Solar power is one of the key components of achieving zero emissions, as it is a renewable energy source that generates electricity without producing greenhouse gas emissions during operation. Accordingly, the Indonesian Government adjusted and amended the prevailing regulation to improve the development of rooftop solar power utilization that is suitable for the current circumstances through MoEMR Reg. No. 2/2024. Find out more our insights about this topic in our Legal Brief publication.

1. Legal Brief
Issuance of Ministry of Energy and Mineral
Resources Regulation No. 2 of 2024:
A Key Move to Boost Solar Rooftop
Project Development

2. Indonesian Government issues a National Energy Policy through
Government Regulation Number 79 of 2014, wherein prioritizing the
development and utilization of renewable energy.
Indonesian Government
Arifin Tasrif – Minister of Energy and Mineral Resources
The development of renewable energy aims to reduce greenhouse gases arising from activities related to the energy sector, including to achieve net zero
emission in 2060.
Indonesia has more than 3.200 GW of potential solar energy resources, but only 200 MW remains being utilized.
As of 2023, fossil fuel had the highest percentage of production amid
primary energy, with the following results, coal (40,46%), oil (30,18%), and
renewable energy (13,09%).
Djoko Siswanto – Head of Indonesia National Energy Council
Dynamic of Renewable Energy Development
According to Indonesia.go.id, as of 24
November 2023 data, Indonesia has
massive potential solar energy throughout
the archipelago.
Sumatera: 48.000 TWh
Java and Lesser Sunda Island: 11.500 TWh
Kalimantan: 29.400 TWh
Maluku and Papua: 51.200 TWh
Historical Background of Rooftop Solar Photovoltaic System Connected to PLN Customer’s Electrification System Provisions
On-Grid Rooftop
Solar Photovoltaic
System, a rooftop
solar photovoltaic
system which is
connected to PLN’s
electrification system.
Rooftop Solar
Photovoltaic System
Off-Grid Rooftop
Solar Photovoltaic
System, a rooftop
solar photovoltaic
system which not
connect to PLN’s
electrification
system.
Ministry of Energy and Mineral Resources (“MoEMR”)
issued MoEMR Regulation Number 49 of 2018
(“MoEMR Reg. No. 49/2018”) to realize energy
efficiency according to National Energy Policy, thus
self-use rooftop solar photovoltaic system development
deemed necessary to accelerate solar energy
utilization. MoEMR issued MoEMR Regulation Number 26 of
2021 (“MoEMR Reg. No. 26/2021”) that revoked
MoEMR Reg. No. 49/2018, wherein to encourage solar
energy utilization by increasing construction and
installation standards for self-use rooftop solar
photovoltaic system.
MoEMR issued MoEMR Regulation Number 2 of 2024
(“MoEMR Reg. No. 2/2024”) which removes provisions
under MoEMR Reg. No. 26/2021 in order to increase
solar energy utilization for self-use rooftop solar
photovoltaic system.
15 November 2018
13 August 2021
29 January 2024
Background
17 October 2014
14 September 2022
26 July 2023
18 January 2024
A H R P L e g a l B r i e f
Principally, MoEMR Reg. No. 2/2024 regulates rooftop solar photovoltaic system development which is connected to grid code of holder of business license of power supply for
public purpose, regardless of whether said rooftop solar photovoltaic system development is channeling electrical energy to the power grid. Specifically, this legal brief provides
explanation on key changes in MoEMR Reg. No. 2/2024 as well as the utilization procedure of rooftop solar photovoltaic system from its application to conduct construction and
installation of rooftop solar photovoltaic system until its operational stage in the forms of utilization report and guidance to and from MoEMR.
What is stipulated under the MoEMR Reg. No. 2/2024?
Provision History
Indonesia’s Energy Solar Potential

3. A H R P L e g a l B r i e f
Art. 5 of MoEMR Reg. No. 26/2021
Elimination of Provisions on Maximum Capacity Constraints
Previous Provisions on Maximum Capacity Constraints
There are capacity constraints for Rooftop Solar Pv System depending on the installation location of the Rooftop Solar Pv System. In the case
where Rooftop Solar Pv System is to be installed by Rooftop Solar Pv System customer within the business area of the state-owned enterprise
(BUMN) holding the IUPTLU, the capacity limit is 100% of the connected power of the Rooftop Solar Pv System customer. In the case where
a Rooftop Solar Pv System is to be installed by prospective customers within the IUPTLU holder's area other than BUMN, the capacity limit is
determined by the local electrical power system declared by the IUPTLU holder and must be reported annually in December. The determination of
the capacity of the Rooftop Solar Pv System is based on the total inverter capacity in volt-amperes.
There is currently no maximum capacity constraints on the installation of Rooftop Solar Pv System.
The capacity of Rooftop Solar Pv System which is going to be installed by the Rooftop Solar Pv System customer in a business area of IUPTLU
holder shall be adjusted in accordance with (1) the required capacity of Rooftop Solar Pv System customer and (2) the quota availability of Rooftop
Solar Pv System.
The capacity of Rooftop Solar Pv System shall be determined based on the capacity of the total inverter (nominal capacity).
Current Provisions on Maximum Capacity Constraints
MoEMR Reg. No. 26/2021 which, among others, upheld the export and import electrical energy served as incentive for the Rooftop Solar Pv System
customer as said customers obtained financial benefits in the form of reduction in the electrical energy bill for the following month, in cases
where the amount of exported electrical energy exceeds the amount of imported energy in the current month.
In the export-import electrical energy mechanism, the exported electrical energy shall be counted based on its recorded value of Export kWh on the
Export-Import kWh Meter multiplied by 100% (one hundred percent). The calculation shall be done every month based on the difference between
the Import kWh value and the Export kWh value. In the event the amount of electrical energy exported is greater than the amount of
electrical energy imported in the current month, the excess difference will be accumulated and accounted for as a reduction in the
electricity bill for the following month.
The calculation of any excess as a deduction in the electricity bill for the following month shall be valid for 6 months and shall be carried out in the
period of:
1. January to June and nullified in July of the current year; and
2. July to December and nullified in January of the following year.
Should the installation of Rooftop Solar Pv System be carried out in January, the excess shall be calculated for the first time since Rooftop start to
operate until June of the current year. Similarly, should the installation of Rooftop Solar Pv System be carried out in July, the excess shall be
calculated for the first time since Rooftop Solar Pv System start to operate until December of the current year.
Art. 6 (3) and (4) of MoEMR Reg. No. 26/2021
Art. 6 (1) and (2) of MoEMR Reg. No. 26/2021
Art. 6 (3) of MoEMR Reg. No. 26/2021
Excess of electrical energy from Rooftop Solar Pv System that enters the network of IUPTLU holders is not taken into account in determining the
amount of electricity bill of the Rooftop Solar Pv System customer.
Art. 13 of MoEMR Reg. No. 2/2024
Principally, export-import electrical energy mechanism under the MoEMR Reg. No. 2/2024 allows excess of electrical energy to be exported from
the Rooftop Solar Pv System customer to the network holder of IUPTLU. However, such export shall not be considered as a deduction of the
electricity bill.
Elimination of Provisions on Export-Import of Electrical Energy
Previous Provisions on Export-Import of Electrical Energy
Current Provisions on Export-Import of Electrical Energy
Key Changes in MoEMR Reg. No. 2/2024 (1/3)

4. A H R P L e g a l B r i e f
Elimination of Provisions on Capacity Charge
Rooftop Solar Pv System customer Capacity Charge
Rooftop Solar Pv System for industrial purposes
Subject to capacity charge which shall be paid
every month using the following calculation:
Total inverter capacity in kilowatt (kW) x 5 hours x
electricity tariff
Rooftop Solar Pv System for non-industrial
purposes
Excluded from the imposition of capacity charge
MoEMR Reg. No. 26/2021 stipulates the imposition of a capacity charge for Rooftop Solar Pv System as follows:
Art. 19 of MoEMR Reg. No. 26/2021
The Rooftop Solar Pv System built and installed by Rooftop Solar Pv System customer shall not be subject to parallel operation costs (capacity
charge and emergency charge).
Art. 29 of MoEMR Reg. No. 2/2024
Introduction to Provisions of Quota of Rooftop Solar PV System
Quota of Rooftop Solar Pv System is the amount of Rooftop Solar Pv System capacity that can be installed in the electricity system of IUPTLU
holder in an area, taking into account the security and reliability aspects of the system. Said capacity is determined by DGoE by considering the
evaluation result against the proposal of IUPTLU holder.
Mechanism for the Submission of Rooftop Solar Pv System Quota Application
IUPTLU Holder
Submission of Rooftop Solar Pv
System Quota Application
At the latest within 3 months after the enactment
of MoEMR Reg. No. 2/2024
Evaluation of the Submitted Rooftop Solar Pv
System Quota Application
At the latest within 1 month after the submission of the Rooftop Solar
Pv System Quota Application by IUPTLU holder.
MoEMR – DGoE and DGoNREEC MoEMR – DGoE
Approved Allocation of
Rooftop Solar Pv System
Quota
IUPTLU Holder
Preparation of Rooftop Solar Pv System
Clustering Quota
At the latest within 10 working days after the approval of
Rooftop Solar Pv System Quota Allocation.
Reporting of Rooftop Solar Pv System Clustering
Quota to the DGoE, with a copy to DGoNREEC
At the latest within 10 working days after the approval of Rooftop
Solar Pv System Quota Allocation.
IUPTLU Holder
Publication of Rooftop Solar
Pv System Quota Application
Previous Provisions on Capacity Charge
Current Provisions on Capacity Charge
Key Changes in MoEMR Reg. No. 2/2024 (2/3)

5. A H R P L e g a l B r i e f
06
Art. 9 (5) of MoEMR Reg. No. 2/2024
07
Art. 10 of MoEMR Reg. No. 2/2024
08
Art. 11 of MoEMR Reg. No. 2/2024
The Rooftop Solar Pv System development quota based on clustering is going to be reported to the DGoE and DGoNREEC and published
in official website, application, and/or social media of IUPTLU holder, at the latest within 10 working days after the establishment of Rooftop
Solar Pv System Development Quota.
IUPTLU holder could propose changes of Rooftop Solar Pv System development quota. The mechanism and procedure for such changes
are in accordance with the mechanism and procedure for proposing the Rooftop Solar Pv System development quota.
In the event the IUPTLU holder does not propose a change in the Rooftop Solar Pv System development quota, such development quota
follows the detailed Rooftop Solar Pv System development quota that has been established.
In the event that there is still available Rooftop Solar Pv System development quota at the end of the current year, the remaining quota for
the development of Rooftop Solar Pv System will become additional quota for the development of Rooftop Solar Pv System in the following
year.
The Rooftop Solar Pv System which had been operating in a connected state with the grid code of IUPTLU holder prior to the enactment of MoEMR
Reg. No. 2/2024 which has implemented the mechanism for calculating electricity import and export and provisions regarding capacity charges, will
be valid for the period of 10 years after obtaining approval from IUPTLU holder.
The Rooftop Solar Pv System customer which had obtained approval from the IUPTLU holder and yet to start its operation prior to the enactment of
MoEMR Reg. No. 2/2024, the mechanism for calculating electricity import and export and provisions regarding capacity charges will be valid for the
period of 10 years after obtaining approval from IUPTLU holder.
Art. 47 (1)(a) of MoEMR Reg. No. 2/2024
Art. 47 (1)(b) of MoEMR Reg. No. 2/2024
Mechanism for the Submission of Rooftop Solar Pv System Quota Application
01
02
Art. 7 of MoEMR Reg. No. 2/2024
Art. 8 (1) and (2) of MoEMR Reg. No. 2/2024
03
Art. 8 (6) of MoEMR Reg. No. 2/2024
04
Art. 9 (1) and (2) of MoEMR Reg. No. 2/2024
IUPTLU holder has the legal obligation to prepare Rooftop Solar Pv System Development Quota for each electrical energy system. The
preparation of said development quota at the very least must take into consideration of (a) direction of national energy policy, (b) plan and
realization of electrical power supply business plan, and (c) reliability of the electricity system in accordance with the provisions in the grid
code of IUPTLU holders. Said development quota shall be described for a period of 5 years, detailed for each year from January to
December.
IUPTLU holder submits a proposal for Rooftop Solar Pv System quota to the DGoE with a copy to the DGoNREEC, accompanied by
technical study documents.
DGoE involves the DGoNREEC and DGoE may involve relevant ministries/agencies and/or local governments to evaluate quota application
from IUPTLU holder.
DGoE sets the quota for the development of Rooftop Solar Pv System no later than 1 month after receiving the Rooftop Solar Pv System
Quota Application. The determination of the development quota for Rooftop Solar Pv System is communicated to the IUPTLU holder.
05
Art. 9 (3) and (4) of MoEMR Reg. No. 2/2024
Based on the approved allocation of Rooftop Solar Pv System Development Quota, IUPTLU holder is required to prepare a development
quota of Rooftop Solar Pv System based on clustering which is an electricity system at the customer service unit of the IUPTLU holder.
Provisions of Rooftop Solar Pv System Prior to the Enactment of MoEMR Reg. No. 2/2024
Key Changes in MoEMR Reg. No. 2/2024 (3/3)

6. Rooftop Solar Pv System contains a solar panel, inverter,
electrical panel, electric meter, and security system, and
henceforth, may be equipped with a battery or power
storage.
Installation and specification of Rooftop Solar Pv System
above shall be in accordance with technical guidance stipulated
on Appendix 1 of MoEMR Reg. No. 2/2024 below.
Domestic Component
Level Provisions
in regard to
cu
Solar Panels Combiner Box Inverter
Rooftop Solar Pv System
customer’s System
Switching and
Controlling Device
Holder of IUPTL’s
Electrification System
Rooftop Solar Pv System without Battery Storage
A
Advanced
Meter
Disconnector
Device
Rooftop Solar Pv System with Battery Storage
B
Components
located in 1
building
Components located in 1 building
Battery stores solar energy produced by Rooftop
Solar Pv System. Henceforth, solar energy can
be used whenever deemed necessary as long
as it remains available in the battery.
Holder of IUPTL’s
Electrification
System
Battery
Advanced
Meter
Solar Panels
Switching and
Controlling
Device
Charger
Controller
Inverter
Rooftop Solar
Pv System
customer’s
System
Switching and
Controlling
Device
Disconnector
Device
Combiner Box
Rooftop Solar Pv System without
battery requires sunlight to utilize
solar power. Distinction to Rooftop
Solar Pv System with battery
storage, whereby solar power can
be used whenever deemed
necessary as long as it remains
available in the battery.
contradiction
A H R P L e g a l B r i e f
Components of Rooftop Solar Pv System

7. A H R P L e g a l B r i e f
Application Verification Announcement License
Construction and
Installation
Commissioning
Certificate
Installation of an
Advanced Meter
Prospective Rooftop Solar Pv System
customer is required to submit an
application for the construction and
installation of Rooftop Solar Pv
System to IUPTLU holder and copies
to DGoNREEC and DGoE. Said
application shall be submitted in
January or July.
Such application shall be submitted at
the latest within 1 month after the
publication of Rooftop Solar Pv
System development quota on the
basis of clustering.
Art. 14 of MoEMR Reg. No. 2/2024
IUPTLU holder must render approval
or rejection towards the Rooftop Solar
Pv System customer’s application for
construction and installation of
Rooftop Solar Pv System no later than
30 days after said application
submission.
Said application will be approved if
IUPTLU holder fails to render decision
within 30 days.
Art. 15 (1) and (2)
of MoEMR Reg. No. 2/2024
In the event the application is:
➢ approved, IUPTLU holder through
DGoNREEC informs the prospective
Rooftop Solar Pv System customer;
or
➢ rejected, IUPTLU holder informs the
prospective Rooftop Solar Pv System
customer in written rejection along
with its reasons.
Rejected application could be
resubmitted. Rejection on the grounds of
unavailability of development quota
means the prospective customer is on a
waiting list for the next period on
condition that development quota is
available. Art. 15 (3) to (8)
of MoEMR Reg. No. 2/2024
Prospective Rooftop Solar Pv System
customer who is going to construct
and install:
➢ Rooftop Solar Pv System with a
capacity of more than 500 kW and
connected to 1 electrification
system, is obliged to obtain
business license of power
supply for self-use.
➢ Solar Pv System with a capacity of
up to 500 kW and connected to 1
electrification system, is obliged to
submit a report to Minister or
Governor prior to conducting
construction and installation.
Art. 17 and 18
of MoEMR Reg. No. 2/2024
The business entity which carries out the
construction and installation of Rooftop Solar Pv
System shall be in accordance with the laws and
regulation in electricity power sector
(https://siujang.esdm.go.id/Dokumen/Daftar-Badan-
Usaha). Moreover, such the construction and
installation is required to comply with the laws and
regulations on electrical safety.
Art. 21 of MoEMR Reg. No. 2/2024
Principally, the construction and installation of
Rooftop Solar Pv System could only be carried out
after obtaining approval and license from IUPTLU
holder. In the event said construction and installation
be carried out prior to obtaining such approval and
license, IUPTLU holder issues an order to the
Rooftop Solar Pv System customer to:
➢ disconnect the Rooftop Solar Pv System from the
IUPTLU holder’s electrification system; and
➢ pay compensation to the IUPTLU holder.
Should the above order not fulfilled within 1 month,
IUPTLU holder may temporarily disconnect the
electrification system service.
Art. 22 of MoEMR Reg. No. 2/2024
Rooftop Solar Pv System with the total capacity of:
➢ more than 500 kW and connected to 1
electrification system; and
➢ up to 500 kW with technical specifications of
control panels forming 1 separate part, must
have an operational fitness certificate,
must own a Commissioning Certificate.
Art. 24 (1) of MoEMR Reg. No. 2/2024
IUPTLU holder revokes its approval in the event
the prospective Rooftop Solar Pv System
customer:
➢ does not have a Commissioning Certificate
within a maximum period of 6 months from
obtaining approval from the IUPTLU holder; or
➢ does not have registration number from the
Minister within a maximum period of 3 months
from obtaining approval from IUPTLU holder.
Art. 26 of MoEMR Reg. No. 2/2024
IUPTLU holder is obliged to provide and install
advanced meter for the prospective Rooftop
Solar Pv System customer which has fulfilled
requirement on Commissioning Certificate. Said
advanced meter shall be provided and installed
at the latest within 15 working days after:
➢ Commissioning Certificate issued by technical
inspection institution; or
➢ Issuance proof of registration number from
Minister,
received by the IUPTLU holder from the
prospective Rooftop Solar Pv System customer.
Art. 28 of MoEMR Reg. No. 2/2024
Trading Prohibition
Rooftop Solar Pv System customer is prohibited from
trading the electricity generated from the Rooftop Solar
Pv System.
Additional Obligation for Industrial Purposes
Rooftop Solar Pv System customer from tariff class for
industrial purposes with Rooftop Solar Pv System with
capacity larger than 3 MW shall provide weather forecast
database arrangements which are integrated with the
Supervisory Control and Data Acquisition (SCADA)
system or smart grid distribution owned by the IUPTLU
holders.
Complaints
Complaints regarding the application for and installation of
Rooftop Solar Pv System shall be submitted to
DGoNREEC through https://ebtke.esdm.go.id/simantaps/.
Art. 41 of MoEMR Reg. No. 2/2024
Art. 42 of MoEMR Reg. No. 2/2024
Utilization Procedure of Rooftop Solar PV System

8. IUTPLU holder
shall submit a
monthly Rooftop
Solar Pv System
utilization report in
connection with:
Data on the number of Rooftop Solar Pv System customer;
Data on the number of application submissions for Rooftop Solar Pv System;
Total capacity of Rooftop Solar Pv System;
Total electrical energy distributed from the installation system of Rooftop Solar Pv System customer to the IUPTLU holder’s
electrification system;
Total electrical energy received by the installation system of Rooftop Solar Pv System customer from the IUPTLU holder’s electrification
system.
Art. 36 of MoMER Reg. No. 2/2024
Standards and quality of Rooftop
Solar Pv System
Implementation of the
construction and installation of
Rooftop Solar Pv System
Fulfillment of licensing
requirements
Electricity safety
Standards and quality for the
construction and installation of
Rooftop Solar Pv System
Standards and quality for the
examination and testing of
Rooftop Solar Pv System
Implementation of reporting of
Rooftop Solar Pv System
Implementation of development
and/or approval of digital-based
application for the utilization of
Rooftop Solar Pv System made
by the IUPTLU holder
Art. 38 of MoMER Reg. No. 2/2024
Decoding MoEMR Reg. No. 2/2024: Reporting, Guidance,
Supervision, and Weighing the Pros and Cons
Minister through DGoNREEC
and/or DGoE conduct
guidance and supervision in
connection with:
The elimination of electricity export-import scheme causes household or
small business customers to delay adopting the Rooftop Solar Pv
System because the peak demand for electricity occurs at night, while
Rooftop Solar Pv System produces peak energy during the day. The
electricity export-import scheme increases the economic viability of
Rooftop Solar Pv System. Therefore, without the electricity export-import
scheme, investment in Rooftop Solar Pv System becomes expensive,
especially if users must spend additional funds for battery storage.
Fabby Tumiwa – Director of Essential Services Reform
Source: https://www.topbusiness.id/88576/permen-esdm-no-2-2024-membatasi-
partisipasi-publik-untuk-dukung-transisi-energi-lewat-plts-atap.html
Electricity export-import scheme regulated under previous regulation
(MoEMR Reg. No. 26/2021) potentially increases state loss because
the state must purchase the excess electricity produced from Rooftop
Solar Pv System.
Daymas Arangga – Executive Director of Energy
Watch Indonesia
Cons over MoEMR Reg. No. 2/2024 Pros over MoEMR Reg. No. 2/2024
Source: https://berkas.dpr.go.id/pusaka/files/isu_sepekan/Isu%20Sepekan---V-
PUSLIT-Februari-2024-245.pdf
A H R P L e g a l B r i e f

9. We will continue to follow the developments on this topic and provide additional information as it
becomes available. If you have any questions on this topic, please contact:
Radhitya Hawari
radhitya@ahrplaw.com
Stacia Faustine
stacia@ahrplaw.com
This publication has been prepared by AHRP for educational and informational purposes only. The information contained in this publication is not
intended and should not be construed as legal advice. Due to the rapidly changing nature of law, AHRP makes no warranty or guarantee
concerning the accuracy or completeness of this content. You should consult with an attorney to review the current status of the law and how it
applies to your circumstances before deciding to take any action.
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P: +6221 50917915
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E: office@ahrplaw.com
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Muhammad Sakti H. Tambunan
sakti@ahrplaw.com