If your company's environmental documents have been sitting with the regional agency for the past few months, there is one thing worth checking this week: whether that file is actually being processed through Amdalnet.
The question sounds administrative. The answer decides whether months of process still count, or whether you start again from zero.
What changed at the beginning of June
The Ministry of Environment issued Ministerial Instruction Number 1 of 2025, requiring the environmental document information system, Amdalnet, to be used for the entire Environmental Approval process. The instruction allowed a transition period, and that period ended on 1 June 2026.
After that date, every stage must pass through Amdalnet: screening of the document type, upload of the file, the assessment process, and issuance of the approval. There is no parallel track. Environmental documents processed outside Amdalnet are declared invalid as a basis for issuing an Environmental Approval.
That last sentence is worth reading twice.
What “invalid” actually covers
This is the part most often misunderstood. Many assume a document that has been carefully prepared, signed off by a consultant, and discussed with the technical team is automatically safe because its substance is sound.
The problem is not the substance. The problem is the route.
A document with no record in Amdalnet leaves no digital trail on which a decree can be based. However good its contents, the agency has no formal footing to issue an approval for it. What usually follows is one of two things: the file must be re-entered into the system, or the assessment restarts from the beginning.
The difference can be two to four months. For a project whose construction schedule is already locked, that is an expensive gap.
Three situations most exposed
First, documents that entered the process before June but have no decree yet. The most vulnerable group. The process began while the old practice was still tolerated, but it finishes under the new regime. If no Amdalnet entry was ever created, that file is in limbo.
Second, companies that delegated everything to a third party without system access. A surprising number of project owners have never held their own OSS or Amdalnet account. Everything is handled by someone else and reported verbally. That works until the rules change and no one can verify where the file stands.
Third, activities in the middle of amending an existing document. Amendments to an Environmental Approval follow the same rules. If the parent document is not in the system, the amendment cannot proceed either.
What you can verify yourself today
You do not need to wait for a consultant. Four things can be confirmed in half an hour:
The company's Amdalnet account. Make sure the company holds its own account rather than borrowing a consultant's. This matters now, and again every time you change providers.
The file registration number. Every document entering the system receives one. If your consultant cannot quote that number, the file most likely never really entered.
The screening result. Amdalnet screens automatically to determine whether you require AMDAL, UKL-UPL, or only SPPL. Compare that result against the document being prepared. A mismatch is far cheaper to fix now than later.
Your status in OSS. The Environmental Approval is now attached to your NIB. Open OSS and see whether the status is still pending or has moved.
Why this change is actually good news
It sounds odd in the middle of the scramble, but the policy direction makes sense.
Before a single system existed, the approval process depended heavily on local practice. Two companies with similar activities could be treated differently simply because they sat in different regencies. Timelines were hard to predict because project owners had no trail to follow.
Amdalnet closes that gap. Screening is done by the system rather than by interpretation. You can see which stage your file has reached. And because everything is recorded, “the file was misplaced” is no longer available as an explanation.
Combined with Government Regulation 28 of 2025, which allows the Environmental Approval and the Technical Approval to be submitted in parallel, the overall direction is clear: faster, provided you are on the right track. Only the adjustment period is difficult, and we are in the middle of it now.
If your file turns out to be outside the system
Do not immediately rebuild the document from scratch. In many cases the existing substance remains usable; the work is to move it onto the correct route and adjust the format to what the system requires. That is a matter of weeks, not months.
What is genuinely expensive is waiting too long in the hope that some allowance will appear. Administrative sanctions for operating without a valid Environmental Approval go beyond a warning letter: fines are calculated as a percentage of investment value, and the NIB can be locked in OSS.
If you are not sure where your company's documents stand, send us the company name and the type of activity on WhatsApp. We will help trace the status first. Checking where a file stands costs nothing, and the answer is far more useful than guessing.
Better to know now, while there is still room to fix it.
