Awaiting the NRE Bill Amid Indonesia's Second NDC Target

Leonyta Nugroho

Contributor

23 Dec 2025 · 17:51 23 December 2025 17:51 WIB 4 minutes reading time: 4 minutes 8 read

Ambitious targets (LCCP) are threatened by domestic regulatory dissonance. The absence of a law-level legal umbrella creates uncertainty for the energy transition.

Energi terbarukan di Indonesia (Source: Eco-Mantra)

Opinion Note

This opinion article was written by a contributor/columnist. The views expressed are entirely the responsibility of the author and do not necessarily represent the views of the editors.

CONTRIBUTOR PROGRAM

You can become a columnist at Legal Literacy.

Submit your legal opinion/analysis writing. If it is published, you have the opportunity to obtain a payout/honorarium in accordance with the provisions.

Submit Article Read Guidelines

Table of Contents

Realistic vs Aspirational
The 2060 Time Trap
No Legal Umbrella
What's Missing?
Conclusion

Legal Literacy - Government in documents Second Nationally Determined Contribution (SNDC) which was recently submitted to the UNFCCC, has taken a step by abandoning the speculative 2010 Business as Usual (BAU) scenario and switching to the actual 2019 emissions baseline year.

However, Indonesia's SNDC still contains a worrying reality, namely that our ambition is progressing slowly amidst a crisis that demands acceleration. If we dissect the SNDC not as a political promise, but as a strategy document, it is clear that Indonesia is playing a high-risk "waiting" game.

Realistic vs Aspirational

The main criticism of the SNDC design lies in the sharp separation of scenarios between the Current Policy Scenario (CPOS) and the Low Carbon Compatible with Paris Agreement (LCCP).

CPOS reflects what we are capable of doing with current domestic strength, while LCCP is an ideal scenario that is "compatible" with the Paris Agreement. The problem is, the gap between the two creates two contrasting future realities. LCCP projects peak emissions in 2030 and a sharp decline thereafter, but this scenario is labeled "conditional".

This means that this policy design explicitly hangs the fate of Indonesia's 1.5°C target on external factors, and this is not about the government's wrong intentions, but about risk management. By separating domestic and conditional targets so widely, we are essentially saying that climate safety is an add-on option that can only be bought if foreign aid arrives.