Terms of Reference: Coal Domestic Market Obligation Legal Consultant
Consultancy objective: ClientEarth is searching for an Indonesia-qualified lawyer who is an expert on coal Domestic Market Obligation regulation to conduct analysis and prepare, briefs memoranda, and other required research on legal, regulatory and policy issues to accelerate the country’s energy transition.
Duty station: Remote work/ international
Type and duration of contract: Consultancy contract of 1.5 months (0.6 FTE/3 days a week); 15 November 2025 to 31 December 2025
Preferred starting date: 15 November 2025
Closing date: 10 November 2025 23:59 WIB
About ClientEarth
ClientEarth is an international environmental legal organisation using the law to protect the earth and its inhabitants. We support practical solutions to the world’s toughest environmental challenges and work with people, governments and industry to make those solutions a reality. We have grown to more than 300 staff in nine offices across Europe, China, Japan and the United States.
Our approach is tailored to each region in which we operate. In Asia, we work to accelerate the region’s clean energy transition and to protect nature. We have been working in China since 2016 and, since 2020, expanded our work to Southeast Asia and Japan. Our regional team includes more than 30 law and policy experts experienced across various Asian jurisdictions. Across the region, we have also been involved in several capacity-building initiatives through training programmes, seminars and webinars in collaboration with different organisations.
In Indonesia, we work with government, the private sector and civil society to strengthen energy regulations to hasten renewable energy (RE) development and the energy transition.
Background
Indonesia remains one of the world’s largest coal producers, with coal supplying over half of the country’s total power generation. To maintain domestic energy affordability, the government enforces the Domestic Market Obligation (DMO) policy, which compels coal producers to sell to PLN, the state-owned electricity utility, at a capped price far below international benchmarks. While this mechanism stabilizes electricity tariffs for consumers and ensures energy security, it artificially suppresses the cost of coal-fired power, thereby distorting the average electricity generation cost (BPP) used as a benchmark for power purchase agreements.
As a result, renewable energy projects are placed at a structural disadvantage, as they must compete against coal prices that do not reflect true market value. The coal DMO also leads to foregone state revenues from royalties and taxes, particularly during periods of high international coal prices, limiting fiscal space for renewable energy incentives and transition financing.
A legal expert on the coal DMO industry is being sought to develop research and analyses on how Indonesia can further bring forward its energy transition programme, with a specific focus on coal DMO, while ensuring energy security and affordability in line with its economic, development and climate targets.
Education and training
· Law degree (essential), post graduate degree in energy, environmental or climate field (desirable)
· Significant experience as an Indonesia-qualified lawyer (desirable) in energy regulation, whether in private practice, government, or non-government organisation (essential)
· Significant experience in coal DMO sector regulation in private practice, public service or in an NGO (essential)
· Experience or knowledge of energy regulation and energy transition issues in Indonesia (essential)
· Experience engaging at different levels (national, local) with different groups of stakeholders (civil society organisations, think tanks, government and/or the private sector) (desirable)
· Experience or knowledge of climate, air and water pollution, and biodiversity regulation (desirable)
· Good knowledge of corporate governance and financial laws (desirable)
Key Competencies
· Fluent (CEFR level C2) in English and Bahasa Indonesia or another Indonesian language
· Excellent legal research, analysis, writing, advisory and advocacy skills
· Confident working with and analysing complex technical, scientific, political and legal material
· Excellent written and oral communication skills to influence external audiences, adapting communication style to specific audiences such as government, industry and civil society
· Able to grasp new concepts and relevant laws quickly
· An openness to learning and developing new ideas
· Able to work independently and in a team-oriented collaborative manner within a multi-disciplinary, multi-lingual and multicultural environment
· Able to work well from a distance and across different geographies and time zones with cross-cultural sensitivity
· Excellent organisation skills and ability to set priorities and manage multiple tasks and react positively in light of shifting and competing timelines
Key Deliverables
The key deliverables are:
1. High-quality research and analysis of laws, policies, technical reports and other documents on energy with a particular emphasis on coal DMO in connection to energy transition targets implementation and issues;
2. Draft and present legal inputs and advocacy/position papers, in close consultation with ClientEarth staff and other key partners, to contribute to ongoing coal DMO market regulatory reform processes in Indonesia;
3. Work closely and liaise directly with ClientEarth staff and key Indonesian and international partners to deliver on joint outputs and strategies to facilitate Indonesia’s transition to sustainable energy systems in accordance with the goals of the Paris Agreement; and
4. Any other tasks as may be reasonably required of this role.
Remuneration
There is a maximum budget of USD 10,000 (inc. UK reverse VAT and Indonesia VAT and all applicable taxes; Consultants shall pay their own applicable Indonesia taxes).
Please include your proposed daily rate and annual rate based on 0.6 FTE (3 days a week). Payment will be on a monthly basis upon receipt of accomplishment report and invoice.
Application procedure
Please send a cover letter detailing your relevant experience to demonstrate suitability for the consultancy together with your curriculum vitae to NWibowo@clientearth.org by 10 November 2025 23:59 WIB.
Please include at least two relevant written samples of past work in your submission. If co-authored, please describe your contribution to the written output. Please note that applications will be reviewed as soon as they are received.
Terms of Reference: State Losses, SOE Losses, and Directors’ Accountability and Liability
Consultancy objective: ClientEarth is searching for an Indonesia-qualified lawyer who is an expert in State-Owned Enterprise governance regulation to conduct analysis and prepare, briefs, memoranda, and other required research on legal, regulatory, and policy issues to accelerate the country’s energy transition.
Duty station: Remote work/ international
Type and duration of contract: Consultancy contract of 1.5 months (0.6 FTE/3 days a week); 15 November 2025 to 31 December 2025
Preferred starting date: 15 November 2025
Closing date: 10 November 2025 23:59 WIB
About ClientEarth
ClientEarth is an international environmental legal organisation using the law to protect the earth and its inhabitants. We support practical solutions to the world’s toughest environmental challenges and work with people, governments and industry to make those solutions a reality. We have grown to more than 300 staff in nine offices across Europe, China, Japan and the United States.
Our approach is tailored to each region in which we operate. In Asia, we work to accelerate the region’s clean energy transition and to protect nature. We have been working in China since 2016 and, since 2020, expanded our work to Southeast Asia and Japan. Our regional team includes more than 30 law and policy experts experienced across various Asian jurisdictions. Across the region, we have also been involved in several capacity-building initiatives through training programmes, seminars and webinars in collaboration with different organisations.
In Indonesia, we work with government, the private sector and civil society to strengthen energy regulations to hasten renewable energy (RE) development and the energy transition.
Background
Indonesia’s State-Owned Enterprise (SOE) governance framework has undergone a major restructuring under Law Number 1 of 2025 on Third Amendment of Law Number 19 of 2003 on State-Owned Enterprises (Law 1/2025), which establishes the sovereign wealth fund Danantara and redefines the treatment of SOE assets and liabilities. The law consolidates state capital participation under a unified holding structure, enabling Danantara to manage, invest, and leverage state assets for national development and energy transition priorities.
This raises critical legal questions regarding the distinction between state losses and SOE losses, particularly when state policy mandates affect SOE financial performance. For instance, when PLN incurs losses by complying with the government’s coal phase-out and energy transition commitments, it remains unclear to what extent such losses constitute a “state loss” under the State Finance Law and whether directors may be held personally liable.
Within this context, clarifying PLN’s “special assignment” (penugasan khusus) as the national electricity supplier is essential to ensure that actions taken in alignment with government climate policies are recognized as public mandates rather than commercial missteps. Doing so would help enable PLN’s board and directors to meet national climate targets under Indonesia’s energy transition agenda and Danantara’s investment mandate without threat of undue liability, while maintaining accountability, transparency, and compliance.
A legal expert on the State Losses, SOE Losses, and Directors’ Accountability and Liability is being sought to develop research and analyses on how Indonesia can further bring forward its energy transition within the legal and regulatory framework governing PLN.
Education and training
· Law degree (essential), post graduate degree in energy, environmental or climate field (desirable)
· Significant experience as an Indonesia-qualified lawyer (desirable) in energy regulation, whether in private practice, government, or non-government organisation (essential)
· Significant experience in SOE governance regulation in private practice, public service or in an NGO (essential)
· Experience or knowledge of energy regulation and energy transition issues in Indonesia (essential)
· Good knowledge of corporate governance and financial laws (desirable)
· Experience engaging at different levels (national, local) with different groups of stakeholders (civil society organisations, think tanks, government and/or the private sector) (desirable)
· Experience or knowledge of climate, air and water pollution, and biodiversity regulation (desirable)
Key Competencies
· Fluent (CEFR level C2) in English and Bahasa Indonesia or another Indonesian language
· Excellent legal research, analysis, writing, advisory and advocacy skills
· Confident working with and analysing complex technical, scientific, political and legal material
· Excellent written and oral communication skills to influence external audiences, adapting communication style to specific audiences such as government, industry and civil society
· Able to grasp new concepts and relevant laws quickly
· An openness to learning and developing new ideas
· Able to work independently and in a team-oriented collaborative manner within a multi-disciplinary, multi-lingual and multicultural environment
· Able to work well from a distance and across different geographies and time zones with cross-cultural sensitivity
· Excellent organisation skills and ability to set priorities and manage multiple tasks and react positively in light of shifting and competing timelines
Key Deliverables
The key deliverables are:
1. Research on and analyse laws, policies, technical reports and other documents on energy with a particular emphasis on State Losses, State-Owned Enterprise (SOE) Losses, and Directors’ Accountability and Liability in connection to energy transition targets implementation;
2. Conduct high-quality research on energy with a particular emphasis on State Losses, State-Owned Enterprise (SOE) Losses, and Directors’ Accountability and Liability, including energy transition issues;
3. Draft and present legal inputs and advocacy/position papers, in close consultation with ClientEarth staff and other key partners;
4. Work closely and liaise directly with ClientEarth staff and key Indonesia and international partners to deliver on joint outputs and strategies to facilitate Indonesia’s transition to sustainable energy systems in accordance with the goals of the Paris Agreement; and
5. Any other tasks as may be reasonably required of this role.
Remuneration
There is a maximum budget of USD 10,000 (including UK reverse VAT and Indonesia VAT and all applicable taxes; Consultants shall pay their own applicable Indonesia taxes).
Please include your proposed daily rate and annual rate based on 0.6 FTE (3 days a week). Payment will be on a monthly basis upon receipt of accomplishment report and invoice.
Application procedure
Please send a cover letter detailing your relevant experience to demonstrate suitability for the consultancy together with your curriculum vitae to NWibowo@clientearth.org by 10 November 2025 23:59 WIB.
Please include at least two relevant written samples of past work in your submission. If co-authored, please describe your contribution to the written output. Please note that applications will be reviewed as soon as they are received.
Terms of Reference: On-Grid Electricity Infrastructure and PPA Legal Consultant
Consultancy objective: ClientEarth is searching for an Indonesia-qualified lawyer who is an expert in on-grid electricity infrastructure and PPA regulation to conduct analysis and prepare, briefs, memoranda, and other required research on legal, regulatory and policy issues to accelerate the country’s energy transition.
Duty station: Remote work/ international
Type and duration of contract: Consultancy contract of 1.5 months (0.6 FTE/3 days a week); 15 November 2025 to 31 December 2025
Preferred starting date: 15 November 2025
Closing date: 10 November 2025 23:59 WIB
About ClientEarth
ClientEarth is an international environmental legal organisation using the law to protect the earth and its inhabitants. We support practical solutions to the world’s toughest environmental challenges and work with people, governments and industry to make those solutions a reality. We have grown to more than 300 staff in nine offices across Europe, China, Japan and the United States.
Our approach is tailored to each region in which we operate. In Asia, we work to accelerate the region’s clean energy transition and to protect nature. We have been working in China since 2016 and, since 2020, expanded our work to Southeast Asia and Japan. Our regional team includes more than 30 law and policy experts experienced across various Asian jurisdictions. Across the region, we have also been involved in several capacity-building initiatives through training programmes, seminars and webinars in collaboration with different organisations.
In Indonesia, we work with government, the private sector and civil society to strengthen energy regulations to hasten renewable energy (RE) development and the energy transition.
Background
The 2025-2034 Electricity Supply Business Plan as published by Ministry of Energy and Mineral Resources in May 2025 outlines the energy transition agenda through the Acceleration of Renewable Energy Development (ARED) program targeting 42.6 GW of new on-grid renewables. To implement this target, PLN as the State-Owned Enterprise assigned to carry out the Electricity Supply Business Plan (RUPTL), will need to will need to establish a comprehensive procurement framework to guide renewable energy project development. This framework is expected to define clear rules for project tendering, selection, and contracting, ensuring transparency, cost competitiveness, and alignment with Indonesia’s broader energy transition goals.
A legal expert on the electricity infrastructure industry is being sought to develop research and analyses on how the comprehensive procurement framework and rules could attract and enable renewable energy
investment whilst addressing regulatory barriers in the said framework that could disincentive new green projects.
Education and training
· Law degree (essential), post graduate degree in energy, environmental or climate field (desirable)
· Significant experience as an Indonesia-qualified lawyer (desirable) in energy regulation, whether in private practice, government, or non-government organisation (essential)
· Significant experience in electricity infrastructure and PPA regulation in private practice, public service or in an NGO (essential)
· Experience or knowledge of energy regulation and energy transition issues in Indonesia (essential)
· Good knowledge of corporate governance and financial laws (desirable)
· Experience engaging at different levels (national, local) with different groups of stakeholders (civil society organisations, think tanks, government and/or the private sector) (desirable)
· Experience or knowledge of climate, air and water pollution, and biodiversity regulation (desirable)
Key Competencies
· Fluent (CEFR level C2) in English and Bahasa Indonesia or another Indonesian language
· Excellent legal research, analysis, writing, advisory and advocacy skills
· Confident working with and analysing complex technical, scientific, political and legal material
· Excellent written and oral communication skills to influence external audiences, adapting communication style to specific audiences such as government, industry and civil society
· Able to grasp new concepts and relevant laws quickly
· An openness to learning and developing new ideas
· Able to work independently and in a team-oriented collaborative manner within a multi-disciplinary, multi-lingual and multicultural environment
· Able to work well from a distance and across different geographies and time zones with cross-cultural sensitivity
· Excellent organisation skills and ability to set priorities and manage multiple tasks and react positively in light of shifting and competing timelines
Key Deliverables
The key deliverables are:
1. High-quality research and analysis of laws, policies, technical reports and other documents on energy with a particular emphasis on on-grid electricity infrastructure, PPA and renewable energy procurement in connection to energy transition targets implementation;
2. Draft and present legal inputs and advocacy/position papers, in close consultation with ClientEarth staff and other key partners;
3. Work closely and liaise directly with ClientEarth staff and key Indonesia and international partners to deliver on joint outputs and strategies to facilitate Indonesia’s transition to sustainable energy systems in accordance with the goals of the Paris Agreement; and
4. Any other tasks as may be reasonably required of this role.
Remuneration
There is a maximum budget of USD 10,000 (including UK reverse VAT and Indonesia VAT and all applicable taxes; Consultants shall pay their own applicable Indonesia taxes).
Please include your proposed daily rate and annual rate based on 0.6 FTE (3 days a week). Payment will be on a monthly basis upon receipt of accomplishment report and invoice.
Application procedure
Please send a cover letter detailing your relevant experience to demonstrate suitability for the consultancy together with your curriculum vitae to NWibowo@clientearth.org by 10 November 2025 23:59 WIB.
Please include at least two relevant written samples of past work in your submission. If co-authored, please describe your contribution to the written output. Please note that applications will be reviewed as soon as they are received.