The Indonesian Nickel Miners Association (APNI) has raised concerns over the government's plan to revert the validity period of the Work Plan and Budget (RKAB) from three years back to one year, warning that the move could disrupt investment certainty, operational efficiency, and national economic contribution from nickel mining.

“Returning to a one-year RKAB cycle would be a step backward,” APNI Secretary General, Meidy Katrin Lengkey, said on Thursday, July 3, 2025.

“The current three-year scheme has proven effective in providing legal certainty and operational stability for both the government and businesses.”she added.

‘

According to APNI, the sheer volume of mining licenses − over 4,100 active permits nationwide − makes it impractical to process annual RKAB approvals efficiently. These include 3,996 Mining Business Permits (IUP), 15 Special Mining Business Permits (IUPK), 31 Contracts of Work (KK), and 58 Coal Mining Concession Work Agreements (PKP2B).

“With thousands of companies needing approvals every year, how can the government ensure timely evaluation without bottlenecks that delay investment and production?” Meidy asked.

APNI, therefore, offered a series of recommendations:

1. Maintain the three-year RKAB: A medium-term approval window is essential for investment planning and sustainable operations.
2. Strengthen realization-based monitoring: Rather than shortening the permit period, the government should focus on enforcing output monitoring mechanisms to match planned targets with actual production and market demand.
3. Abolish end-of-year volume revisions: The current practice of RKAB adjustments late in the year should be replaced with a more realistic system based on annual production realization to avoid over-optimistic projections.
4. Uphold Ministerial Regulation No. 10/2023: This regulation, which formalized the three-year RKAB system, should remain unchanged. Regulatory focus should shift toward enhancing compliance and monitoring.
5. Review Ministerial Decree No. 84/2023: The decree’s cap on production aligned with maximum feasibility study capacity could push companies to apply for aggressive output increases, risking overproduction amid weakening global nickel prices and rising costs.

“We believe that consistent, data-driven policies, designed in collaboration with stakeholders, are essential to safeguarding legal certainty and advancing Indonesia’s downstream nickel ambitions,” Meidy said.

APNI underscored that frequent regulatory shifts and inconsistent policymaking create uncertainty for investors. “Such volatility complicates long-term business planning, disrupts supply certainty for the downstream industry, and weakens investor confidence,” Meidy said.

To that end, APNI asked the government to ensure regulatory consistency to maintain legal certainty and a favorable investment climate; limit policy revisions to urgent, data-justified needs; and involve industry stakeholders and associations in drafting new regulations to ensure they reflect operational realities.

“Indonesia has the potential to remain a globally competitive and attractive mining investment destination,” Meidy said. “But that will only be possible if our regulatory framework is stable and investor-friendly, aligned with our national goals of downstream development and economic resilience.”

The association reiterated its support for the government’s vision of sustainable mining and industrial transformation, but emphasized that such objectives can only be achieved through predictable policies, robust oversight, and inclusive dialogue.