Eight Days Before Antalya
When delegations arrive in Antalya on 9 November 2026 for the 31st Conference of the Parties to the UN Framework Convention on Climate Change, Indonesia will carry two stories that do not sit comfortably together. The first is a pitch: a credible, transparent carbon market, built on Presidential Regulation No. 110 of 2025, that can unlock international finance for forests, energy, agriculture, waste and blue carbon. The second is a question it already expects to be asked, and has publicly prepared to answer: what happened during the 2026 forest and land fire season, how much burned, how much carbon was released, and what has been done to prevent a repeat.
The Turkish Presidency has designated COP31 the “Implementation COP”, a deliberate shift from setting targets to tracking progress on the ground. That framing is unkind to delegations that arrive with announcements but without evidence. For Indonesia, the test is therefore unusually concrete. It is not whether its climate ambition sounds impressive in a plenary speech. It is whether the carbon credits it wants the world to buy are backed by landscapes that are wet, monitored and defended, and whether the fire data it presents in Antalya can survive scrutiny from neighbours who breathed the smoke.
This article sets out what Indonesia is bringing to COP31, where its case is strongest, where it is most exposed, and what a credible delegation package would look like by 20 November, when the conference closes.
What the “Implementation COP” Changes
COP31 runs from 9 to 20 November 2026 in Antalya, Türkiye, with a Leaders’ Summit scheduled for 11 to 12 November. The Presidency, led by President-Designate Murat Kurum with Australia’s Chris Bowen as President of the Negotiations, has set out principles of inclusivity, transparency, ambition, results-oriented action and international cooperation. Its Action Agenda includes, among other items, a push to raise electricity’s share of global final energy consumption to 35 percent by 2035.
The preparatory trail matters because it shows what the Presidency will reward. A Pre-COP Leaders’ Event was held in Fiji and Tuvalu from 5 to 8 October 2026, producing the Taku Pakasoa Declaration. Small island states used that platform to insist, again, that implementation is measured in metres of sea level and in finance actually disbursed, not in communiques. For a large emitter and a large forest country, that is a useful warning: at an Implementation COP, the most damaging moment is not a failed negotiation, but a credible presentation that is contradicted by satellite data within days.
Indonesia’s own second Nationally Determined Contribution, submitted in October 2025, provides the roadmap to 2035 on the way to net zero emissions by 2060 or sooner. The government has presented that pathway through the Forestry and Other Land Use (FOLU) Net Sink 2030 programme, waste and methane reductions, and industrial decarbonisation. According to figures reported from the national climate registry system (SRN PPI), total emissions across all sectors in 2024 stood at 1,495.58 million tonnes of carbon dioxide equivalent, with reductions against the baseline of 775.97 million tonnes, or 34.16 percent. A new generation of SRN PPI has operated since July 2026 as a unified platform for mitigation actions, inventories and achievements, alongside a SIGN SMART Robust system for emissions accounting. Those institutional facts are the foundation of Indonesia’s credibility claim. Whether they are sufficient depends on what they are asked to carry.
Indonesia’s Pitch: Carbon as a Gateway to Finance
The clearest statement of Indonesia’s COP31 pitch came on 12 October 2026, when Coordinating Minister for Food Zulkifli Hasan, chairing a ministerial coordination meeting on COP31 preparations, described a credible and transparent carbon market as a gateway for international financing to support climate action and national development. The sectors named were forestry and land management, energy, industry, agriculture, waste management, and marine and coastal ecosystems, including blue carbon.
The institutional scaffolding for that pitch is real. Presidential Regulation No. 110 of 2025 establishes the carbon economic value framework. A Minister of Forestry regulation, Permenhut 6/2026, regulates trade in forest carbon credits and operationalises that framework for the forestry sector. The domestic carbon exchange, operating since 2023, was reported in an OJK institutional presentation in March 2026 to have moved IDR 91.7 billion, traded 1.93 million tonnes of carbon dioxide equivalent, and expanded its user base from 24 to 151. Those are modest volumes by global standards, but they indicate a market that exists and is being governed, not merely announced.
The energy side of the pitch is equally ambitious, and equally in need of bankable detail. The government has prepared initiatives including a 100 gigawatt-peak solar programme, acceleration of waste-to-energy plants, and plans for up to 7 gigawatts of nuclear capacity, as reported in COP31 previews. State utility PLN’s Electricity Supply Business Plan for 2025 to 2034 targets an additional 69.5 gigawatts of generation capacity, roughly 76 percent of it from renewable energy integrated with advanced storage. Under the Just Energy Transition Partnership, now in its JETP 2.0 phase, a reported USD 21 billion funding commitment covers transmission, energy access, early coal retirement, hydropower and geothermal acceleration, solar and wind acceleration, and supply chain strengthening.
The Institute for Essential Services Reform (IESR), in an assessment published on 20 October 2026, welcomed that direction but identified the gap that will matter most in Antalya: bankability. IESR chief executive Fabby Tumiwa argued that Indonesia still lacks a clear electrification target to match its energy mix ambition, that a roadmap for raising the renewable share from 20 percent to 35 percent is incomplete, and that the waste crisis requires action in its own right. The government priorities discussed in coordination meetings, including the New and Renewable Energy Bill and an Equitable Climate Change Bill, address the legal framework. They do not, by themselves, make a project financeable. At COP31, investors will ask a narrower question than negotiators: which projects, at what price, with what offtake and what risk allocation, are ready to sign?
The Question Indonesia Cannot Avoid: The 2026 Fires
No part of Indonesia’s COP31 preparation has been as candid, in public, as its preparation on fires. On 14 October 2026, Irawan Asaad, Director of Climate Change Control Resource Mobilisation at the Ministry of Environment, told a discussion that forest fires and deforestation had been discussed at a ministerial-level meeting attended by seven ministers and chaired by Presidential Special Envoy for Climate and Energy Hashim Djojohadikusumo. His message was direct: this issue will certainly be one of the questions counterparts raise at COP, and Indonesia should prepare a good and comprehensive response, backed by valid data and information, covering area burned, locations affected, emissions generated, impacts on communities, measures already taken, and plans to prevent recurrence.
That candour is strategically wise, because the data are already public and will be raised by others if Indonesia does not raise them first. As set out in ICLSP’s analysis of the 2026 season, SiPongi data cited by Universitas Gadjah Mada put cumulative burned area from 2015 to 2026 at 8.35 million hectares. The Copernicus Atmosphere Monitoring Service reported 140.5 megatonnes of carbon emitted by 6 October 2026, about 13 percent of global wildfire carbon to that date. Singapore’s Pollutant Standards Index reached 192 in central Singapore on 9 October, and more than 333,000 acute respiratory infection cases were reported across seven provinces. Irawan himself acknowledged that haze had caused hundreds of thousands of respiratory cases, and that the effects were felt not only in Indonesia but in neighbouring countries.
The legal and political significance of that transparency goes beyond public relations. Under the ASEAN Agreement on Transboundary Haze Pollution, Indonesia’s obligation is framed as due diligence: what a diligent state does to prevent foreseeable transboundary harm. A delegation that arrives in Antalya with a complete, geolocated fire record, per-concession burned area, and enforcement actions taken, strengthens its due diligence case even if the season was severe. A delegation that arrives with aggregate figures and general assurances, while satellite trackers publish concession-level maps, weakens it. The fire question is therefore not a distraction from Indonesia’s carbon market pitch. It is the evidentiary foundation on which that pitch will be judged.
The Carbon Credibility Test
The connection between fires and carbon markets is direct, and it is where Indonesia’s case is most exposed. A forest carbon credit is a claim that carbon will remain stored. If the forest burns, the claim reverses. The question for buyers, regulators and corresponding-adjustment accounting under Article 6 of the Paris Agreement is whether the buffer set aside to cover reversals is large enough, and whether the governance behind the credit can detect and report a reversal honestly and quickly.
ICLSP’s 2026 fire analysis reported, from the Landscape Group tracker, that fire inside 29 of 39 Verra carbon projects released an estimated 16.7 megatonnes of carbon dioxide equivalent in 2026, equal to 45 percent of a year of their expected credits, against buffer pools covering only about one quarter of that amount. That figure is a modelled estimate, not an official statistic, and it requires confirmation project by project. But its direction is the point: if buffers are calibrated to averages from wetter years, a strong El Niño year will overwhelm them. A market that discovers that fact after credits have been sold and counted toward another country’s NDC faces a double-counting and integrity crisis, not merely a bad season.
Three credibility tests follow for any forest carbon credit Indonesia presents at COP31. First, additionality and permanence must be demonstrated on drained peat and fire-prone landscapes specifically, not on forest in general. A credit from a rewetted, monitored peat dome is a different asset from a credit from a concession where the water table is falling and no firebreak exists. Second, corresponding adjustments must be transparent: when a credit is transferred internationally under Article 6, Indonesia’s NDC accounting must reflect the transfer, so the same tonne is not counted twice. Third, community benefit must be verifiable, not asserted. Smallholders and communities who live with fire risk, and who are asked to refrain from burning for land preparation, must see a share of carbon revenue and access to mechanical clearing alternatives. A market that pays intermediaries while criminalising smallholders will fail on justice and, over time, on effectiveness, because it creates the grievance that drives ignition.
Indonesia’s domestic reforms point in the right direction on each test, but they are incomplete in the same place: disclosure. SRN PPI, SIGN SMART Robust, Permenhut 6/2026 and the carbon exchange are governance infrastructure. What COP31 needs from them is not another description of the infrastructure, but the data it produces: which projects, which reversals, which buffers, which adjustments, published in a form that an independent buyer or journalist can check.
What ASEAN Brings, and What It Does Not Settle
Indonesia does not negotiate alone. Under the Philippines’ chairmanship, ASEAN is preparing a joint statement for COP31 covering Nationally Determined Contributions, National Adaptation Plans, loss and damage, climate finance and a just energy transition. A unified ASEAN statement carries more weight than individual statements, particularly on finance access, adaptation and the special circumstances of archipelagic and coastal states.
But a joint statement does not settle Indonesia’s specific exposure. Other ASEAN members have their own carbon market frameworks: Malaysia’s National Carbon Market Policy under its Climate Change Policy 2.0, Cambodia’s work on an Article 6 registry to prevent double counting, and regional work through the ASEAN Plan of Action for Energy Cooperation and the ASEAN Power Grid. Indonesia’s contribution to that collective position will be judged on whether it offers something concrete to the region, such as a shared protocol for geolocated fire records and concession maps, or a common standard for buffer adequacy on peat. A regional fund for prevention and response, modelled on cooperative mechanisms for shared waterways, would be a credible offer. A general call for more finance, without a disclosure standard attached, would not.
A Credible Delegation Package: Five Items
If Indonesia wants to leave Antalya with finance, not merely with photographs, its delegation package should contain five verifiable items, each of which can be checked before the conference closes.
First, a complete 2026 fire account. Not a summary, but a published dataset: area burned by province and by concession, peat versus non-peat, emissions by the measure used, health impacts, and enforcement actions, including permit reviews for repeat-fire concessions. The ministerial preparation already described by Irawan points this way. Publishing it before counterparts demand it converts scrutiny into credibility.
Second, a carbon buffer disclosure. For every forest carbon project offered internationally, the buffer size, the reversal rate assumed, the observed reversal in 2026, and the remaining buffer after that season, stated plainly. If any project is under-buffered, say so and say what will be topped up, by whom, and by when. Buyers discount uncertainty more heavily than they discount a disclosed shortfall that is being fixed.
Third, a bankable project list. Not a target, but a list: project name, capacity or area, offtake arrangement, financing need, technology required, and expected outcome, for the solar, waste-to-energy, transmission and geothermal pipeline. IESR’s point about electrification targets should be answered with a roadmap that maps renewable potential, grid capacity and storage, so that a 35 percent electricity share is a plan rather than a slogan.
Fourth, a community benefit rule for carbon revenue. A stated minimum share for communities and smallholders in and around project areas, a mechanism for payment, and a commitment that mechanical land-clearing support accompanies any restriction on burning. Without that rule, Indonesia’s carbon pitch will be read, fairly or not, as a market for intermediaries.
Fifth, a peat rewetting commitment with a maintainer. Canal blocking, water-table monitoring and vegetation restoration are the fire prevention system itself. The commitment should name the institution responsible between fires, its budget, and its annual reporting obligation. The dissolution or absorption of a restoration agency without a clear successor mandate is precisely the silent degradation that becomes visible only in the next El Niño year. Naming the maintainer in Antalya would be a concrete, checkable promise.
What Success and Failure Look Like on 20 November
Success at COP31 for Indonesia will not be measured by the number of bilateral meetings held, or by the size of a headline investment figure that is not yet contracted. It will be measured by three outcomes. The first is whether forest carbon credits presented by Indonesia are treated by buyers and by Article 6 counterparts as credible enough to transact at a price that reflects permanence, rather than discounted as fire-exposed. The second is whether the fire account presented in Antalya is accepted as the authoritative record, so that the conversation moves from “what happened” to “what will be fixed”. The third is whether at least one bankable pipeline, in energy or in nature-based solutions, leaves Antalya with signed terms, not a memorandum of understanding.
Failure looks different, and it is also specific. It looks like a carbon market announcement that is met, within days, by a tracker publication showing under-buffered reversals that were not disclosed. It looks like a fire presentation that is contradicted by concession-level satellite data. And it looks like a set of energy targets without an electrification roadmap, which investors quietly set aside while praising the ambition in public. None of those failures requires bad faith. Each requires only the gap between announcement and evidence that an Implementation COP is designed to expose.
Conclusion
Indonesia arrives at COP31 with a stronger institutional story than it had a decade ago: a second NDC, a carbon economic value framework, a functioning exchange, a unified registry, and a government that has publicly prepared to answer the hardest question about its own fire season. That is a genuine asset. It is not yet a proof.
The proof will be in the package the delegation actually tables: a fire account that can be checked, buffers that can be audited, projects that can be financed, revenue rules that can be verified by the communities they are meant to benefit, and a named maintainer for the peatlands that must stay wet between fires. If that package is presented, the 2026 fire season, severe as it was, becomes the evidence that forced a change in the model, and Indonesia’s carbon market becomes a credible gateway to finance. If it is not, the next strong El Niño will produce the same season again, and the next COP will ask the same questions, with less patience.
Antalya is therefore not a stage for Indonesia to perform credibility. It is a deadline to produce it.
Sources and Notes
Carbon Credit Markets. 16th Week CCM 2026: Carbon markets advance in Asia-Pacific; Indonesia; COP31; REDD+; Verra and Article 6. 20 April 2026. OJK March 2026 presentation figures for the carbon exchange (IDR 91.7 billion, 1.93 million tCO2e, 24 to 151 users) and Permenhut 6/2026, as summarised there.
COP31 Presidency. Letter from President-Designate Murat Kurum with President of the Negotiations Chris Bowen, principles and Action Agenda, including Pre-COP in Fiji (5-8 October) and Leaders’ Summit in Antalya (11-12 November), as summarised in Carbon Credit Markets, April 2026.
ICLSP. Fire, Peat and the State: The 2026 Fire Season and the Limits of Suppression in Indonesia. 30 October 2026. https://iclsp.org/fire-peat-and-the-state-the-2026-fire-season-and-the-limits-of-suppression-in-indonesia/ . Fire figures, Verra project reversal estimate (Landscape Group, modelled, requiring project-level confirmation), and legal analysis drawn from that article.
IESR (Institute for Essential Services Reform). Indonesia Heads to COP 31: The Need to Push for Electrification and Bankability Targets. 20 October 2026. JETP 2.0 USD 21 billion commitment, five focus areas, electrification target gap, waste crisis, RUU EBET and Climate Change Bill.
Indonesia, Ministry of Environment. Statements by Minister Moh Jumhur Hidayat at the Pre-COP Leader’s Event, Fiji, 6 October 2026, as reported 7 October 2026: NDC roadmap to NZE 2060 or sooner, FOLU Net Sink 2030, waste and methane reductions, industrial decarbonisation.
Indonesia, Ministry of Environment. Statements by Irawan Asaad, Director of Climate Change Control Resource Mobilisation, 14 October 2026, as reported: ministerial preparation on fires for COP31, seven ministers, chaired by Presidential Special Envoy Hashim Djojohadikusumo, need for transparent burned area, locations, emissions, impacts and measures.
Indonesianow, via detikFinance. Indonesia Targets Investment Opportunities via Carbon Market at COP31. 13 October 2026. Coordinating Minister Zulkifli Hasan, 12 October 2026 ministerial meeting, Perpres 110/2025, sectors for green investment.
Jawawa. Beyond pledges: Indonesia prepares its climate action plan for COP31; and Indonesia Prepares Data on Forest and Land Fires Ahead of Questions at COP31 in Türkiye. October 2026. Second NDC (October 2025), SRN PPI 2024 emissions and reduction figures, SIGN SMART Robust, PLN RUPTL 2025-2034 (69.5 GW, about 76% renewables with storage), 100 GWp solar and 7 GW nuclear initiatives, COP31 as “Implementation COP”.
Southeast Asia Desk. ASEAN COP31 Climate Strategy: Regional Energy & Policy Focus. October 2026. ASEAN joint statement under Philippines chairmanship, priorities on NDCs, National Adaptation Plans, loss and damage, climate finance and just transition; member frameworks including Malaysia and Cambodia.
Note on sources: figures attributed to government statements, registry summaries and previews are reported as such in the sources cited, not independently verified against primary decree or registry texts. The Verra reversal figure is a modelled tracker estimate and requires project-level confirmation before being cited as a project fact. This article is analytical, not a negotiating brief, and should not be read as a statement of the Indonesian delegation’s position.