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Ember argues that Indonesia's energy transition requires more ambitious emissions targets and a stronger regulatory framework, particularly for the underregulated captive coal sector. The organization recommends integrating JETP investments with long-term economic diversification in coal-dependent provinces to ensure a just transition. Ember also highlights a significant gap in solar deployment, noting that Indonesia reached only 416 MW of on-grid solar capacity last year against a 2025 target of 4.1 GW, and calls for more transparent procurement processes by PLN.

The report evaluates transparency in the voluntary carbon market (VCM) by analyzing a sample of 140 projects across the Verified Carbon Standard (VCS), Gold Standard (GS), American Carbon Registry (ACR), and Climate Action Reserve (CAR). It finds that no single standard provides full disclosure, with significant gaps caused by both inadequate rule-setting and insufficient enforcement. Specifically, CAR and ACR have structural limitations regarding the public disclosure of monitoring reports. The study also identifies widespread issues with mislabelled, duplicated, or missing documents, which rating agencies confirm hinder the independent assessment of carbon credit quality. The report recommends implementing stronger quality assurance/quality control (QA/QC) processes, standardized naming conventions, and regular audits to align with Integrity Council for Voluntary Carbon Markets (ICVCM) requirements.

Carbon Market Watch (CMW) opposes the current draft of the Free Allocation Regulation (FAR) revision, stating it increases free allowances for industrial sectors and contradicts the political mandate of the EU ETS Directive. CMW identifies critical failures in steel and cement benchmarking, the use of median production levels for Historical Activity Level (HAL) calculations, and an insufficiently ambitious reduction in free allowances for process emissions.

Carbon Market Watch argues that the European Commission's proposal to revise the Industrial Emissions Directive (IED) fails to meaningfully address greenhouse gas (GHG) emissions because it maintains the exclusion of GHGs from installations covered by the EU Emissions Trading System (ETS). The organization recommends deleting Article 9.1 to allow binding emission limits for ETS sectors, maintaining the deletion of Article 9.2 to make energy efficiency requirements mandatory, and strengthening the requirements for industrial transformation plans (TP) to ensure they are binding, detailed, and implemented before 2030.