Why Data Centres Need an AMDAL Report Before Construction

Why Data Centres Need an AMDAL Report Before Construction

  • InCorp Editorial Team
  • 28 October 2026
  • 9 minutes reading time

A data centre project isn’t construction-ready just because land, investment, and contractors are secured. An Environmental Impact Assessment (AMDAL report) and other required approvals must also be completed before physical development begins. 

In September 2026, an AI data centre project in West Java was temporarily halted because it still lacked the required AMDAL and Building Approval (Persetujuan Bangunan Gedung/PBG). 

For data centre developers, the key issue is not only compliance but also timing. Businesses should complete the required environmental and building approvals before construction and make sure they align with the planned project scope. 

Key Takeaways

  • Data centre developers should address AMDAL and Environmental Approval during pre-construction planning, not after physical work has started. 
  • AMDAL identifies and assesses a project’s environmental impacts, while Environmental Approval is the official approval issued after the assessment process. 
  • Data centre assessments can involve important issues such as water use, electricity demand, waste, emissions, noise, and impacts on surrounding communities. 
  • PBG is separate from AMDAL and Environmental Approval, but it is another critical requirement before building construction. 
  • Incomplete approvals can stop construction and create wider project, cost, commissioning, and operational delays. 

What Needs to Be Ready Before Data Centre Construction? 

Requirement What It Means Who Issues It Why It Matters to the Project 
AMDAL Assessment of significant environmental impacts for projects that meet the applicable criteria Reviewed by the authority that issues the Environmental Approval Identifies environmental risks and the measures required to manage them 
Environmental Approval (Persetujuan Lingkungan) Formal approval obtained through the applicable environmental assessment route Regent/mayor, governor, Minister, or BP Batam, depending on project location Forms the environmental basis for the project to proceed 
PBG Approval of the building’s construction and technical requirements Regency or city government Required before building construction 
Other applicable approvals Spatial use, water, utilities, infrastructure, or specific project activities Relevant sector authority One outstanding requirement can hold back the entire development 

Why AMDAL Matters for Data Centre Development 

AMDAL is part of project readiness because data centres can have significant environmental impacts that must be assessed before construction. 

Key issues can include: 

  • Water demand for cooling 
  • Electricity use and backup power 
  • Wastewater and waste management 
  • Emissions and noise 
  • Land and community impact 

If these issues are identified too late, they can affect project design, construction schedules, costs, and operations. 

Water Demand 

Water use can affect site selection, cooling design, sourcing, and wastewater planning. In West Java, authorities specifically raised concerns about reservoir water use and its potential impact on other users. Developers should establish these early, so they are properly reflected in the AMDAL. 

Power Demand 

Data centres also require significant electricity. Power needs, backup generators, and supporting infrastructure can affect both environmental planning and project approvals. 

What Data Centre Developers Need to Get Right Before Construction 

The best time to address environmental requirements is while the project still has room to adjust. 

Confirm the Environmental Pathway and Authority Early 

Not every project follows the AMDAL route. Permen LHK No. 4/2021 determines whether an activity requires AMDAL, UKL-UPL, or SPPL, based on its type, scale, and characteristics. 

Under Permen LH/BPLH No. 22/2025, authority generally follows location: 

  • Regent or Mayor: Projects within a single regency or city. 
  • Governor: Projects spanning more than one regency or city in a province. 
  • Minister: Cross-provincial projects, National Strategic Projects, and certain high-risk activities. 
  • BP Batam: Projects within the Batam free trade zone. 

Complete the AMDAL Based on the Actual Project 

The AMDAL report should reflect the project that will actually be developed. Depending on the project, a data centre AMDAL typically needs to cover key issues. 

Issue What the Assessment Should Establish Why It Matters for Data Centres 
Water use and wastewater Water source, expected demand, use, and wastewater management Cooling demand can compete with households, agriculture, and industry 
Electricity and infrastructure Realistic operating load and supporting electrical infrastructure High-density AI workloads significantly increase power demand 
Waste and hazardous materials Construction and operational waste, batteries, fuel handling, equipment replacement Creates ongoing environmental management obligations 
Emissions and noise Backup generator emissions, cooling noise, construction traffic and dust Directly affects surrounding residents 
Communities and shared resources Impact on nearby residents, farmers, roads, and water resources Community concerns can shape approval outcomes 

If the technical project changes materially while AMDAL preparation is underway, businesses should assess whether those changes also affect environmental documentation or approvals. 

Secure Environmental Approval 

An AMDAL report and Environmental Approval are related, but not the same.  

AMDAL is an environmental impact assessment for a planned activity with environmental impacts. Environmental Approval is the formal government approval arising through the applicable environmental process. 

For project planning, businesses should therefore track both AMDAL preparation and the status of Environmental Approval. 

Coordinate PBG with the Wider Approval Timeline 

PBG is a building approval and is separate from AMDAL. Under Government Regulation No. 28 of 2025, both sit within Indonesia’s risk-based licensing framework. 

Completing the environmental work while PBG is still pending leaves the project just as unready for construction. Before contractors mobilise, the project team should know which approvals are required, who issues each one, their status, and which depend on others. 

Keep Approvals Aligned with the Planned Development 

An approval covers the project described in the application. Changes to capacity, cooling technology, water demand, buildings, utilities, or site layout should trigger a compliance review before implementation. 

This is especially important for data centres built in phases or expanding capacity over time. 

Build Approvals into the Project Schedule 

Start environmental planning during site selection and early design, not after groundbreaking. Place approval milestones in the same schedule as design, procurement, and construction, so environmental approval never becomes the constraint holding construction back. 

Planning a data centre in Indonesia? Share your site and project scope, and our team will map the environmental and building approvals you need before construction. Book a free consultation. 

What Happens When Required Approvals are Incomplete? 

The consequences can extend significantly beyond having an incomplete document. 

Construction on the West Java project began in September 2026, despite pending AMDAL and PBG approvals. The West Java Provincial Government later ordered a temporary halt until these requirements were fulfilled. 

The provincial government also clarified that the suspension was due to pending approvals, not an environmental violation by the company. 

Construction and Operations Can Be Delayed 

If required approvals are still outstanding, construction may need to stop until they are completed. This can disrupt contractor schedules, equipment deliveries, installation, testing, commissioning, and the planned operational date. 

Project Costs Can Increase 

Delays may lead to contractor standby, remobilisation, additional studies, design changes, and higher financing or procurement costs. 

Commercial Commitments Can Be Affected 

A delayed operational date can also affect customer commitments, revenue timing, and overall project returns. Therefore, treat environmental compliance as part of the critical project path, not a separate administrative task. 

Administrative Sanctions Can Apply 

Government Regulation No. 22/2021 provides environmental supervision and administrative sanctions when businesses fail to meet their environmental obligations, including after approval is granted. 

Guide to Doing Business in Jakarta

Mailchimp Free eBook Indonesia Business Insight

Get Your AMDAL Report Ready Before Construction with Ascentium 

Align the AMDAL report with your development plan before construction begins. Delays or gaps in the environmental process can affect approvals and ultimately hold up the project. 

Ascentium Indonesia supports data centre investors and developers with: 

  • AMDAL requirements and project assessment 
  • AMDAL report and environmental documentation preparation 
  • Environmental Approval support 
  • PBG and related licensing coordination 
  • Pre-construction compliance assessment 
  • Compliance review for project changes or expansions 

By aligning AMDAL and related approvals with the construction timeline, businesses can reduce approval gaps that may delay development. 

Get Ascentium’s support to prepare your AMDAL and move your data centre project towards construction. Book a free consultation by filling out the form below. * 

*T&C apply. 

Frequently Asked Questions

What is an AMDAL report?

An AMDAL report is the documentation prepared under Indonesia’s Environmental Impact Assessment (Analisis Mengenai Dampak Lingkungan) process. It assesses the significant environmental impacts of a planned business or activity and sets out how those impacts will be managed and monitored. AMDAL is an environmental assessment, not a construction permit.  

Do data centres need AMDAL in Indonesia?

Permen LHK No. 4/2021 sets the criteria for activities requiring AMDAL, UKL-UPL, or SPPL based on the project type, scale, characteristics, and location. Large data centre campuses with significant water, power, or land requirements are more likely to fall under AMDAL. Developers should confirm the correct pathway during project planning.

Should AMDAL be completed before data centre construction begins?

Yes. Where AMDAL is required, complete the assessment and obtain Environmental Approval before physical development begins.

Does an AMDAL report the same as Environmental Approval?

No. AMDAL is the assessment of a project’s significant environmental impacts. Environmental Approval (Persetujuan Lingkungan) is the government’s formal decision based on that assessment. Completing the AMDAL document does not mean the project is approved, so developers should track both as separate milestones in the project schedule. 

Who issues Environmental Approval for a data centre in Indonesia?

Under Permen LH/BPLH No. 22/2025, the authority generally depends on the project’s location. The regent or mayor approves projects within one regency or city; the governor approves projects spanning several regencies; and the Minister approves cross-provincial and National Strategic Projects. Projects in Batam fall under BP Batam. 

Is PBG part of AMDAL?

No. PBG (Persetujuan Bangunan Gedung) is a separate building approval issued by the regency or city government. AMDAL and Environmental Approval cover environmental impacts and obligations, while PBG covers the building’s technical requirements. A data centre needs both in place before construction can proceed. 

What environmental issues should a data centre AMDAL cover?

The scope depends on the project, but a data centre AMDAL typically covers water consumption, wastewater, power demand, backup generator emissions, waste and hazardous materials, noise, land impacts, supporting infrastructure, and effects on surrounding communities. These assumptions should match the actual technical design rather than be assessed separately. 

Why is water important in a data centre AMDAL?

Many data centres use water for cooling, and demand can be substantial. At full capacity, West Java is projected to draw up to 384 litres per second, raising concerns about supply for local farmers and residents. Where a project relies on shared water sources, the AMDAL must address availability, other users, and wastewater. 

What happens if data centre approvals are incomplete?

Incomplete approvals can stop construction and delay contractor schedules, installation, commissioning, and the operational date. Delays also add costs, such as contractor standby and financing costs. Government Regulation No. 22/2021 further provides administrative sanctions when businesses deviate from their environmental obligations. 

Can changes to a data centre project affect its AMDAL?

Yes. Changes to capacity, water use, cooling systems, utilities, site layout, or other material aspects of the project may affect the environmental assumptions behind existing approvals. This is especially relevant for data centres built in phases or expanding over time. Developers should assess the environmental and licensing implications before implementing a change. 

Verified by

Hotdo Nauli

Senior Legal & Delivery Manager at InCorp Indonesia

Hotdo heads the Legal and Delivery team at InCorp Indonesia, managing Product Registration, Legal Advisory, and Business Licensing. With over 8 years of experience, she focuses on compliance and integrity,... Read more

Get in touch with us.

Lead Form

What you’ll get

A prompt response to your inquiry

Knowledge for doing business from local experts

Ongoing support for your business

Disclaimer

The information is provided by PT. Cekindo Business International (“InCorp Indonesia/ we”) for general purpose only and we make no representations or warranties of any kind. We do not act as an authorized government or non-government provider for official documents and services, which is issued by the Government of the Republic of Indonesia or its appointed officials. We do not promote any official government document or services of the Government of the Republic of Indonesia, including but not limited to, business identifiers, health and welfare assistance programs and benefits, unclaimed tax rebate, electronic travel visa and authorization, passports in this website.