Indonesia Makes Quantity Assurance SNI Mandatory for Upstream Oil and Gas Activities

Indonesia has introduced a mandatory national standard for quantity assurance in upstream oil and gas activities through Minister of Energy and Mineral Resources Regulation No. 11 of 2026 (“MEMR Regulation 11/2026”).

The regulation requires upstream oil and gas activities to apply the Quantity Assurance System Standard, based on SNI 9040:2021, in the presentation of quantity data throughout the production process. The framework is intended to strengthen accountability and transparency in quantity data through standardized flow systems, quality control, competent personnel and regulatory oversight.

1. Mandatory Application of the Quantity Assurance Standard

MEMR Regulation 11/2026 makes the Quantity Assurance System Standard mandatory for upstream oil and gas activities.

The standard applies to the presentation of quantity data generated through a Flow System covering the production process from the subsurface through the relevant delivery and/or processing points.

The regulation therefore moves the Quantity Assurance System from a voluntary technical standard into a mandatory requirement for the relevant upstream activities.

For contractors, the requirement applies to the presentation of quantity data at each stage of oil and gas production. The data must be generated from a Flow System that has implemented the Quantity Assurance System Standard.

2. Scope of the Quantity Assurance System

The regulation defines the Quantity Assurance System as a management system designed to ensure the reliability of Quantity Assurance statements.

Quantity Assurance itself adopts a planned and systematic approach to establishing accountability for information concerning the quantity of an economic product, including through internal controls and verification and validation of the reasonableness of the data.

The applicable technical standard is SNI 9040:2021 on the Quantity Assurance System for Accountability and Transparency of Quantity Flow in the Oil and Gas Sub-Sector, including any subsequent amendments to the standard.

The framework therefore covers more than the final reporting of production figures. The Quantity Assurance System is intended to form part of the management and control of quantity flows throughout the relevant production process.

3. Obligations of Upstream Contractors

Contractors are required to apply the Quantity Assurance System Standard when presenting quantity data at each stage of oil and gas production.

The data must be presented regularly in accordance with the applicable laws and regulations and must originate from a Flow System that has implemented the required standard.

Contractors must also ensure that personnel involved in the presentation of quantity data have the necessary qualifications and competence in the upstream oil and gas Quantity Assurance System.

These requirements apply to contractors operating under cooperation contracts, including contractors operating under the supervision of SKK Migas and, within the relevant jurisdiction, BPMA.

The practical consequence is that Quantity Assurance becomes part of the contractor’s data management and production reporting processes rather than a separate exercise performed only after production data has been generated.

4. Independent Quality Control of Quantity Data

MEMR Regulation 11/2026 introduces an additional quality-control layer through a public service agency (Badan Layanan Umum or “BLU”) providing testing services in the oil and gas sector.

Quantity data presented by contractors must undergo quality control by the BLU in accordance with the Quantity Assurance System Standard.

The BLU is required to submit the results of its quality control to the Minister.

At the same time, the regulation requires the BLU to maintain the confidentiality of contractor data and to enter into a data confidentiality agreement with the relevant contractor.

This creates a two-sided control mechanism: quantity data is subject to independent quality control, while commercially and operationally sensitive information remains subject to confidentiality safeguards.

5. Corrective Action and Reporting

The results of the BLU’s quality control serve as a basis for evaluation and, where necessary, corrective action by the contractor.

Contractors must prepare reports on the results of their evaluation and/or corrective action and submit them to SKK Migas or BPMA annually and whenever required.

SKK Migas or BPMA then submits the relevant report to the Minister through the Director General.

The reporting structure therefore creates a defined chain from the generation of quantity data through independent quality control, contractor corrective action and government-level reporting.

6. Competency and Certification Requirements

The regulation also links implementation of the Quantity Assurance System to personnel competency.

Personnel involved in the implementation of the system must meet the applicable competency standards for upstream oil and gas activities.

The relevant competency standards are issued by a professional certification body (Lembaga Sertifikasi Profesi or “LSP”) designated by the Minister. In developing the standards, the LSP must refer to the modules and technical standards determined by the Minister.

Upon fulfillment of the applicable competency and technical standards, the LSP issues competency certificates.

For contractors, this means that compliance with the Quantity Assurance System involves not only systems and data controls but also the availability of personnel with the required technical competency.

7. Government Supervision and Non-Compliance

MEMR Regulation 11/2026 provides the Minister with supervisory authority over the implementation of the Quantity Assurance System Standard and the associated competency standards.

Supervision may be conducted through an integrated operating system, periodic contractor reporting and/or direct supervision.

The BLU may be assigned to develop the integrated operating system and conduct direct supervision.

Monitoring and evaluation are also carried out by SKK Migas and BPMA. Where a contractor does not implement the mandatory Quantity Assurance System requirements, SKK Migas or BPMA may recommend that the Minister issue a written warning.

A contractor receiving a written warning must take corrective action within 15 calendar days.

Where the contractor fails to follow up within that period, the Minister may publish the list of contractors that have not implemented the mandatory Quantity Assurance System Standard.

The framework therefore combines corrective supervision with a public disclosure mechanism for continued non-compliance.

8. Relationship with Other Mandatory Oil and Gas Standards

MEMR Regulation 11/2026 forms part of the wider use of mandatory national standards in Indonesia’s oil and gas sector.

Other regulations address mandatory standards for areas such as hydrocarbon transportation systems, gas transmission and distribution pipelines, and the safety of oil and gas installations and equipment.

MEMR Regulation 11/2026 addresses a different subject: accountability and transparency of quantity data.

Its focus is therefore not the technical safety of installations or pipelines, but the systems and controls used to ensure that quantity data generated throughout upstream oil and gas production can be presented and subjected to verification and quality control.

The different standards may consequently apply concurrently to the same upstream operation, depending on the relevant activity and equipment.

9. Practical Implications for Contractors

For upstream contractors, the regulation creates several compliance considerations.

First, contractors need to ensure that their Flow Systems used to generate quantity data are aligned with the mandatory Quantity Assurance System Standard.

Second, the personnel responsible for quantity data and Quantity Assurance activities need to meet the applicable competency requirements and obtain the required certification.

Third, contractors should be prepared for independent quality control by the designated BLU and maintain appropriate records to support the evaluation and corrective-action process.

Finally, contractors should ensure that their internal data governance and reporting processes can support the periodic reporting obligations to SKK Migas or BPMA.

These requirements make the governance of production and quantity data an increasingly structured compliance matter within upstream operations.

Conclusion

MEMR Regulation 11/2026 establishes a mandatory Quantity Assurance System framework for upstream oil and gas activities based on SNI 9040:2021.

The framework connects standardized Flow Systems, contractor reporting, independent quality control, personnel competency and government supervision. It also establishes a corrective mechanism for non-compliance, culminating in the potential publication of contractors that fail to implement the mandatory standard.

For upstream contractors, the immediate focus should be on ensuring that quantity data is generated through compliant Flow Systems, supported by competent personnel and capable of undergoing independent quality control and regulatory review.

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

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