Jakarta, April 3, 2026 – On January 20, 2026, President Prabowo decided to revoke the permits of 28 companies spread across the provinces of Aceh, North Sumatra, and West Sumatra as a law enforcement response to the Sumatra Disaster. The management of the business areas from the revoked permits will be handed over to Danantara, which subsequently appointed PT. Perhutani to manage the land from 22 Forest Utilization Business Permits (PBPH), MIND ID for mining permits, and Agrinas for Plantation Business Permits. Following the revocation, Prabowo requested his administration to review the permit revocations of these companies to prevent a miscarriage of justice.

The Civil Society Coalition for Forestry Law Advocacy has 5 (five) notes regarding the revocation of the business permits of the 28 companies post-Sumatra Disaster.

1. Law Enforcement Must Prioritize Access to Information and Public Participation

It needs to be highlighted that up to this moment, there is no complete information regarding the government's Permit Revocation Decree (SK) for the 28 related companies and the forms of violations that served as the basis for these revocations.

Information transparency also includes the openness of corporate concession map overlays to provide clear information to the public as the oversight party. Without clarity regarding the location and characteristics of the affected areas, permit revocations risk operating merely on an administrative level without ensuring the improvement of governance at the field level. In fact, data serves as an objective assessment instrument for the direction of post-revocation management, including the potential for environmental recovery.

Another issue related to information transparency is that critical information regarding law enforcement, including administrative sanction decrees, is classified as exempted information by the relevant government agencies. This is stipulated in the Decree of the Secretary-General of the Ministry of Forestry No. 71/2025 concerning the Detailed List of Exempted Public Information within the Ministry of Forestry. Access to information is vital to provide space for checks and balances by the public, allowing citizens to provide comparative data that contributes to the process and quality of decisions.

2. Handing Over Land to SOEs Deviates from the Core Purpose of Permit Revocation

In administrative sanctions, permit revocation is often categorized as a reparative sanction (sanksi reparatoir) because it is aimed at halting violations and restoring their impacts to the original condition. Permit revocation should ensure that business activities do not continue and must be followed by efforts to restore the functions of the forest ecosystem.

Therefore, handing over the management of revoked permits to State-Owned Enterprises (BUMN) precisely deviates from the essence of the permit revocation itself. The government should instead return the rights and distribute the controlled lands through the agendas of Customary Forests (Hutan Adat), Social Forestry (Perhutanan Sosial), and Agrarian Reform (Reforma Agraria) to vulnerable groups (such as indigenous peoples, farmers, and local community groups) to strengthen food sovereignty and improve public welfare and the community economy.

3. Rapid Revocations Indicate a Lack of Due Process and Excessive Discretion

In principle, administrative sanctions should be applied in a tiered or gradual manner. The direct application of permit revocation sanctions indicates excessive government discretion and power in law enforcement. This issue is compounded by the lack of public information regarding the steps taken by the government prior to the permit revocations.

Furthermore, the President subsequently opened a window to correct the decision by ordering his administration to conduct an in-depth review. This demonstrates an absence of due process. This fundamental issue precisely opens up opportunities for lawsuits against the government, similar to the permit revocations in Papua and West Papua. This problem also emerges as an impact of the Job Creation Law (UU Cipta Kerja), which allows the application of administrative sanctions without going through tiered stages, including direct permit revocation.

4. Law Enforcement Must Be Accompanied by Comprehensive Recovery and Governance Improvements

Based on MADANI's preliminary analysis of 13 of the revoked PBPHs, an area of 48.4% or 287,063 Hectares still consists of forest cover, and 99,434 Hectares (16.8%) of the total revoked area is categorized under Key Biodiversity Areas (KBA), which hold significant value for the conservation of Sumatra's endemic flora and fauna. Therefore, maintaining natural forests within the revoked permit areas, restoring damaged ecosystems, and improving governance in the forest and land sectors are crucial.

The Sumatra Disaster cannot be viewed merely as an incidental event; rather, it must be placed within the context of more fundamental governance issues. Therefore, in addition to focusing on environmental recovery and impact management, the government needs to use this as momentum to conduct a comprehensive evaluation of permitting (particularly in regions with disaster-vulnerable ecosystems), implement a moratorium on new permits, and review spatial planning policies.

5. The Forestry Law Revision Must Guarantee Transparent and Recovery-Oriented Law Enforcement

The Coalition views that, in principle, the ongoing agenda for the revision of the Forestry Law—which is currently a priority national legislation program of the House of Representatives (DPR RI)—must guarantee law enforcement mechanisms that are transparent, accountable, participatory, and recovery-oriented. Restoring the functions of forest ecosystems must be the objective of forestry law enforcement in the Revision of the Forestry Law, utilizing integrated criminal, administrative, and civil law enforcement instruments. Forestry law enforcement also needs to open up space for the public to participate actively through oversight and complaints based on active public disclosure of information.

Grounded in the issues outlined above, the Civil Society Coalition for Forestry Law Advocacy urges the government to:

1. Guarantee and fulfill access to information and public participation in the law enforcement process, including by disclosing the Permit Revocation Decree (SK) of the 28 Companies to realize transparency, accountability, and legal certainty;

2. Cancel the transfer of management for the 28 revoked corporate permit areas to SOEs (BUMN), and instead carry out environmental recovery as well as the restoration of damaged forest ecosystems;

3. Uphold the due process of law in executing law enforcement;

4. Conduct a comprehensive evaluation of all permits related to natural resource management, particularly in disaster-prone areas, halt the issuance of new permits, and review spatial planning policies; and

5. Guarantee transparent, accountable, participatory, and recovery-oriented law enforcement mechanisms within the agenda of the Forestry Law Revision.

Signatories:

1. Indonesian Center for Environmental Law

2. Working Group ICCAs Indonesia

3. MADANI Berkelanjutan

4. WALHI Nasional

5. Kaoem Telapak

6. Aliansi Masyarakat Adat Nusantara

7. FIAN Indonesia

8. HuMa Indonesia

9. Jaringan Pemantau Independen Kehutanan

10. Forest Watch Indonesia

11. Sawit Watch

12. Garda Animalia

13. Konsorsium Pembaruan Agraria

14. Independent Forest Monitoring Fund

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