What Perpres 109/2025 does

Why the timing is now

• Replaces Presidential Regulation 35/2018 — the prior incineration-first regime

• Mandates non-thermal anaerobic digestion for wet and organic waste streams

• Places projects in this class within Indonesia's PSE Bioenergy + Renewable Fuels priority category

• Confirms regulatory framing: the project class exists because the regulator wanted it to

• Anchors Indonesia's broader gas-import-substitution and methane-avoidance agendas

• Indonesia has zero operating waste-to-gas AD plants today

• Malaysia operates 3 (Penang reference plant in this configuration)

• Project sponsors have MoU progress aligned with the staggered award sequence

• First-mover platform — the regulation creates the market, the deal serves it

• Single LP captures three plants before competing capital structures the market

0

3

3

Indonesia operating plants

Malaysia operating plants

SPVs in this raise — first-movers