Indonesia Establishes Verification Framework for Special-Priced Fuel Distribution to Fishing Vessels

The Ministry of Marine Affairs and Fisheries has established a verification framework for the distribution of fuel with special pricing to fishing vessels through Minister of Marine Affairs and Fisheries Decree No. 69 of 2026 (“Decree 69/2026”).

Effective from 4 September 2026, Decree 69/2026 regulates the verification of consumer eligibility and distribution volumes for special-priced fuel supplied to fishing vessels measuring more than 30 GT up to 200 GT.

The decree forms part of the broader regulatory framework for special-priced fuel for fishing vessels and complements the technical requirements governing the use and supervision of such fuel.

1. Scope of Decree 69/2026

Decree 69/2026 focuses on two aspects of special-priced fuel distribution: consumer eligibility and distribution volume.

The verification is carried out at the point of delivery and is intended to ensure that the vessels receiving special-priced fuel are eligible consumers and that the volume distributed corresponds to the applicable allocation.

The decree applies to fishing vessels above 30 GT up to 200 GT and operates within the special-pricing mechanism for fishing-vessel fuel financed through the Palm Oil Plantation Fund Management Agency (Badan Pengelola Dana Perkebunan or “BPDP”).

Accordingly, Decree 69/2026 is primarily an operational instrument for verification within the Ministry of Marine Affairs and Fisheries rather than a regulation establishing the special-pricing scheme itself.

2. Position within the Special-Priced Fuel Framework

Decree 69/2026 should be read together with the other instruments governing fuel distribution to fishing vessels.

At the energy-sector level, the special-pricing mechanism is linked to Minister of Energy and Mineral Resources Decree No. 303.K/MG.01/MEM.M/2026, which provides the framework for the supply and distribution of fuel for fishing vessels measuring 30–200 GT through a special-pricing mechanism financed by BPDP.

Within the fisheries sector, Minister of Marine Affairs and Fisheries Decree No. 54 of 2026 provides technical guidance on the use and supervision of special-priced biodiesel for fishing vessels in the same size range.

Decree 54/2026 addresses requirements at the vessel and operator level, including applicable vessel documentation, operational plans, vessel monitoring requirements and reporting of fuel utilization.

Decree 69/2026 addresses a different point in the process. It establishes the verification of consumer eligibility and distribution volume at the point of delivery.

The two decrees therefore operate alongside each other: Decree 54/2026 establishes the requirements applicable to the use and supervision of special-priced fuel, while Decree 69/2026 establishes a verification mechanism for the distribution itself.

3. Verification at the Point of Delivery

The central requirement under Decree 69/2026 is verification of the accuracy of the consumer and the volume of special-priced fuel distributed at the point of delivery.

Consumer verification is intended to establish whether the recipient is a fishing vessel falling within the relevant eligibility criteria and whether its data corresponds with the applicable allocation.

Volume verification concerns the amount of special-priced fuel delivered to each vessel and in each relevant area.

The verification is therefore not limited to the identity of the recipient. It also addresses whether the quantity distributed corresponds with the applicable allocation for the vessel and area.

This creates two related verification questions: whether the vessel is entitled to receive the special-priced fuel, and whether the amount supplied is consistent with its applicable allocation.

4. Delegation to the Directorate General of Capture Fisheries

Decree 69/2026 assigns the verification function to the Director General of Capture Fisheries, acting on behalf of the Minister of Marine Affairs and Fisheries.

The Director General is assisted by surveyors in carrying out the verification.

The surveyors are appointed and financed by BPDP in accordance with the applicable laws and regulations. This arrangement places the surveyor within the operational verification mechanism while the regulatory responsibility remains with the Directorate General of Capture Fisheries.

Decree 69/2026 further provides that the verification is conducted from the first distribution of special-priced fuel.

This means that the verification framework is intended to apply from the commencement of the special-priced fuel distribution rather than being introduced only after the distribution mechanism has been operating for a period of time.

5. Further Technical Arrangements

Decree 69/2026 authorizes the Director General of Capture Fisheries to establish further provisions concerning the implementation of the verification.

This delegation is important because Decree 69/2026 establishes the verification framework at a high operational level but does not itself set out all detailed procedures that may be required for implementation.

Further technical arrangements may therefore address matters such as the working procedures of surveyors, verification documentation, reporting arrangements and coordination among the relevant government institutions and stakeholders.

The detailed implementation should consequently be assessed against any further technical provisions issued by the Director General of Capture Fisheries.

6. Relationship with Decree 54/2026

Decree 54/2026 remains relevant to the eligibility and utilization of special-priced biodiesel by fishing vessels measuring 30–200 GT.

Among other requirements, the framework under Decree 54/2026 concerns vessel eligibility, required documentation, operational planning and monitoring of fuel utilization.

An operational plan is used to determine the vessel’s fuel requirements, taking into account factors such as engine power and operating time. The amount that may be obtained is also subject to the vessel’s remaining allocation.

Decree 69/2026 complements this framework by introducing verification at the point of delivery.

In practical terms, the special-priced fuel distribution framework therefore involves controls at different stages: eligibility and operational requirements at the vessel level, followed by verification of the recipient and volume at the point of delivery.

7. Practical Implications for Vessel Owners

Owners and operators of fishing vessels within the relevant size range should ensure that their vessel and supporting data remain consistent with the requirements applicable to special-priced fuel.

This includes maintaining the relevant vessel permits and operational documentation and ensuring that the vessel’s fuel requirements and allocation can be reconciled with the amount actually received.

The introduction of verification at the point of delivery also increases the importance of accurate distribution records. Differences between vessel data, applicable allocation and actual delivery volume may become relevant during verification.

8. Implications for Fuel Distributors

Entities distributing special-priced fuel to eligible fishing vessels should also be able to maintain reliable records of deliveries made under the special-pricing scheme.

The verification framework means that distribution volumes may be subject to verification by surveyors appointed under Decree 69/2026.

For distributors, accurate recording of the recipient vessel, delivery location and volume supplied will therefore be important for subsequent verification and reconciliation with the applicable allocation.

9. Key Takeaway

Decree 69/2026 adds a specific verification layer to the special-priced fuel framework for fishing vessels above 30 GT up to 200 GT.

Rather than regulating the entire fuel subsidy or special-pricing mechanism, the decree focuses on whether the correct vessels receive the fuel and whether the volume distributed is appropriate, with verification conducted at the point of delivery.

The Director General of Capture Fisheries is responsible for implementing the verification on behalf of the Minister, assisted by surveyors appointed and financed by BPDP. Further technical arrangements are expected to provide the operational detail necessary to implement the verification mechanism.

For vessel owners and fuel distributors, the practical focus should therefore be on maintaining consistent vessel, allocation and distribution records so that the receipt and distribution of special-priced fuel can be properly verified.

This alert is part of a series examining recent developments in Indonesia’s fisheries, energy and regulatory framework. Please feel free to contact us should you wish to discuss these developments further.

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