Mining Fund Placement
Source: Extracted from Appendix VI ESDM Ministerial Decree No. 1827 K / 30 / MEM / 2018
(PWYP Indonesia, 2018)
Ineffective Law and Regulation Enforcement
Other issues related to the obligations of reclamation and
post-mining is poor regulation enforcement. Government
Regulation (PP) No 55 Year 2010 has mandated both the
Ministry of ESDM as well as Local Government to oversee
reclamation and post-mining activities, one of which is by
giving sanctions for mining companies who conduct a vio-
lation. In fact, the Ministry of ESDM, through the Dirjen
Minerba has applied administrative sanctions to all com-
panies that have not placed reclamation fund, starting from
the warning letter to the temporary suspension. However,
this measure still does not appear to be effective.
The Dirjen Minerba has issued the first written warning let-
ter in April 2015, mandating the provincial government to
report the IUP holders who have not placed reclamation
and/or post-mining fund. It’s recorded that 8,166 IUP hold-
ers have not fully met said obligations. Those IUP holders
were asked to place the fund no later than 10 October 2015.
Another letter issued by the Dirjen Minerba in 2017. Letter
No. 1186/30 / DJB / 2017 mandates the provincial govern-
ment to temporarily suspend mining companies that do
not comply with reclamation and post-mining obligations.
However, the follow-up of this letter is still slow in the re-
gions. 14 provinces have not yet followed up the sanctions
for temporary suspension, according to the letter of Ditjen
Minerba per 23 January 2018. Moreover, there are five
provinces that have no data at all regarding the reclamation
and post-mining funds (Ditjen Minerba, June 2018).
The situation above illustrates inefficient coordination and
poor consolidation between central and provincial gov-
ernment. Also, it’s clearly indicates the ineffectiveness of
such measure to increase the level of compliance of recla-
mation and post-mining regulation. Given the prolonged
problems, the government should immediately enforce the
sanctions to revoke IUP which does not immediately place
reclamation and post-mining guarantee as stipulated in the
Permen 26/2018.
The government has composed a number of recommen-
dations for provinces that still have not submitted data on
the reclamation and post-mining fund. Ditjen Minerba has
coordinated with the Coordinating Ministry for Political,
Legal and Security Affairs in Palangkaraya, Palu, and Pe-
kanbaru, and has produced a number of recommendations
to discipline the provinces that still have problems with
their reclamation and post-mining obligations. These rec-
ommendations include:
a. Establish an integrated team / task force in each
province, with the budget charged to the budget
(APBD) of each province;
b. Strict law enforcement specifically for unlicensed
mining;
c. Prioritizing the issue of post-mining fund placement
by rock miner community given its short time mining
period;
d. IUP data collection is to be carried out in more detail
to synchronize data in the central and provincial
governments;

6. 6 | POLICY BRIEF www.pwyp-indonesia.org
This issue also needs to be considered as not a mere ad-
ministrative violations. Conducting mining activities
without carrying out the obligation to restore disturbed
land also has numerous impacts that goes beyond the is-
sue of licensing governance, but also environment and
socio-economic aspects. The low level of compliance and
orderliness of mining companies to meet the reclamation
and post-mining obligations indicates that law enforce-
ment through administrative sanctions is not enough.
Provisions regarding reclamation and post-mining obli-
gations have not been able to accommodate law enforce-
ment for violations of the obligations of reclamation and
post-mining. Ideally, such violations must be processed
through corporate criminal acts. The Mineral and Coal
Mining Law itself does not accommodate criminal provi-
sions for perpetrators of environmental damage. However,
in accordance with the meaning of accountability from the
principle of strict liability, that it is appropriate for mining
companies that caused environmental damage to be re-
sponsible to restore as its function. Thus, the government
also needs to use criminal functions as a mean to enforce
the law.
Data and Administration of Fund Placement
It is necessary to evaluate the monitoring of the compli-
ance of reclamation and post-mining fund placement. An-
other obstacle in the monitoring system is that the place-
ment of reclamation and post-mining fund is still carried
out manually with limited personnel. Thus, it takes a long
time to check and update the data submitted by the pro-
vincial government.
Data is still a major problem in improving the reclamation
and post-mining systems. There is no online integrated
monitoring system between the Ministry of ESDM and the
Provincial Agency of ESDM to monitor the placement of
reclamation and/or post-mining fund. Monitoring is still
carried out independently by each ESDM Agency, while
the placement status is reported to the Ditjen Minerba
through the submission of data by mail and/or submission
of data directly at the time of supervision. In this regard,
the Ditjen Minerba seeks to develop a periodic reporting
system to facilitate the supervision of the placement of rec-
lamation and post-mining fund that is integrated with the
Provincial Government in the context of implementing
Article 54 of Permen 26/2018.
The handover of data and documents regarding the fund
placement is also one of the hot topics and problems in
the process of handing over/transferring personnel, fund-
ing and facilities as well as documents (P3D) from the
Regency/City to the Province in the transition process
of implementing Local Government Law No.23 of 2014.
Constraints faced include, in some areas, the handover
of data recapitulation is not followed by the handover of
documents. Consequently, the funds can’t be disbursed,
and remains unused. Or if it can be used, the disbursement
process takes time because it requires the approval of the
official who was previously registered as the bank account
holder in the Joint Account.

7. 7 | POLICY BRIEF www.pwyp-indonesia.org
1 According to KPK research in 2017, found that Lingga Regency, Riau Islands Province should have received 517 billion. However, only 19.9 billion were deposited.
The remaining 497.1 billion is unknown
The enactment of Law No. 23 of 2014 has implications for
the mining sector. The law mandates the delegation of min-
ing licensing authority from regents to governors. It’s also
followed by the P3D, in which the district also need to del-
egate the personnel, financing, facilities, and infrastructure,
as well as documents to the province.
The transfer of authority, on the one hand, is considered as
the right momentum because it coincides with the curbing
process that is being carried out through coordination and
supervision of the KPK with the relevant ministries, insti-
tutions and provincial governments. Placing the licensing
authority at the provincial level is considered to shorten the
range of coordination. It is expected to control the number
of permits that have exceeded the capacity of government
supervision. Although on the other hand, the motive for
rent-seeking between licensing and local elections is not
necessarily able to be resolved properly.
In addition, the regions also often do not have clear data
regarding the recapitulation of records and placement of
funds (EITI Indonesia, 2016). According to the 2015 EITI
Indonesia Reconciliation Report, the total number of na-
tional reclamation funds deposited by both the Ditjen
Minerba and the Local Government is not published. As
a result, data on reclamation and post-mining fund at the
regions are difficult to specify. This problem is increasingly
complicated because the provincial government is also dif-
ficult to trace precisely about the existence of these funds.
In this case, not a few funds were allegedly spread in private
accounts or even on personal behalf outside of government
accounts.
Related to this, efforts to verify and reconcile between cen-
tral and provincial government are clearly a necessity. This
verification and reconciliation effort are important to be
immediately carried out by the government and ensured
that the process is not prolonged. If not, then the condition
will have a serious impact on various other aspects within
the scope of mining governance.
As an illustration, today, many of the reclamation and post-
mining funds are still stored in the bank. The bank (where
the funds are placed) is reluctant to withdraw or move
the fund due to unclear mechanism of disbursement and
transfer. Furthermore, another reason is the absence of a
reclamation plan document as a reference for the process of
transferring funds.
The delays in the process of transferring authority have also
affected the reclamation and post-mining funds. Until now,
there are still many reclamation and post-mining funds that
have not been transferred from the Regency / City to the
name of the Province. This causes problems in a number of
fundamental aspects, for example: making it difficult to ver-
ify and monitor IUPs that have placed funds, so that later it
can complicate the disbursement process when the IUP has
entered the reclamation and post-mining phases.
Coordination between Central and Provincial Government in Disbursing the Funds

8. 8 | POLICY BRIEF www.pwyp-indonesia.org
Weak Supervision Function Due to Limited Capacity of Mine Inspectors
Reclamation and post-mining compliance can actually be
improved by empowering the capacity of mine inspectors
and PPNS (Civil Servant Investigators) as the executors of
the supervisory function. The duties of mine inspectors
include supervision in terms of administration and field
inspections of environmental management, reclamation,
and post-mining. However, the readiness of the supervi-
sory staff is in fact inadequate. Of the 7,464 existing IUPs,
there are only 260 mine inspectors (Ditjen Minerba, Octo-
ber 2018). For example, there are only 38 mine inspectors
in East Kalimantan to oversee 1,010 IUPs (ESDM Agency
of East Kalimantan Province, August 2018). This shows
that the number of permits supervised is not comparable
with the number of supervisors that exist.
Picture 3
The Report and Disbursement of the Reclamation Fund on Production Operation Phase
Source: Extracted from Appendix VI ESDM Ministerial Decree No. 1827 K / 30 / MEM / 2018
(PWYP Indonesia, 2018)
Moreover, the disbursement of reclamation funds in the
regions is also an obstacle in the implementation of rec-
lamation and post-mining, as complained by the ESDM
Agency of South Sumatra Province. The disbursement of
reclamation and post-mining funds which were placed be-
fore the enactment of Permen 26/2018 is difficult to do,
considering reclamation and post-mining funds still use
bank guarantees, which are considered difficult to dis-
burse.
The same problem was found in Riau Islands Province,
where reclamation and post-mining fund still settling at
the district level (Tribun Batam, June 2018). In the KPK's
findings, there were more than 233 billion post-mining
funds that settled in several districts in the Riau Islands
Province, where the funds were circulated and used as cap-
ital by the bank concerned. Therefore, the KPK in the joint
meeting instructed that the funds must be transferred no
later than the end of 2018. Meanwhile, the Minister has
instructed that all reclamation funds held in local govern-
ment-owned banks must be transferred to state-owned
banks (BPK Riau Province, March 2018).

9. 9 | POLICY BRIEF www.pwyp-indonesia.org
Picture 4
Duties and Authorities of Mine Inspectors
Source: ESDM Agency of East Kalimantan Province, August 2018
Mining monitoring budget which has been allocated by
the provincial government could not be used for the op-
eration of mine inspectors due to the transfer of oversight
function to the central government. From legal perspec-
tive, this transfer authority hampers the provincial govern-
ment to act in a decisive manner. Importantly, this transfer
also leads to a decrease number of mine inspectors. Many
mine inspectors apply for transfer to be structural employ-
ees (compared to functional) due to the unclear function,
budget, and coordination after the transfer of oversight au-
thority to central government. So that, of course, this can
lead to weak supervision in the regions.
The number and quality of mine inspectors also affect
other aspects of supervision. In addition to administra-
tive supervision, mine inspectors are also responsible for
overseeing environmental safety in the mine area. Non-
reclaimed environments have the potential to be danger-
ous for safety, so there needs to be increased supervision of
mine pits. Given the comparison between the number of
inspectors and the size and number of permits, it is neces-
sary to add mine inspectors, both in quantity and quality.

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Recommendation
1. Improving the licensing through strict enforcement of regulations.
Improvements in the licensing system are encouraged through strengthening standards and regulations on ap-
plicants for IUP. It can be ascertained by strong due diligence process in the assessment process before permit is
issued. This step was taken so that the IUP applicants who did not meet the procedures and basic conditions could
not pass to carry out their operational activities.
2. Curbing IUPs that have not placed reclamation and post-mining fund and followed by an effective and continual
law enforcement.
The government needs to immediately curb (including through a letter of warning and revocation) IUP that has
not placed reclamation and post-mining fund as a firm law enforcement measure. Not only that, Ditjen Minerba
also needs to ask the Governor not to provide services to IUPs that have not placed the funds. Criminal acts against
violations in the mining environment also need to be implemented by the government, one of which is by formu-
lating policies related to the implementation of disincentives in the form of fines to mining companies who are
negligent in fulfilling the obligations of reclamation and post-mining. The application of sanctions also needs to be
supported by improving government performance in evaluating reclamation and post-mining phases so that min-
ing companies do not only put the funds in place, but also continue to carry out their commitments in accordance
with good mining practices;
3. Increasing the number of mine inspectors for a stronger reclamation and post-mining monitoring.
The government needs to increase the empowerment of supervisory staff, both through budget readiness and train-
ing of mine inspectors to increase supervisory capacity. Improvement of the capacity and quantity of mine inspec-
tors is expected to increase the oversight of the overall reclamation and post-mining. This strengthening effort
must also be accompanied by clarity of lines of coordination and authority in the duties and functions of the mine
inspector and PPNS so that supervision and law enforcement for good mining governance can be firmly enforced.
4. Accelerating the transferring process of reclamation and post-mining fund from the district/city for a more effective
fund disbursement.
The government needs to accelerate the process to handover the reclamation and post-mining fund so that the fund
disbursement can be immediately carried out. These efforts can be done by encouraging the process of verification
and reconciliation of data at the local level comprehensively. This is important to ensure the authority transition
process becomes smoother and the quality of mining management will be better. Thus, efforts to move the licensing
authority from district to province will not be a failed step that will only move the level of the problem. If these ef-
forts are slow or deadlocked, the provincial government can be encouraged to review all plans and funds placement
for all IUPs in their jurisdiction. #
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Policy Brief Compliance of Reclamation And Post-Mining Fund Placement In Indonesia is published by Publish
What You Pay Indonesia (PWYP Indonesia), composed by the authors, who are members of the National Secre-
tariat of PWYP Indonesia, supported by The Asia Foundation and funded by UKaid. Content and opinion are the
responsibility of Publish What You Pay Indonesia independently and do not reflect attitudes and opinions from The
Asia Foundation and UKaid.

12. Publish What You Pay (PWYP) Indonesia is a national coalition institution that
is concerned with transparency, accountability, development of extractive
governance, mining and natural resources. Established since 2007, and registered
as an Indonesian legal entity since 2012 under the name Yayasan Transparansi
Sumberdaya Ekstraktif, and affiliated in the Publish What You Pay campaign at
the global level. PWYP Indonesia promotes transparency and accountability along
the extractive resource chain, from the stage of developing contracts and mining
operations (publish why you pay and how you extract), stages of production
and income from the industry (publish what you pay), to the stage of income
expenditure for sustainable development and social welfare (publish what you earn
and how you spent).
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