| |



In 2022, the Government of Indonesia through the Minister of Energy and Mineral Resources (“ MEMR ”) is targeting as many as 1,000 (one thousand) units of fuel-based motorcycles to be converted into electric-powered motorcycles. This is in view of Indonesia’s commitment to controlling climate change, with a target of reducing carbon emissions or known as the Nationally Determined Contribution (“ NDC ”) by 29% (twenty nine percent) in 2030. As an effort to support this commitment, the State Electricity Company ( Perusahaan Listrik Negara , “ PLN ”) (Persero) is preparing to provide electric vehicle charging infrastructure, one of which is the Public Electric Vehicle Charging ( Stasiun Pengisian Kendaraan Listrik Umum, SPKLU ”). A total of 580 (five hundred and eighty) units SPKLU is targeted to be utilized by electric vehicle owners in the country. This number is an increase compared to the realization of the SPKLU in 2021 in which as many as 190 (one hundred and ninety) units have been built. 


PLN is committed to accelerating the use of electric vehicles by providing electricity infrastructure through SPKLU, Public Electric Battery Vehicle Replacement ( Stasiun Penukaran Baterai Kendaraan Listrik Umum, SPBKLU ”) and Home Charging Stations by providing many incentives such as additional electricity discounts for electric vehicle owners and also 30% (thirty percent) discount on electricity consumption at night. To smooth this plan, the MEMR seeks to facilitate the licensing process related to Electric Vehicle Charging Infrastructure.


A. Regulation of Electric Vehicle Charging Infrastructure 

Initially, Electric Vehicle Charging Infrastructure is stipulated under Presidential Regulation Number 55 of 2019 on the Acceleration of the Battery-Based Electric Motorized Vehicle Program for Road Transportation (“ PR 55/2019 ”). Some key points contained under PR 55/2019 are provided as follows: 

  1. Facilities Provided
    • Charging facilities; and/or
    • Battery swap facilities
  2. Charging Station
    Charging Station is 100% (one hundred percent) open for foreign investment ownership
  3. Environmental Protection
    Battery waste must be handled by recycling and/or through management carried out by domestic companies of Battery Electric Vehicles (“ BEV ”) with specific licenses.
  4. Building Contractor
    1. State-Owned Enterprises (“ Badan Usaha Milik Negara , “ BUMN ”) and/or
    2. Other business entities  

      However, for the initial stage, PLN will be assigned as the contractor, in which PLN may cooperate with BUMN or other business entities. Furthermore, the sale of electricity shall be conducted by the holder of business license for the supply of electricity that :

      1. owns business locations; and/or
      2. owns business locations, and cooperate with BUMN or other business entities.
  5. Location for Installation
    • Public Fuel Pump Stations (“ SPBU ”)
    • Gas Pump Stations (“ SPBG ”)
    • Central and Regional Government Offices
    • Shopping centers
    • Public parking by the roads
    • Residences particularly for private electricity 

Regulation of the MEMR Number 13 of 2020 on Provision of Electric Charging Infrastructure for Battery-Based Electric Motorized Vehicles ( Kendaraan Bermotor Listrik Berbasis Baterai , “ KBLBB ”) (“ MR 13/2020 ”) regulates business schemes and business permits for SPKLU and SPBKLU Business Entities, as follows:


  1. SPKLU Business Entity
    Infrastructure Development by SPKLU Business Entities is carried out based on the provider scheme, retailer scheme, and cooperation scheme. Business actors need an SPKLU or SPBKLU identity number and permit to carry out the schemes.

    1. In the provider scheme, the provider generates its own electricity and then sells it to KBLBB consumers where the provider is required to have a business area determination, an Integrated Electricity Supply Business Permit ( Izin Usaha Penyediaan Tenaga Listrik , “ IUPTL Terintegrasi/Intergrated IUPTL ”) and an SPKLU identity number.
    2. In the retailer scheme, the electricity seller buys electricity from PT PLN (Persero) or other business area holders and then sells it on behalf of its own business entity. This scheme requires a business area determination, an Electricity Supply Business for sales Permit ( Izin Usaha Penyediaan Tenaga Listrik , “ IUPTL Penjualan/ IUPTL for sales ”), and an SPKLU identity number.
    3. In the cooperation scheme, a business entity as a partner of PLN or other business area holders is only required to have an SPKLU identity number. Meanwhile, other permit requirements are sufficient with permits owned by PLN or other business area holders.
  2. SPBKLU Business Entity
    Business entities intending to run SPBKLU are only required to have an SPBKLU identity number Tipe SPKLU More details of business schemes are described in table as follows:

    Furthermore, licensing for the development of SPKLU and SPBKLU is facilitated under Regulation of the MEMR Number 5 of 2021 on Standards for Business Activities and Products in the Implementation of Risk-Based Business Licensing for the Energy and Mineral Resources Sector (“ MR 5/2021 ”), which required a recommendation from the regional government for the determination of SPKLU business areas. Now, that recommendation can be replaced with a document of proof of SPKLU land ownership or a cooperation agreement with SPKLU land owners.


Read More: Domestic Market Obligation (DMO) And Its Role In Securing Domestic Coal Supply

B. Establishment of System Integration 

Over time, KBLBB technology and electric vehicle infrastructure continue to develop, including the development of batteries, charging systems and processing management, most of which are done online. The Online Single Submission Risk-Based Business Licensing System (“ OSS PBBR ”) will also be entirely integrated with the ESDM licensing application so as to provide convenience for business entities in the licensing process. The MEMR is preparing an integrator information system for SPKLU and SPBKLU so that later it can facilitate SPKLU and SPBKLU business entities to have access to information and permits, and at the same time facilitate the monitoring of related ministries or institutions. 


This system is still being perfected. For the time being, permits for non-standard Indonesian Business Field Classification ( Klasifikasi Baku Lapangan Usaha Indonesia, KBLI ”), especially the determination of business areas and SPKLU and SPBKLU identification numbers are still being carried out outside the OSS PBBR, or through the ESDM business and operational licensing applications.



ADCO Law earns the trust to represent clients from multinational companies to emerging entities across a wide range of industries to achieve their business objectives in Indonesia.


ADCO Law as a Law Firm in Jakarta assists the clients to structure, organize and implement their business ventures and investments, including structuring, financing, and securing investments as well as establishing new foreign companies in Indonesia. 


Should you have more queries regarding this matter, please do not hesitate to contact us


Setiabudi Building 2, 2nd Floor, Suite 205C

Jl. H.R. Rasuna Said Kav. 62, Setiabudi Karet

Jakarta Selatan, 12920, Indonesia.

Phone : +6221 520 3034

Fax : +6221 520 3035

Email : inquiry@adcolaw.com

Disclaimer: This article has been prepared for scientific reading and marketing purposes only from ADCO Law. Accordingly, all the writings contained herein do not constitute the formal legal opinion of ADCO Law. Therefore, ADCO Law should be held harmless of and/or cannot be held responsible for anything performed by entities who use this writing outside the purposes of ADCO Law.