Purpose This study aims to examine whether risk-based licensing reform under Law No. 6 of 2023 remains compatible with environmental protection in the context of Indonesian forestry governance. Using the principle of non-regression as its primary normative lens, the study evaluates whether the post-reform licensing framework preserves the core control function of environmental law or instead creates conditions for gradual regulatory backsliding. Design/methodology/approach The study uses normative doctrinal legal research with an analytical and prescriptive design. It examines key legal materials governing forestry, environmental protection, environmental approval and risk-based licensing, and evaluates them through three operational criteria: auditability, traceability and correction capacity. These criteria are used to test whether the post-reform framework preserves sufficiently clear safeguards, a traceable allocation of responsibility and credible pathways for administrative correction. Findings The analysis shows that risk-based licensing is not inherently incompatible with environmental protection. Its compatibility, however, is conditional. The framework becomes normatively vulnerable where risk classifications and baseline safeguards are insufficiently specific, where decisions and institutional responsibilities cannot be traced across the chain from environmental approval and licensing to supervision and remediation and where administrative correction lacks continuity, escalation or restoration verification. Broader institutional conditions, including coordination, procedural rights and supplementary compliance instruments, matter only insofar as they reinforce or weaken these three core dimensions. Originality/value This study contributes a normative and transferable evaluative framework that moves beyond the conventional efficiency-versus-protection debate. By operationalising the principle of non-regression through legally testable criteria, it offers a structured way to assess whether licensing reform preserves or weakens the preventive and corrective force of environmental law. Its contribution is primarily normative and diagnostic, identifying legal vulnerabilities within the regulatory architecture rather than empirically measuring implementation outcomes.
Hastri et al. (Mon,) studied this question.