Your Indonesian customer has sent you an ESG questionnaire. Here is what the law requires of them — and what they need from you.
Indonesia has introduced mandatory sustainability reporting for listed companies and financial institutions through the Financial Services Authority (OJK — Otoritas Jasa Keuangan). The OJK Sustainability Roadmap and POJK 51/2017 require ESG disclosure across the financial sector, with expansion to all listed companies. Indonesia is also a major supplier nation to EU, US, Australian, and Japanese buyers — all of whom face mandatory ESG reporting obligations that extend into their Indonesian supply chains. If you supply goods or services to an Indonesian buyer, or if your Indonesian buyer supplies international markets, ESG compliance evidence is increasingly a regulatory and procurement requirement.
Key regulations in Indonesia — ESG & Sustainability Reporting Supplier Guide
OJK POJK 51/2017 — Sustainable Finance Regulation
Indonesia's Financial Services Authority (OJK) issued POJK 51/2017 requiring financial institutions, listed companies, and issuers to submit annual Sustainability Reports. The regulation requires disclosure of environmental, social, and governance performance, including supply chain sustainability. The OJK Sustainability Roadmap 2015–2024 and the updated 2021–2025 roadmap set out the phased expansion of mandatory sustainability reporting across the Indonesian economy.
IDX Sustainability Reporting Guidelines
The Indonesia Stock Exchange (IDX) requires all listed companies to publish sustainability reports aligned with GRI Standards. Reports must cover material ESG topics including environmental impact, labour practices, human rights, and supply chain management. IDX-listed companies are required to disclose their supplier assessment processes and supply chain sustainability data.
EU CSRD & CSDDD — Reach into Indonesian Suppliers
Indonesian companies that supply European buyers — particularly in textiles, palm oil, electronics, and natural resources — are already subject to ESG questionnaires driven by EU CSRD and the incoming CSDDD. The EU Deforestation Regulation (EUDR) specifically affects Indonesian palm oil and timber suppliers, requiring due diligence and traceability evidence from 2025.
EU Deforestation Regulation (EUDR)
The EU Deforestation Regulation requires companies placing palm oil, timber, soy, cocoa, coffee, cattle, rubber, and derived products on the EU market to conduct due diligence to ensure products are deforestation-free and produced in compliance with local laws. Indonesia is the world's largest palm oil producer and a major timber exporter — Indonesian suppliers in these sectors face direct and immediate compliance requirements from their EU buyers.
ISSB-Aligned Indonesian Sustainability Standards (IFRS S1 & S2)
The Indonesian Sustainability Standards Board has finalised sustainability disclosure standards based on IFRS S1 (General Requirements) and S2 (Climate-related Disclosures). Full mandatory implementation begins 1 January 2027 with a three-year transition period. Climate-related disclosures are mandatory; reporting on other sustainability topics remains voluntary initially. In January 2025, the Indonesia Stock Exchange (IDX) also launched ESG Metrics Reporting (Form E020) for listed companies, requiring structured ESG data submission. Indonesian listed companies must begin collecting sustainability data now to meet the 2027 deadline.
What this means for you as a supplier
You may not be directly regulated by all of these frameworks. But your Indonesian buyer is — and so are the international buyers in your supply chain. OJK-listed companies must disclose supply chain sustainability data. EU buyers must assess Indonesian suppliers under CSRD, CSDDD, and the EUDR. Australian buyers must assess Indonesian suppliers under the Modern Slavery Act. A non-response or a weak response increases your buyer's regulatory risk and makes you a liability in their supply chain.
Key dates
2017 onwards
OJK POJK 51/2017 — mandatory sustainability reporting for financial institutions and listed companies
Active now
IDX sustainability reporting guidelines — all listed companies must publish annual sustainability reports
Active now
EU CSRD — large EU companies must disclose supply chain sustainability data including Indonesian suppliers
Active now
EU Deforestation Regulation — Indonesian palm oil, timber, and rubber suppliers must provide deforestation-free evidence
July 2029
EU CSDDD Phase 1 — large EU companies must conduct active supply chain due diligence; Indonesian suppliers will receive structured questionnaires
2028
EU CSDDD Phase 2 — extended to companies with 3,000+ employees
Indonesia's sustainability reporting framework
Indonesia has one of the most developed sustainability reporting frameworks in Southeast Asia. The OJK's phased approach has progressively expanded mandatory sustainability disclosure from the financial sector to all listed companies. The IDX sustainability guidelines align with GRI Standards, making Indonesian company reports directly comparable with international ESG disclosures. For suppliers to Indonesian listed companies, this means your buyer's sustainability report will include supply chain data — and they need your information to complete it.
EU Deforestation Regulation — critical for Indonesian exporters
Indonesia is the world's largest producer of palm oil and a major exporter of timber, rubber, and cocoa. The EU Deforestation Regulation (EUDR) requires EU buyers of these commodities to conduct due diligence proving that products are deforestation-free and produced in compliance with Indonesian law. This is not a voluntary standard — it is a mandatory legal requirement for any EU company importing these products. Indonesian suppliers in palm oil, timber, rubber, cocoa, and coffee must be able to provide geolocation data, deforestation-free evidence, and legal compliance documentation to their EU buyers.
What your Indonesian buyer's questionnaire will ask
Environmental management and deforestation
Evidence of environmental management systems, deforestation-free sourcing (critical for palm oil, timber, rubber), and compliance with Indonesian environmental law (UUPPLH). EU buyers will require geolocation data and deforestation-free certificates.
Labour rights and decent work
Compliance with Indonesian Labour Law (UU Ketenagakerjaan), minimum wage, working hours, health and safety, and freedom of association. International buyers will reference ILO conventions and their own jurisdiction's modern slavery or supply chain due diligence laws.
Human rights due diligence
A written policy covering forced labour, child labour, and non-discrimination. Evidence that you assess your own supply chain for human rights risks. EU CSDDD buyers require documented human rights due diligence from their Indonesian suppliers.
GHG emissions and climate data
Scope 1 and Scope 2 emissions data, and increasingly Scope 3 (supply chain) emissions. OJK-listed companies and EU CSRD buyers require supply chain emissions data. Your buyer needs your emissions data to complete their own mandatory disclosure.
Supply chain traceability
Evidence of your own supplier assessment processes and traceability through your supply chain. The EUDR specifically requires geolocation data for land where commodities were produced. EU and Australian buyers require traceability through the supply chain.
Governance and anti-corruption
Anti-bribery and anti-corruption policies aligned with Indonesian law. Board oversight of ESG matters, and whistleblowing mechanisms. International buyers will reference their own jurisdiction's anti-corruption laws.
What happens if your response is inadequate
- →Your OJK-listed buyer must disclose supply chain sustainability data — a non-response from you creates a gap in their mandatory IDX sustainability report
- →EU buyers subject to the EUDR cannot place your palm oil, timber, or rubber products on the EU market without your deforestation-free evidence — a non-response means lost contracts
- →EU buyers subject to CSDDD may be required to source from suppliers who can demonstrate compliance — a non-response puts your contract at risk from July 2029
- →Australian buyers subject to the Modern Slavery Act must assess Indonesian suppliers — weak responses create reputational risk for your buyer and procurement risk for you
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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