Indonesia launched its 2035 Nationally Determined Contribution (NDC) in late October 2025 ahead of many countries that are yet to provide their updated targets, signalling a continued commitment to the Paris Agreement. This domestic policy milestone comes at a time when the climate partnership between Jakarta and Berlin is gaining momentum, evolving through several key channels. Beyond bilateral cooperation, this relationship is increasingly shaped by multilateral frameworks such as the Climate Club, where both countries work together on industrial decarbonisation. In parallel, through the EU’s Global Gateway initiative, Germany and its European partners are mobilising strategic investments in sustainable infrastructure to reinforce the Just Energy Transition Partnership (JETP) as a central pillar of support for Indonesia’s shift toward a low-carbon economy. This blog examines key aspects of Indonesia’s new NDC and explores possible ways for Germany to support the country’s climate goals.
Civil society cooperation plays an important role in navigating these developments. Germanwatch is one of several organisations actively engaged in this context, working closely with its expert partner organisations such as the Indonesian Center for Environmental Law (ICEL) and the Indonesia Research Institute for Decarbonization (IRID). The focus of this collaborative work is to open and sustain spaces for dialogue among a broad range of actors, from local communities to national and international policymakers. Building on a shared history of cooperation, including technical work on the Climate Change Performance Index (CCPI) and joint advocacy during G7 and G20 presidencies, these efforts aim to ensure that climate commitments in both Indonesia and Germany are scientifically robust and socially equitable.
Despite demonstrating ongoing commitment to climate mitigation, the 2035 NDC has been widely criticised by local experts as insufficient to align with the 1.5°C temperature goal. Under the current framework, Indonesia is projected to reach peak emissions by 2030, with a decline only occurring after 2035. ICEL notes that while the shift to a 2019 reference-year baseline improves transparency and measurability, projected emissions in 2035 remain significantly higher than 2019 levels in all scenarios, underscoring the gap between current commitments and the ambition required to meet global climate targets.
Note on terminology
Indonesia's NDC, submitted on 27 October 2025, is titled the Second Nationally Determined Contribution (SNDC), despite being the third NDC document the country has submitted to the UNFCCC and the fourth NDC document overall. The First NDC, containing 2030 emission target, was submitted in 2016 and was based on the Intended NDC published in 2015. The NDC was then updated to become the Enhanced NDC submitted in 2022, which included improved and increased relative emission targets, but still for the year 2030. Then in 2025, the SNDC was submitted, along with a new absolute emission target for 2035. This blog uses the name 2035 NDC to refer to the SNDC to avoid confusion.
Governance and implementation framework
Implementation of the new targets is likely to be impeded by a fragmented governance structure that lacks a single overarching climate law. Sectoral targets are instead coordinated through several national instruments, such as the National Electricity Supply Business Plan (RUPTL) and the yet-to-be-updated National Medium-Term Development Plan (RPJMN). The current position of the 2035 NDC within this policy framework influences both the formulation of the NDC itself and the practical implementation of its objectives.
Challenges also remain regarding the technical foundations of these policies. According to Kuki Soejachmoen of the Indonesia Research Institute for Decarbonization, ‘a key challenge is that the modelling used as the base for the 2035 NDC is not yet fully integrated across economic and emitting sectors.’ Improving this cross-sectoral integration is useful for future assessments and for supporting a cohesive national transition toward decarbonisation.
Sectoral implementation: forestry (FOLU) and energy
The role of Forestry and Other Land Use (FOLU) in the mitigation sector is more prominent in this NDC, with an annual deforestation ceiling of 300,000 hectares stated as a target to reduce emissions. The number is higher than the deforestation rates in recent years, which have been below 100,000 hectares per year. The numbers run counter to the strategy formulated in the second NDC to make Indonesia’s forests a carbon sink. ICEL highlights that the 2035 NDC’s focus on FOLU requires stronger protections for the 9.8 million hectares of natural forests in concessions and the recognition of the 33.64 million hectares of customary forests, to prevent land-based energy projects from driving further deforestation.
In the energy sector, the NDC and subsequent regulations only call for a gradual transition, with renewable energy targets of 34.3% by 2034, in contrast to President Prabowo’s July 2025 statement, in which he said that Indonesia could reach a 100% renewable energy mix as early as 2035. However, Indonesian strategies still favour Clean Coal Technology (CCT) over a complete fossil fuel phase-out. Additionally, the NDC's energy strategy includes the use of biofuel and biomass, which, without proper control, could contribute to further deforestation. A researcher from ICEL, Saffa Azzahra, identifies significant gaps in the 2035 NDC’s target to reduce emissions from the energy sector, noting that the new renewable energy trajectory is slower than previous targets and remains misaligned with the COP28 goal, as stated in the Global Stocktake outcome, to triple renewable capacity.
Just Transition and the opportunity for future ambition
The inclusion of a dedicated Just Transition section marks a significant paradigm shift in the 2035 NDC. However, Germanwatch and ICEL observe that the current narrative remains narrow, focusing predominantly on workforce issues rather than the whole-of-economy approach and ecosystem integrity discussed in UNFCCC negotiations. The 2035 NDC also states that the just transition policy is still in the preparation phase, but it needs to be linked to improvements in labour laws and other regulations that ensure social protection. To develop higher ambitions, principles of Just Transition developed as part of the JETP process must be systematically integrated and modified to cover all aspects of the transition beyond energy, across both mitigation and adaptation components, to ensure equity in renewable energy scale-up, a low-carbon economy, and the phase-out of fossil-fuel industries.
While there are gaps and room for improvement in the 2035 NDC, Indonesia still has an opportunity to update it and demonstrate greater ambition for climate action mid-cycle, as it did when updating its first NDC to the Enhanced NDC. Indonesia needs to use this opportunity to improve the NDC’s core emission modelling, shift focus back towards the heavy-emitting sector, and provide clear pathways not only for renewable energy but also to energy efficiency. This trajectory will be critical as Indonesia’s engagement at COP30 continues to underscore a reliance on FOLU-based mitigation and carbon market regulations.
Germany and the international dimension
Germany plays a pivotal role in shaping and implementing Indonesia’s climate commitments. Through the International Climate Initiative (IKI) and the NDC Partnership, Germany provides essential support for NDC planning. Both nations collaborate on critical initiatives, such as the Just Energy Transition Partnership (JETP), which directly contributes to meeting emission reduction targets. Furthermore, emerging efforts like the Tropical Forest Forever Facility (TFFF) offer promising outcomes for both climate stability and biodiversity. German institutions, specifically GIZ and KfW, have become cornerstone partners, providing the expertise and funding necessary for climate action.
For example, in June 2025, Germany and Indonesia signed a EUR 200 million policy-based loan agreement to advance Just Energy Transition (under the JETP Programme). The funding is packaged as an ‘Affordable and Sustainable Energy Transition Program’ (ASET) in order to strengthen the regulation for a clean energy transition and enhance sector governance. The programme could be seen as a continuation of Germany’s contribution to Indonesia's JETP Projects, which, according to the German Embassy in Indonesia, amounted to more than USD 1 billion as of 2024. However, it needs to be proven and controlled whether the funding already contributes to steps towards emission reduction.
Potential avenues exist for bilateral cooperation to address the identified gaps in the 2035 NDC. The NDC includes conditional targets that rely on international support, and Germany has the capacity to provide technical assistance, facilitate technology exchanges, and offer alternative financing structures. One priority area for future collaboration involves the development of Indonesia’s Climate Change Law and related regulations.
By establishing a comprehensive regulatory framework informed by scientific data and engaging in legislative exchanges with Germany, which has an established legal framework for climate change mitigation, Indonesia can develop a more structured regulatory environment. Within the changing geopolitical landscape, Germany can serve as a reliable partner, indicating that climate action based on human rights and justice remains a global focus.
