Legal development

Indonesia CCS - New Regulation on Carbon Storage

By Frédéric Draps and Norman Ibnuaji

21 February 2025

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    January 2025

    Background

    The regulatory landscape for Carbon Capture and Storage (CCS) and Carbon Capture Utilization and Storage (CCUS) activities in Indonesia is rapidly evolving. Following the enactment a year ago of President Regulation No. 14 of 2024 on the Implementation of Carbon Capture and Storage Activities (PR 14/2024) which we discussed in a previous article, the Ministry of Energy and Mineral Resources (MEMR) recently issued Regulation No. 16 of 2024 on the Organization of Carbon Storage in Carbon Storage Permit Areas (Wilayah Izin Penyimpanan Karbon or WIPK) (MEMR 16/2024). This new regulation, effective from 24 December 2024, brings much needed clarity and detail regarding certain practical aspects of CCS projects and operations in Indonesia beyond the framework existing for upstream oil & gas under production sharing contract (PSCs). 

    The chart below provides an overview of the current Indonesian CCS regulatory framework following the issuance of MEMR 16/2024:

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    In this article, we provide an overview of the new regime and requirements introduced by MEMR 16/2024 and consider the practical implications and opportunities for the implementation of CCS activities in Indonesia.

    Key Highlights of MEMR 16/2024

    The Indonesian CCS regulatory framework laid out by PR 14/2024 (which is the overarching CCS regulation) includes 2 separate regimes for the implementation of CCS activities in Indonesia: 

    1. PSC scheme for development by upstream oil and gas contractors (Contractors): Implementation of CCS activities in Oil & Gas Work Areas by Contractors1 based on the applicable PSCs. This regime is further regulated through MEMR Regulation No. 2 of 2023 on the Organization of CCS and CCUS for Upstream Oil and Gas Business Activities (MEMR 2/2023) and PTK-070/SKKIA0000/2024/S9 on the Implementation of CCS and CCUS in Oil & Gas Work Areas (PTK 070). Please click here for an overview of MEMR 2/2023 and here for our analysis of the key takeaways of PTK 070;
    2. WIPK scheme (Carbon Storage Permit Areas): Implementation of CCS activities in WIPKs which may be issued to a broad range of parties (including Contractors) by way of obtaining an Exploration Permit which can be converted into a Storage Operation Permit. 

    MEMR 16/2024 sets out detailed requirements and procedures for the implementation of CCS activities within WIPKs. Its main areas of coverage include:

    1. Determination and tendering of WIPKs;
    2. Granting of relevant permits;
    3. Management of CCS-related assets; 
    4. Carbon storage business activities, fees and royalties; and
    5. Closure of carbon storage activities.

    1) Determination and tendering of WIPKs

    1.1 WIPK Tender Team

    MEMR establishes the WIPK Tender Team (Tim Penawaran WIPK), which is tasked with providing support to the Minister (of Energy and Mineral Resources) in the preparation, determination and tendering of WIPKs.2 The WIPK Tender Team's functions are summarized below:

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    1.2 Types of WIPK

    Pursuant to PR 14/2024, WIPKs may be located in3:   

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    Business entities incorporated in Indonesia (Business Entities) or Permanent Establishments4 can propose the determination of WIPKs to MEMR5. MEMR in turn shall prepare and determine WIPKs by conducting (i) an initial risk evaluation and (ii) a review of relevant technical data on the relevant area. 

    If a proposed area is overlapping or located within an area already covered under a mining business license or an Oil & Gas Work Area, MEMR shall conduct the initial risk and technical evaluation by obtaining data from the relevant operators through data utilization cooperation or joint utilization of surface facilities.6  

    In the event that there is potential for CCS in an Oil & Gas Work Area that is not utilized for CCS activities by the Contractor, then7 any of its affiliates or a third-party Business Entity or Permanent Establishment can propose such area to MEMR to be designated as a WIPK. 

    If such area is subsequently accepted and "determined" as a WIPK by MEMR8, it may then be offered to Business Entities or Permanent Establishments through a limited selection process.

    On the other hand, WIPKs initiated and prepared by MEMR shall be procured through an auction process. 

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    In the event that a potential WIPK has been proposed in an Oil & Gas Work Area, MEMR must first confirm the relevant Contractor's interest in carrying out CCS "Injection Target Zone" (zona target injeksi or ZTI)9 exploration activities and carbon storage operations in such area before offering the area to third parties through the WIPK procurement process. The relevant Contractor has 30 days to submit its confirmation of interest to MEMR. 

    If the Contractor confirms its interest, it must then submit a business plan which among other things sets out the relevant scheme under which the CCS activities will be undertaken (i.e. either the PSC scheme or the WIPK scheme). 

    The table below sets out some of the key differences between the two schemes:

    Criteria

    PSC scheme

    WIPK scheme

    Applicants

    PSC Contractor

    Any Business Entities or Permanent Establishments fulfilling tender requirements (can include PSC Contractors)

    CCS area

    PSC Work Area

    Any suitable site/area as determined by MEMR (can be within a PSC Work Area if permitted under the WIPK scheme)

    Licensing

    Pursuant to the PSC

    WIPK Exploration Permit, Storage Operations Permit, and Carbon Transportation Permit

    CCS activities

    Conducted as a secondary activity to upstream oil & gas exploration and operation

    CCS as main business activity

    Transfer

    Participating interest in PSC can be transferred subject to notification to and approval by SKK Migas

    WIPK permits cannot be transferred

    1.3 WIPK Offered through Auction

    WIPKs will be offered through an auction if the initial risk assessment and technical evaluation of the proposed locations are carried out by MEMR or other parties appointed by MEMR.10

    Business Entities and/or Permanent Establishments (whether or not they are included in MEMR's Short List) may participate in WIPK auctions provided they fulfil the requirements set by MEMR for the relevant auction (see 1.5 below for more detail). 

    1.4 WIPK Offered through Limited Selection 

    WIPKs may also be proposed to MEMR by Business Entities or Permanent Establishments11. In such case, the WIPKs will then be offered by MEMR through a limited selection process involving the proponent of the WIPK as well as other Business Entities and/or Permanent Establishments who are included on the MEMR Short List.12 

    If within 14 working days of the submission of a proposal to determine a new WIPK, another Business Entity or Permanent Establishment submits a proposal for a WIPK that overlaps by more than 50% with the area in the first proposal, the WIPK Tender Team will evaluate both proposals to determine which entity should be considered as the proponent of the limited selection process.13 However, if the overlap is 50% or less, the respective proponents must adjust their proposal to exclude the overlapping area.14

    Proposals must include detailed information such as the area's coordinates, risk assessments (covering geological integrity and environmental impacts), technical evaluations, a work plan for ZTI exploration, and administrative documentation about the proponent. 

    The WIPK Tender Team will review and asses the proposals and, if compliant, MEMR will formally notify the applicant that it is recorded as the "proponent" of the limited selection.15

    As final step in the preparation of the limited selection process, MEMR will determine the proposed area as a WIPK area after coordination with the relevant regional government and ministries/agencies (including the Ministry of Environment and Forestry, Ministry of Agraria and Spatial Planning, and Ministry of Maritime Affairs and Fisheries).16

    MEMR Short List

    MEMR will keep a list of parties who fulfil basic requirements to be able to take part in:

    • Limited selection WIPK tenders;
    • WIPK auctions based on a reduced list of requirements and bid documents.

    The Short List will be open for new applicants no more than once a year with the registration details made available on the MEMR's website. 

    Business Entities or Permanent Establishments may apply to be included on the Short List by submitting registration documents which include: 

    • corporate documentation of the applicant; and
    • information on the experience and investment value of the applicant's businesses in the oil & gas, mining, geothermal and/or CCS sectors – this experience can include the experience and investment value of the parent company or affiliates of the applicant.

    The assessment for each application will be conducted by the WIPK Tender Team.  

    1.5 Bid requirements and Documents

    Pursuant to Article 13 of MEMR 16/2024, MEMR will prepare and issue Bid Documents for each WIPK which will be offered. 

    Parties who intend to join a WIPK tender will be required to purchase the relevant Bid Documents.17

    Bid Documents shall include at least the following information:

    (a) Procedures and timeline

    (b) Geological information and carbon storage potential (geological synopsis)

    (c) Data on the offered WIPK

    (d) Initial risk assessment

    (e) Information on land use, infrastructure, and other geospatial data available regarding the WIPK and its surroundings 

    (f) Any further information on the WIPK and the key provisions of the Exploration Permit

     

    Participants in a WIPK auction or limited selection may submit a proposal which shall include prescribed Participation Documents.18

    Participation Documents include the following:

    1. completed application form

    2. 6-year work plan and budget for ZTI exploration, which consists of a firm commitments for the first 3 years and work commitment for the latter 3 years

    3. detailed plans for geological, geophysical, and engineering activities, studies on leakage mitigation, risk assessments and environmental impacts

    4. bid guarantee

    5. statement agreeing to the WIPK tender winner determination by MEMR

    6. evidence of purchase of the Bid Document

     

    For participants who are not included on the MEMR Short List, additional submissions consisting of corporate administrative documents and proof of experience need to be made to, and processed by, MEMR to confirm their eligibility to participate in the relevant auction.

    The Participation Documents are to be submitted in digital form to the WIPK Tender Team19 within (a) 60 calendar days for auctions; or (b) 30 calendar days for limited selection, from the issuance of the Bid Documents.20 These timeframes may be extended by the Minister. 

    The WIPK Tender Team will open and evaluate the Participation Documents submitted by the respective tender participants.  Based on the result of this assessment, the WIPK Tender Team will submit the ranking order and proposed winner of the auction or limited selection to the Minister.22

    For limited selection tenders, if the proponent of the WIPK is not ranked first, it will be given a right to match the offer from the first ranked participant (in terms of the type and amount of exploration commitment which are set out in the work plan & budget included as part of the Participation Documents).23 In the event that the WIPK proponent is willing to match the highest offer and provides evidence of financial capability, the WIPK proponent may then be appointed by the Minister.24

    MEMR will announce the winner of the auction or limited selection and send a notification letter outlining the following requirements which the tender winner will need to comply with25:

    (a) Submission of a guarantee for the ZTI exploration commitment;

    (b) Fulfillment of the ZTI exploration commitments;

    (c) Using a Business Entity (either newly formed or through the appointment of an affiliate) to apply for the Exploration Permit. If the winner is a consortium, its members may form a (joint venture) Business Entity;

    (d) Submit the Exploration Permit application through the OSS online system;

    (e) Obligation to comply with the main provisions of the Exploration Permit and MEMR’s decision on the determination of the tender winner;

     

    Within 7 working days from this announcement, the tender winner must submit a letter of commitment to fulfill these requirements. If the tender winner resigns, fails to submit the commitment letter, or does not apply for the Exploration Permit on time, this will lead to them being disqualified.

     

    Bid guarantee 

    Participants to WIPK auctions or limited selections are required to submit a bid guarantee in favour of MEMR. 

    This guarantee must be equal to 100% of the Exploration Permit fee payable to MEMR and must be submitted together with the Participation Documents. The bid guarantee is valid for a period of six months from the submission date and may be extended depending on the timeline of the auction or limited selection process.26

    The bid guarantee will be:

    • disbursed by MEMR if a bidder has been disqualified;27 and
    • returned to participants if they are not selected as winners.28

     

    Performance guarantee

    The winner of the auction or limited selection is required to provide a performance guarantee for the implementation of the ZTI exploration. This guarantee must amount to the higher of 10% of the total ZTI exploration commitment or USD 1,500,00029 and be valid for three years from issuance of the Exploration Permit (and may be extended until all commitments are fulfilled).30

    If the winner fails to fulfil the commitment, the guarantee will be disbursed by MEMR31, and if all commitments are fulfilled, the guarantee will then be returned.32

    2) Permits 

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    2.1 Exploration Permit

    The tender winner of a WIPK auction or limited selection must apply for an Exploration Permit which will be issued by MEMR. The permit grants the right to conduct ZTI Exploration activities based on certain agreed exploration commitments (which were part of the proposal to MEMR made by the tender participant).33 This permit can be issued to Business Entities, Permanent Establishments, or a consortium (of Business Entities or Permanent Establishments). 

    If issued to a consortium, the following additional conditions shall apply:34

    a. each member of the consortium is to be listed in the Exploration Permit, with one of the consortium members acting as the operator; 

    b. the business entity designated as the operator must hold the largest share of the consortium’s membership; and 

    c. all members of the consortium are bound by the main requirements of the Exploration Permit and are jointly and severally liable.

    Applications must be submitted within 12 months of being declared the winner of the WIPK tender. 

    Exploration Permits are valid for 6 years, with an option for a one-time extension of up to 4 years.35 Extensions can be granted based on the performance of the permit holder, the need for further exploration, or the need for additional time to prepare the ZTI Plan for Development and Operation.36

    Exploration Permit holders must submit a detailed work plan and budget for their ZTI exploration activities within 30 days of issuance.37 This plan should include a three-year firm commitment and three-year implementation commitment for ZTI exploration, outlining key activities such as geological studies, seismic data acquisition, and well drilling, as well as safety, environmental protection, and licensing aspects.38 In the event that the firm commitment for ZTI exploration cannot be implemented in its entirety, an amendment to the ZTI exploration activity work plan would need to be made and approved by MEMR.39

    In the event that the Exploration Permit holder discovers carbon storage potential in the WIPK during the Exploration phase, it must then prepare and submit a ZTI Plan for Development and Operation to MEMR.40 Upon approval of the plan by MEMR, the Exploration Permit holder may then proceed to the Storage Operations Permit application stage.41

    2.2 Storage Operations Permit 

    The holder of an Exploration Permit shall obtain a Storage Operation Permit upon submitting an application through the OSS System and fulfilling the required administrative, technical, environmental and financial conditions.42

    The permit can be issued to a single Business Entity or a consortium of Business entities (with the same additional requirements applicable to consortia as for the Exploration Permit  - see 2.1 above)43.

    This means that Permanent Establishments (or a consortium of Permanent Establishments) are not allowed to hold a Storage Operations Permit, and as a result would have to establish a Business Entity to hold the permit.

    For carbon storage projects and operations to be given green light to proceed, the capacity of the storage area must first be certified.44 Certification is to be carried out by an independent body  appointed or determined by MEMR. The procedures for registering independent certification bodies or institutions will be determined by MEMR45 (we expect this to be set out in a further implementing regulation).

    Other features of the Storage Operations Permits are that they are: (a) non-transferable; (b) granted for an initial period of 30 years with an option for extension by up to 20 years based on a range of factors such as sustainability, project performance, and available storage capacity.46

    The Storage Operation Permit includes a range of obligations for permit holders, including:

    • Work Plan: Permit holders must submit an annual work plan outlining all carbon storage operational activities (e.g., construction, drilling, injection, monitoring) and budget plans for approval by MEMR. The first work plan must be submitted within 30 calendar days from the issuance of the Storage Operation Permit.47
    • Monitoring and Reporting: Operators are required to report periodically (every 6 months) and incidentally (in case of emergencies, accidents, or other disruptions). The procedures and format for submitting reports on the implementation of Storage Operation Permits shall be determined by MEMR (we expect this to be further regulated in an implementing regulation).48 
    • Financial Responsibility: As mentioned above in Section 1.5, WIPK tender winners must provide a financial guarantee to ensure their compliance with applicable requirements. This guarantee must be submitted before the permit is granted.49

     

    MEMR has the discretion to request revisions or reject proposals that do not meet the required standards. In cases of unforeseen circumstances, such as force majeure or technical hindrance to the CCS operations, permit holders may propose modifications to their work and budget plans. 

    Assets

    Goods and equipment purchased by Exploration or Storage Operation Permit holders in the course of carrying the CCS exploration and operations remain their property. However, upon the completion of said activities (including closure), certain assets (that are required for post-operation/decommissioning) must be transferred to the government to become state assets managed by MEMR. These assets (which include well heads, casings, and land around wells) shall be identified in the closure work plan agreed upon with the government.50 For comparison, for Contractors undertaking CCS activities under the PSC scheme, all goods and equipment purchased and used directly in the implementation of their CCS activities shall become state assets immediately upon their acquisition.

    Closure

    Carbon storage operations may close under several conditions such as when storage capacity is full, no more CO2 is injected, or unsafe conditions arise. Closure includes dismantling equipment, permanently closing wells, and recovering the location. The holder of a Storage Operations Permit must submit a closure plan that outlines the process, costs, timetable, monitoring, and risk prevention measures, to be approved and supervised by MEMR and verification by an independent verifier.51

    The closure will be considered complete upon meeting the required standards. Continuous monitoring shall then be required for a further period of 10 years post-closure to assess certain risks such as leakage or contamination. The permit holder must set aside post-operational guarantee funds for closure and monitoring, which will be managed jointly with the Directorate General of Oil and Gas.52  

    At the end of this post-closure monitoring phase, the supervision and responsibility for the WIPK area where CCS activities have been carried out will be transferred to the State as provided under PR 14/2024.

    Transportation Permit

    Business Entities or holders of a Storage Operations Permit may apply for and obtain a Transportation Permit (also issued by MEMR) which allows them to engage in carbon transportation activities using pipelines. The transportation of CO2 is undertaken from the carbon capture and/or processing facility to the injection point. This permit is valid for up to 20 years, with a possibility of a 10-year extension.53

    Key requirements include: (a) proof of compliance with environmental regulations; (b) safety standards for transportation facilities, and (c) evidence of adequate financial backing. Applicants must also provide a Carbon Transportation Agreement if they are transporting CO2 from other entities.54 

    Given the limited scope of the permit, which only appears to apply to transportation by pipelines, the applicable regime and requirements for other transportation modes (such as vessels or trucks) are not regulated under MEMR 16/2024. It is unclear whether transportation of CO2 through other modes would be regulated under existing gas transportation framework in the downstream oil & gas sector, or if further specific regulations would need to be issued. 

    3) Other important provisions 

    3.1 Carbon Storage Services and Fees

    Pursuant to Article 57 of MEMR 16/2024, holders of Storage Operations Permit may provide carbon storage services to third parties and charge a carbon storage fee for their services. The holders of Storage Operations Permit must obtain MEMR's approval of the proposed carbon storage fees by submitting an application along with supporting documents including:55  

    • source, specification, and volume of the CO2;
    • CO2 transportation method and costs from the point of delivery;
    • delivery point;
    • carbon storage fee; and
    • copy of draft carbon storage agreement.

    MEMR will impose a royalty on the carbon storage fee as non-tax state revenue. Further details on the calculation of such royalty will have to be provided by MEMR in due course as this is not regulated in MEMR 16/2024.

    3.2 Carbon Economic Value

    MEMR 16/2024 further provides that the economic value of carbon involved in the implementation of CCS can be realized further through the voluntary carbon market or other carbon markets in Indonesia or other countries, based on applicable laws and regulations.56 

    3.3 Adjustment of Emissions due to Leaks

    In the event of leakage during cross-border CO2 transport or injection and storage operations involving foreign emitters, the leaked CO2 shall not be counted in Indonesia's greenhouse gas inventory. The responsibilities and mechanisms for adjusting emissions from such leaks shall be regulated by relevant regulations and bilateral agreements between the carbon-producing and receiving countries.57

    Conclusion

    MEMR 16/2024 builds on the foundation and overarching framework provided by PR 14/2024 (which was issued just a year ago) and provides a comprehensive set of requirements and processes to support the commercial implementation of CCS activities in Indonesia. The establishment of the WIPK Tender Team and the process for determining and offering Carbon Storage Permit Areas (WIPKs) should allow proponents and MEMR to ensure the transparency and efficiency in the allocation of carbon storage opportunities across the vast Indonesian archipelago. Both the processes for WIPK auction and limited selection, along with the stringent criteria for the issuance of Exploration and Storage Operations Permits, reflect the government's commitment to applying high standards of technical, environmental, and financial performance in the allocation of the rights to implement CCS projects.

    This additional framework complements the earlier requirements introduced by PR 14/2024 and MEMR 2/2023 and should provide confidence to investors that the Indonesian Government is indeed taking CCS seriously. This is partly driven by the well-known potential of the technology to mitigate domestic emissions from hard-to-abate sectors and business activities, but also to capture new opportunities and revenue streams arising from potential international CO2 offtakes, especially from North Asian emitters, or from Singapore or other developed economies in the region who are not necessarily blessed with Indonesia's vast storage potential.

    In developing a clear, stable and attractive regulatory framework, Indonesia is walking the talk and hopes to capture investments into the sector and in the required exploration activities, storage and transportation infrastructure to give it an edge over other potential storage destinations, not least Malaysia who is also looking to develop significant storage capacity and offer CCS as a service to domestic and international emitters.

    The Indonesian Petroleum Association has welcomed the new regulation, noting that it will enhance investor confidence in the country’s CCS potential which is critical to achieving Indonesia’s Net Zero Emissions (NZE) goal while supporting economic growth.

    A remaining, but not insignificant, hurdle lies with the economic feasibility of CCS developments in countries and regions where the current carbon pricing falls significantly short of the development and operational cost of vertically integrated CCS projects and value chains. As successful developments in other pioneering industries have shown (such as renewable energy), bridging this gap initially requires a high level of government support through subsidies and other incentives (fiscal and non-fiscal). To make commercial projects viable in the short to mid-term, this would require a combination of domestic support from the Indonesian Government as well as potential additional support and incentives (or disincentives through higher carbon pricing or tax) in other emitting countries who are looking for storage capacity.

     

    Authors: Frédéric Draps, Partner / Foreign Legal Consultant; Norman Ibnuaji, Senior Associate; Rachelia Jumanti, Junior Associate.

     

    1. Article 1(29) of PR 14/2024 and Article 1(26), MEMR 16/2024 defines a Contractor as a Business Entity or Permanent Establishment determined to carry out exploration and exploitation in an Oil & Gas Work Area based on a PSC with the Special Working Unit for the Organization of Offshore Oil-and-Gas Business Activities (Satuan Kerja Khusus Pelaksana Kegiatan Usaha Hulu Minyak dan Gas Bumi or "SKK Migas") or the Aceh Migas Organizational Body (Badan Pengelola Migas Aceh BPMA").
    2. Articles 2(4)-2(5), MEMR 16/2024. 
    3. Article 9, PR 14/2024 and Article 3(4), MEMR 16/2024. 
    4. Article 1(21) of PR 14/2024 and Article 1(24) of MEMR 16/2024 define "Permanent Establishments" as business entities that are established and incorporated outside of the territory of Indonesia which carry out activities within the territory of Indonesia and are obliged to comply with the laws and regulations that are prevailing in Indonesia.
    5. Article 10, PR 14/2024 and Article 3(2), MEMR 16/2024.
    6. Article 10, PR 14/2024 and Article 3(6), MEMR 16/2024.
    7. Article 13, PR 14/2024.
    8. Article 14, PR 14/2024.
    9. Article 1(5), MEMR 16/2024 defines as a rock system in a geological formation consisting of storage zone layers, buffer zone layers, impermeable zone layers and geological traps that are able to accommodate injected CO2, safely and permanently while meeting environmental safety standards.
    10. Articles 4(3)-4(4), MEMR 16/2024.
    11. Article 5(1), MEMR 16/2024.
    12. Article 9(5), MEMR 16/2024.
    13. Article 5(3), MEMR 16/2024.
    14. Article 5(4), MEMR 16/2024.
    15. Article 6(11), MEMR 16/2024.
    16. Article 8, MEMR 16/2024.
    17. Article 14(3), MEMR 16/2024. (Note: In the event that the prospective participants form a consortium, each consortium member is required to purchase a Bid Document.)
    18. Article 15(1), MEMR 16/2024.
    19. Article 16(1), MEMR 16/2024.
    20. Article 16(2), MEMR 16/2024.
    21. Article 19-20, MEMR 16/2024.
    22. Article 23(4), MEMR 16/2024.
    23. Article 24(1), MEMR 16/2024.
    24. Article 24(3), MEMR 16/2024.
    25. Article 25, MEMR 16/2024.
    26. Articles 26(1)-(2), MEMR 16/2024.
    27. Article 26(7), MEMR 16/2024.
    28. Article 26(8), MEMR 16/2024.
    29. Article 27(1), MEMR 16/2024.
    30. Articles 27(6)-(7), MEMR 16/2024.
    31. Article 27(10), MEMR 16/2024.
    32. Article 27(12), MEMR 16/2024.
    33. Article 28 (1), MEMR 16/2024.
    34. Article 28(3), MEMR 16/2024.
    35. Article 28 (6), MEMR 16/2024.
    36. Article 28 (7), MEMR 16/2024.
    37. Article 31, MEMR 16/2024.
    38. Articles 31(4)-(5), MEMR 16/2024.
    39. Article 31(7), MEMR 16/2024.
    40. Article 37(1), MEMR 16/2024.
    41. Article 39, MEMR 16/2024.
    42. Articles 42(1)-(2), MEMR 16/2024.
    43. Article 40(2), MEMR 16/2024.
    44. Article 50, MEMR 16/2024. 
    45. Article 50(5), MEMR 16/2024.
    46. Articles 40(6)-(7), MEMR 16/2024.
    47. Article 43, MEMR 16/2024.
    48. Article 47, MEMR 16/2024.
    49. Article 49, MEMR 16/2024.
    50. Article 61, MEMR 16/2024.
    51. Articles 62-69, MEMR 16/2024.
    52. Articles 62-69, MEMR 16/2024.
    53. Article 51(4), MEMR 16/2024.
    54. Article 53(2), MEMR 16/2024.
    55. Article 57, MEMR 16/2024.
    56. Article 56, MEMR 16/2024.
    57. Article 70, MEMR 16/2024.

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    This material is current as at 10 February 2025 but does not take into account any developments to the law after that date. It is not intended to be a comprehensive review of all developments in the law and in practice, or to cover all aspects of those referred to, and does not constitute legal advice. The information provided is general in nature, and does not take into account and is not intended to apply to any specific issues or circumstances. Readers should take independent legal advice. No part of this publication may be reproduced by any process without prior written permission from Ashurst. While we use reasonable skill and care in the preparation of this material, we accept no liability for use of and reliance upon it by any person.

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