The adequacy of land acquisition planning documents as an instrument for legal risk mitigation at the preparatory stage for toll road land acquisition in West Sumatra

This article examines whether Indonesia’s normative framework for Land Acquisition Planning Documents (DPPT) adequately anticipates customary land and Indigenous community representation in toll-road acquisition in West Sumatra. This normative legal study uses statutory and conceptual approaches to analyse constitutional and agrarian guarantees, regional customary-land rules, land-registration provisions, and land-acquisition procedures. Because no project-specific DPPT was available, the article assesses the legal framework rather than the factual adequacy of a particular project document. Three findings emerge. First, the Constitution, the Basic Agrarian Law, West Sumatra Regional Regulation No. 7 of 2023, and Minister of ATR/BPN Regulation No. 14 of 2024 recognise customary-land interests but serve different functions. The regional regulation identifies nagari, suku, and kaum land and their customary leadership, while the national regulation governs administration and registration; ulayat rajo is not listed as a separate category in the 2023 regulation. Second, the Land Acquisition Law and Government Regulation No. 19 of 2021, as amended, provide mechanisms for preliminary data collection, public consultation, objections, and judicial review. DPPT information must be traceable to these later steps to be operationally useful. Third, DPPT can be strengthened through a tenure-information annex, representation records, data-status labels, a risk register, and a traceability matrix. These additions can initially be implemented through technical guidance within existing DPPT components, without making DPPT a land-right determination or creating a new consent requirement. The article concludes that the normative framework is developed but requires clearer information links between planning and preparation.