Indonesia’s Mining Reporting Mess: Why Replacing KCMI and CPI with SNI Risks Lower Reporting Standards

Government-created complexity has already pushed geologists, companies and investors back toward JORC

Indonesia spent years developing its own credible system for reporting mineral exploration results, resources and reserves.

That system was built around the Kode KCMI and the professionals recognised under it as Competent Persons Indonesia, or CPI. KCMI was intended to give Indonesia a national professional reporting code comparable to internationally recognised systems such as Australia’s JORC Code.

Indonesia’s original regulatory direction was reasonably clear. In 2015, the Directorate General of Minerals and Coal issued Regulation No. 569.K/30/DJB/2015, establishing the use of Indonesian national standards and the KCMI Code in reporting exploration results and estimating mineral and coal resources and reserves.

The concept was sensible. Indonesia would use national technical standards, while KCMI and qualified CPIs would provide the professional judgement, detailed disclosure and personal accountability behind the reported figures.

Instead of strengthening that framework, the government later added another definition of a Competent Person and another route to recognition. CPI became separated from the government-defined Competent Person, or CP.

A transitional group of 413 existing CPIs was recognised by the government in 2021. CPIs accredited later were not automatically given the same recognition.

At the same time, the government placed greater emphasis on SNI, even though SNI does not have the same international capital-market function, investor familiarity or professional reporting structure as JORC.

This is no longer merely a risk or a theoretical future outcome.

It is already happening.

Internationally financed Indonesian projects continue to describe, promote and evaluate their resources using JORC. Indonesian geologists and consultants working on transactions, fundraising and foreign investment continue to encounter JORC as the commercially relevant reporting framework. Investors and lenders ask about JORC resources and reserves, not whether a signatory appears on an Indonesian government CP list.

SNI may be required for regulatory compliance. Government CP recognition may determine whether a submission is accepted administratively. But neither has become a meaningful substitute for JORC in the international investment market.

The government has therefore created the worst possible outcome: additional Indonesian requirements without reducing reliance on a foreign standard.

Indonesia already had a workable system

KCMI was designed to govern the reporting of:

• exploration results;

• mineral resources; and

• mineral reserves.

It adopted the principles used by CRIRSCO-style reporting codes: transparency, materiality and competence.

The KCMI Code 2017 published through CRIRSCO confirms that it was developed as Indonesia’s code for reporting exploration results, mineral resources and mineral reserves.

These principles are also central to the official JORC Code. Transparency requires reports to contain sufficient information and to avoid misleading presentation.

Materiality requires the disclosure of information that investors and their professional advisers would reasonably expect to see. Competence requires responsibility to be accepted by suitably qualified and experienced professionals.

Mineral-resource and reserve estimation cannot be reduced to completing a government form. It requires professional judgement about:

• drilling quality;

• sampling;

• laboratory controls;

• geological continuity;

• density;

• estimation methodology;

• resource classification;

• mining assumptions;

• metallurgy;

• infrastructure;

• economics;

• environmental conditions; and

• other modifying factors.

A geologist experienced in coal is not automatically competent to estimate a nickel laterite resource. A resource geologist is not automatically qualified to declare a reserve dependent on mine design, processing, economics, permits and environmental obligations.

KCMI recognised this reality by connecting technical reporting to a named and accountable professional.

The system could have been improved. Assessment could have been strengthened. Administration could have been simplified. Professional discipline could have been made more visible. But its foundation was sound.

CPI was supposed to mean professional responsibility

A Competent Person Indonesia is not simply somebody with a geology or mining degree.

A CPI is expected to have relevant experience in the commodity, deposit type and activity being reported. The professional must work within the limits of that competence and accept personal responsibility for the technical information.

That responsibility is what gives a reporting code credibility. A resource figure is not reliable merely because it appears in an official document. Its credibility depends on the quality of the underlying work, the disclosure of assumptions and the competence of the person prepared to sign it.

Indonesia spent years creating this professional structure through KCMI, IAGI and PERHAPI.

Then the government built another structure on top of it.

The government created CP on top of CPI

The regulatory framework changed following Minister of Energy and Mineral Resources Decree No. 1827 K/30/MEM/2018, concerning the implementation of good mining-engineering practices.

Under the newer approach, the government developed its own definition and certification route for a Competent Person, abbreviated as CP.

The names are almost identical:

• CPI: Competent Person Indonesia under the KCMI professional framework.

• CP: Competent Person recognised under the government’s statutory certification framework.

But the two titles ceased to mean the same thing.

A CPI is recognised through KCMI’s professional process.

A government CP is connected to Indonesia’s occupational competency-certification structure, involving an LSP and BNSP.

The government’s own presentation on regulations governing Competent Persons describes the separate CP certification and registration framework.

Instead of auditing, strengthening and formally recognising the system that already existed, the government introduced another credential.

This immediately created unnecessary questions:

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• Can every CPI sign a government report?

• Must a CPI also become a CP?

• Is every government CP also qualified under KCMI?

• Does CP certification test competence for the relevant commodity and deposit type?

• Will an investor accept a government CP report without a JORC or KCMI Competent Person statement?

• Which register is authoritative?

• Which standard applies to which report?

None of these questions improves the quality of geological work.

They exist because the government made a previously understandable system more complicated.

The 413-person dividing line

When the new CP structure was introduced, the statutory certification system was apparently not ready to absorb the existing CPI population.

The government therefore adopted a transitional arrangement.

Through Director General of Minerals and Coal Letter No. B-1099/MB.07/DJB.T/2021, dated 8 November 2021, a group of existing CPIs was recognised or registered under the government CP framework.

Official Minerba materials identify the original transitional group as 413 CPIs. The government’s 2023 presentation records the group registered under the 2021 letter. A 2024 Minerba presentation again refers to the original 413-person population, with later reductions resulting from deaths and record adjustments.

This is the basis for the widely repeated industry statement that only “the first 400 CPIs” are recognised.

Technically, the government does not appear to have published a rule saying that CPI registration numbers 1 through 413 were accepted and all later numbers rejected.

The reality is slightly different but no less problematic.

A particular list of 413 existing CPIs was grandfathered into government CP recognition. CPIs accredited later did not automatically receive the same status.

A temporary administrative solution became a permanent dividing line within the profession.

A valid CPI can still be unacceptable to the government

A professional accredited as a CPI after the 2021 transitional list may have:

• decades of relevant industry experience;

• passed KCMI peer assessment;

• demonstrated competence in a particular commodity;

• maintained continuing professional development;

• accepted KCMI ethical obligations; and

• become qualified to sign a KCMI report.

Yet the same person may not be accepted as a government CP without obtaining another certificate and completing another registration process.

In simple terms:

A person can be a valid CPI under Indonesia’s own KCMI Code but still be unacceptable to the Indonesian government as a CP.

That is an extraordinary outcome.

The government did not replace an inadequate system with a clearly superior one. It created two overlapping systems and failed to establish a permanent bridge between them.

The earlier group received government recognition because its members happened to be included in the transitional population.

Later CPIs must pass through another process, even where their experience and KCMI assessment are equal to or stronger than those of people in the grandfathered group.

Competence should depend on experience, knowledge, judgement and ethical standing. It should not depend on whether a name appeared on a list compiled in November 2021.

The contradiction cannot be explained away

The contradiction is straightforward.

• If KCMI recognition was sufficient for the original 413 CPIs to become government-recognised CPs, why is the same KCMI recognition insufficient for later CPIs?

• If LSP/BNSP certification is essential to protect reporting quality, why were the original 413 admitted through grandfathering rather than subjected to the supposedly essential new process?

This is not an argument that the original 413 were unqualified. They had already been assessed through KCMI. The problem is that identical professional recognition is treated differently depending on its date.

A sensible transition would have led to a permanent equivalency arrangement. It would not have created an early protected group and a later disadvantaged group. The government could have formally recognised KCMI accreditation, subject to continuing professional requirements. Alternatively, it could have introduced a focused bridging assessment applicable on equal terms.

Instead, Indonesia now has grandfathered CPs, later CPIs, newly certified CPs and uncertainty about the relationship between all of them.

SNI adds another layer without adding investment credibility. Useless Indonesian mining reporting standards.

SNI means Standar Nasional Indonesia.

Indonesia has national standards for reporting exploration results, mineral resources and reserves. BSN lists SNI 4726:2019, confirmed in 2026, as the national guideline for mineral exploration results, resources and reserves. Such a standard has an administrative role. The government needs consistent terminology, forms, classifications and databases. But SNI is not automatically an investment reporting code.

It does not obtain (any) international capital-market credibility merely because the Indonesian government requires it.

Investors do not allocate capital based on national pride. They use frameworks that their technical advisers understand, that their investment committees recognise and that allow meaningful comparison between projects and jurisdictions.

For serious international investment decisions, SNI carries little standalone weight.

A foreign investor does not ordinarily begin by asking whether a project has an SNI resource.

The investor asks:

• Is there a JORC resource?

• Who is the Competent Person?

• What relevant experience does that person have?

• What drilling supports the estimate?

• Are the sampling and quality controls reliable?

• How was geological continuity demonstrated?

• What assumptions support economic extraction?

• What modifying factors support the reserve?

• Can an independent technical adviser verify the work?

Calling an estimate SNI-compliant does not answer those questions.

Nor does stating that the report was signed by a government-recognised CP automatically satisfy an investor who does not know the certification system, its assessment depth or its relationship to deposit-specific professional competence.

For the international capital market, SNI and CP are local regulatory concepts. They are not replacements for an internationally recognised reporting and professional-accountability framework. Indonesia mining reporting standards have become increasingly fragmented as SNI, KCMI, CPI, government CP recognition and JORC now overlap without a clear and consistent hierarchy.

The return to JORC is already happening

The return to JORC is already the commercial reality.

Indonesian projects seeking international exposure continue to report their resources and reserves under JORC. ASX-listed companies operating Indonesian projects routinely use JORC in investor presentations, market announcements and technical disclosures.

This is visible across different commodities and project stages. Indonesian coal, gold, copper and polymetallic projects have repeatedly been presented to the market through JORC resource and reserve statements.

For example, ASX disclosures have used JORC for Indonesian projects including:

• the Mamahak and Tanur Jaya coal projects;

• the Awak Mas gold project;

• the Tembang gold project;

• the Romang Island polymetallic project; and

• the Idenburg gold project.

The reason is not mysterious.

JORC is integrated into the ASX Listing Rules. Investors, analysts, technical consultants and lenders know what it means. They understand the classifications, Competent Person requirements and expected disclosures.

JORC is not used because it is foreign.

It is used because it is consistent, recognised and commercially functional.

By contrast, an Indonesian company relying only on SNI and a government CP would still need to explain those concepts to every foreign investor, lender and technical adviser.

In many cases, the investor would then request a JORC report anyway.

No serious investor bases a decision on SNI alone

SNI may be mandatory for an Indonesian filing. That does not make it the standard on which serious investors base capital decisions. A government can mandate a document. It cannot mandate market confidence. Investors care about whether a resource or reserve estimate can survive technical due diligence. They care about whether the information is sufficiently detailed, whether the signatory has relevant experience and whether the terminology is comparable with other investment opportunities.

JORC already provides that shared language.

SNI does not have the same international recognition. Government CP registration does not have the same commercial meaning as a JORC Competent Person statement.

This is why companies increasingly face a two-report reality:

• an SNI-based submission for the regulator; and

• a JORC report for investors, lenders, buyers and transaction advisers.

In some cases KCMI may also remain relevant, producing a third reporting layer.

The practical structure therefore becomes:

1. SNI for government compliance;

2. CP registration for acceptance of the signatory;

3. KCMI where Indonesian professional reporting remains relevant; and

4. JORC for the market and the people providing capital.

That is not regulatory improvement.

It is duplication institutionalised.

Government policy has weakened KCMI

KCMI should have been Indonesia’s internationally credible national code.

Indonesia is recognised within the CRIRSCO reporting family, and CRIRSCO publishes KCMI as Indonesia’s reporting code. CRIRSCO explains that its member standards, including JORC and KCMI, are used internationally for market-related reporting and financial investment.

Instead of using that position as a foundation, the government weakened it by separating CPI from CP.

• If CPI recognition no longer determines whether a person can sign an accepted regulatory report, the practical value of CPI status is reduced.

• If the government accepts only a historical grandfathered CPI population or demands an additional certificate from later CPIs, companies naturally begin to question why they should rely on KCMI at all.

KCMI has consequently been squeezed from both sides:

• government administration favours SNI and its own CP structure; while

• investors and international markets favour JORC.

This leaves KCMI in the worst possible position. It is weakened domestically without being replaced internationally. The Indonesian government has therefore achieved the opposite of what a national-standard policy should accomplish. It has not made Indonesia less dependent on foreign standards. It has made JORC more necessary (again) - even more.

Complexity without technical value

None of this regulatory complexity improves the underlying geology.

1. It does not produce better drilling.

2. It does not improve core recovery.

3. It does not prevent sampling bias.

4. It does not improve laboratory quality control.

5. It does not create more reliable geological domains.

6. It does not improve variography, interpolation or classification.

7. It does not produce better mine plans.

8. It does not make metallurgical assumptions more realistic.

9. It does not strengthen project economics.

10. It merely adds uncertainty about which professional title, certificate, list and reporting format must be used.

A geologist may be professionally accepted as a CPI but administratively rejected as a CP.

A government-recognised CP may be able to sign an SNI submission but still lack the market standing required for an investor-facing JORC report.

A company may comply fully with government requirements and still need to commission another report before approaching international capital.

Every additional layer consumes time and money without necessarily improving the reliability of the resource or reserve estimate.

What should have happened

The government should have strengthened the system Indonesia had already built.

SNI should have remained the national technical and administrative standard.

KCMI should have remained the unquestionable professional reporting code aligned with CRIRSCO principles. CPI should have remained the professional designation for people accepting responsibility under KCMI.

Where the government required statutory recognition, it should have created a transparent and permanent equivalency mechanism between CPI and CP. The 413-person transitional population should never have become a privileged group.

Later CPIs meeting the same professional requirements should have received the same recognition. Where additional legal or administrative knowledge was genuinely required, a limited bridging assessment could have addressed the gap.

One public register could have shown:

• CPI status;

• government CP status;

• commodities and deposit types;

• resource or reserve competence;

• certificate validity;

• continuing-professional-development status; and

• disciplinary restrictions.

That would have been clear, defensible and usable.

Instead, policy created a maze.

Conclusion

Indonesia spent years building KCMI and developing the CPI profession. The country had the foundations of a national reporting framework aligned with international standards and supported by professional responsibility. Government intervention then separated CPI from CP, grandfathered a closed transitional population of 413 people and left later CPIs without equivalent automatic recognition.

Greater emphasis on SNI added another layer but did not create international investor confidence. The commercial result is already visible.

SNI is used because the government requires it.

CP status matters because the government controls regulatory acceptance.

But JORC remains the standard that serious international investors, lenders, technical advisers and transaction parties understand and use.

No serious investor is likely to treat an SNI classification or government CP certificate as a substitute for internationally recognisable technical disclosure and Competent Person accountability.

The government has therefore weakened KCMI without making SNI commercially relevant. It has increased paperwork without reducing risk. It has created more credentials without creating greater confidence.

Companies now comply with Indonesian requirements for the regulator and return to JORC when money, investment or transactions are involved. That is not a future danger. It is the present outcome.

The final question is therefore not technical but institutional:

Why is policy for a specialised international industry being designed by people who appear foreign to how that industry actually works?

And why does the governing mindset so often seem to be:

Why keep it simple when it can be made complicated?