HAkA: Aceh’s Wildlife Qanun Is Like a Bicycle Without Wheels

BANDA ACEH – The implementation of Aceh Qanun No. 11 of 2019 on Wildlife Management is considered far from effective. To date, not one of the at least 10 implementing regulations mandated by the qanun has been issued by the Aceh Government.

Muhammad Fahmi, Legal and Advocacy Manager of the Aceh Forest, Nature and Environment Foundation (HAkA), said the main problem does not lie in the substance of the qanun, but in the absence of implementing regulations to serve as an operational basis in the field.

“The qanun mandates at least 10 implementing regulations, in the form of either Governor Regulations or Governor Decrees for technical matters. Yet to this day, not a single one has been issued,” Fahmi told AJNN on Wednesday, 23 September 2026.

According to him, this contradicts the mandate of Article 8 of Aceh Qanun No. 11 of 2019. The article explicitly requires implementing regulations on the Wildlife Management Strategy and Action Plan to be enacted no later than one year after the qanun was promulgated. That deadline, Fahmi said, passed years ago. As a result, several provisions of the qanun still lack a clear operational basis for implementation in the field.

He likened Qanun 11/2019 to a bicycle without wheels: the legal framework has been built, but it cannot move because its implementing instruments have yet to be put in place.

“This qanun is like a bicycle without wheels. The legal framework has been built, but it can’t be ridden because the implementing instruments were never put in place,” he said.

Fahmi said that, based on HAkA’s monitoring, Qanun 11/2019 has in practice not yet been implemented in the field. Cases of poaching, wildlife trafficking and other issues have so far been handled using other existing legal instruments.

One of these is Law No. 5 of 1990 on the Conservation of Living Natural Resources and Their Ecosystems, as amended by Law No. 32 of 2024, along with its implementing regulations at the national level.

“In practice, Qanun 11/2019 has not yet become an active reference for law enforcement officers or technical agencies in Aceh, because there are still no implementing instruments to make it ready for use,” he said.

Beyond the gap in implementing regulations, HAkA has identified several other interrelated problems, including a lack of political commitment and budget for drafting the implementing rules.

Fahmi explained that drafting implementing regulations requires initiative and budget allocation from the executive. However, this has so far not been treated as a priority.

Another issue is overlapping authority between the central and regional governments. Wildlife management involves the central government’s authority through the Natural Resources Conservation Agency (BKSDA) and the Ministry of Environment and Forestry (KLHK), as well as the Aceh Government.

Without clear implementing regulations, he said, the boundaries of authority often become a grey area that can in fact weaken law enforcement.

Meanwhile, capacity and resources in the field remain limited, in terms of monitoring personnel, facilities and infrastructure, as well as officials’ understanding of the qanun.

Pressure on wildlife habitats also continues. According to Fahmi, deforestation and land conversion keep driving human-wildlife conflict and poaching, regardless of whether the qanun exists.

“Inter-agency coordination still needs to be significantly strengthened,” he said.

According to Fahmi, the absence of implementing regulations means there is still no formal forum or mechanism binding all parties to work within a single wildlife management framework.

As a result, coordination has so far been largely ad hoc, particularly when major cases come to public attention.

Beyond inter-agency coordination, community involvement is also considered not yet structured. Local communities living around forest areas have not been systematically involved in the management and monitoring schemes mandated by the qanun.

Yet, Fahmi said, communities hold an important position as the front line in safeguarding wildlife and their habitats.

HAkA therefore urges the Aceh Government to immediately draft and enact all implementing regulations mandated by Qanun 11/2019.

“The most urgent and non-negotiable step is to immediately draft and enact all the implementing regulations mandated by this qanun,” he said.

Fahmi said the Aceh Government needs to establish a cross-agency team or working group to accelerate the drafting of all Governor Regulations and technical implementing rules, with clear and measurable timelines.

The Aceh House of Representatives (DPRA) should also be involved in overseeing and pushing for the accelerated drafting of these regulations, given that a qanun is a joint product of the executive and the legislature.

Once the implementing regulations are issued, the government also needs to conduct widespread outreach to law enforcement officers, BKSDA, district and city governments, and communities, so that Qanun 11/2019 is truly understood and used as a reference.

In addition to regulation, budgetary and institutional support must also be ensured. According to Fahmi, issuing regulations is not enough without the support needed to implement them in the field.

HAkA also calls for a periodic evaluation mechanism to monitor the qanun’s implementation. The public and civil society organisations should be given space to help oversee progress in wildlife management in Aceh.

“Ultimately, we urge that Qanun 11/2019 does not remain merely a symbol of Aceh’s commitment to wildlife protection, but truly becomes an instrument that works to protect wildlife and their habitats,” Fahmi said.

This article was first published on AJNN.net under the title “HAkA: Qanun Satwa Liar Aceh Ibarat Sepeda Tanpa Roda”.