Hans Nicholas Jong, Jakarta – Indonesia is testing whether one of the world's most powerful timber certifiers can deliver justice – or merely a reset – to forest communities harmed by industrial logging.
At stake is the credibility of the Forest Stewardship Council's (FSC) first-of-its-kind "remedy framework," an ambitious mechanism that allows logging companies stripped of certification to regain it – but only if they repair the environmental and social damage they've caused.
But early implementation has exposed cracks – particularly in how past harms are assessed.
The FSC is the world's most recognizable ethical wood certifier, whose logo of a green checkmark and tree is widely used to assure consumers of sustainable sourcing and appears on forestry products – from furniture to paper – worldwide.
Under the remedy framework that was adopted in 2023, forestry companies can obtain or regain sustainability certificates if they remedy past environmental and social harms.
Two of Indonesia's largest forestry firms have entered this process, making the country a global testing ground for what could become a new model of corporate accountability, opening the door to restoring millions of hectares of forests, and bringing restitution to thousands of affected communities.
FSC director-general Subhra Bhattacharjee told Mongabay that the Indonesian context will highlight the framework's limitations and the need to customize it to local conditions, "because what works in Indonesia won't work in another country – but the processes will."
Baseline flaws undermine remedy process
However, for Indonesia to set an example of how the remedy framework can truly deliver justice, the FSC must address the shortcomings revealed in the process, according to a new report by a coalition of NGOs including the Forest Peoples Programme (FPP), Yayasan Kehutanan Masyarakat Lestari (YMKL) and Bahtera Alam.
The report reviewed the remedy process for APRIL, the forestry subsidiary of Singapore-based Royal Golden Eagle (RGE) Group.
APRIL had its FSC certification revoked in 2013, in a process known as disassociation, amid ongoing concerns over large-scale deforestation and social conflicts. The disassociation means APRIL can no longer market its products as FSC-certified or use the FSC logo.
Seeking reassociation, APRIL signed an agreement with the FSC in November 2023 to start the remedy process. As part of this process, APRIL underwent a baseline assessment of potential environmental and social harms, conducted by independent consultancy Remark Asia.
According to the FSC, Remark Asia completed the assessment for APRIL's operations in North Sumatra province in November 2024.
Representatives of various NGOs subsequently visited nine affected communities, including five where the assessments were said to have been completed, for an independent check. They found a series of shortcomings in the social baseline assessment process, especially around obtaining the free, prior and informed consent (FPIC) of affected rightsholders.
The communities in North Sumatra told the NGOs they had never been contacted by the assessors. Many communities said they hadn't even heard of the FSC, APRIL or Remark Asia – indicating a major failure of communication and outreach, the NGOs said.
Furthermore, the NGOs found that the assessors relied on administrative villages as proxies for impacted communities, overlooking customary communities, whose governance and territorial structures often don't align with government designations.
Community members noted it was possible Remark Asia had met with the administrative heads of their villages, but that they weren't informed of these visits, the NGOs said.
"The omission of FPIC at multiple stages is not a technical oversight; it is a serious breach of both FSC's own policies and international human rights standards," the report's authors told Mongabay.
Another major issue was the methodology used in the baseline assessment, which the NGOs said was flawed. Remark Asia reportedly spent an average of just two days gathering information per village – about one day for focus group discussions and FPIC processes, and another for a community meeting.
This limited time wouldn't have been adequate to capture decades of complex social and environmental harms, the NGOs said.
The methodology also lacked rigor and failed to include collaboration with customary leaders or local civil society organizations, they added. It lacked clear guidelines on identifying harms and whether the assessor must meet all impacted rightsholders, the NGOs noted.
"To uphold the integrity of the FSC Remedy Framework and ensure justice for affected communities, these gaps must be urgently addressed," the NGOs said. "This includes revisiting the methodology, conducting genuine FPIC processes with third-party oversight, and ensuring communities are given full and timely access to draft findings. Anything less risks eroding stakeholder confidence and undermining the credibility of FSC's commitment to remedy."
Lack of substantiated data
FSC remedy program manager Salem Jones said she welcomed the report's findings and acknowledged its usefulness in identifying confusion around the process.
"I think what the FPP report does is it says, 'Hey, there are communities out there that are within the impact area that don't understand whether their information is relevant for an FSC remedy framework process and that they need to understand better what the scope is, why the independent assessor has not come to visit them,'" she told Mongabay in Jakarta.
However, Jones noted the report lacked "triangulated" or substantial cross-checked data, relying mainly on limited interviews, and thus being "a bit anecdotal." As such, she said, the report doesn't prove that the five communities were wrongly excluded from the baseline assessment.
"I wouldn't draw conclusions about the quality of the independent assessor, the quality of the baseline, or the harms identification based on that report," Jones said.
The NGOs pointed out that this means the FSC acknowledges it hasn't verified whether the five North Sumatran communities fall within the remedy framework's scope. Verification by a third-party is planned to review the work of the independent assessor, but the NGOs said this verification should have occurred earlier to ensure FPIC was respected in identifying impacted rightsholders.
"By accepting a final baseline assessment without confirming whether all affected communities were included, FSC has breached this requirement," the NGOs said. "This creates a serious risk that communities – including those visited by FPP – have been excluded from the remedy process."
APRIL said in an email to Mongabay that the five communities identified in the NGOs' report were included in the impact area and identified as affected rightsholders down to the village level. However, it acknowledged that some community members may not have received key information – possibly due to "differences in who was consulted" or "limited information-sharing among attendees after the meetings."
Harms done
Although the NGOs' report doesn't conclusively determine whether the five North Sumatran communities fall within the remedy framework's scope, it documented myriad alleged harms based on its interviews and existing reports.
In Dolok Parmonangan, for instance, community members reported that 425 hectares (1,050 acres) of community lands were appropriated by PT Toba Pulp Lestari (TPL), a subsidiary and a key supplier of APRIL in North Sumatra, without FPIC.
They also reported an increase in incidents of physical violence and criminalization since 2018. In December 2024, several community members were reportedly injured after TPL security forces allegedly threw stones at them during protests against the company's plan to destroy their watershed area, their primary source of water.
TPL responded to the incident by suggesting the community members were the ones acting violently.
That same year, the customary leader of the community, Sorbatua Siallangan, was sentenced to nine months in prison on charges of illegally occupying land belonging to TPL.
Like others in the report, community members said they'd never heard of the FSC or Remark Asia until the NGOs visited them, but expressed willingness to engage with the FSC and Remark Asia if approached through their customary institutions.
They said the only acceptable remedy would be full recognition of their land rights, TPL's exit from their lands, and an end to criminalization of community members.
The NGOs concluded it would take more time to accurately and completely document the harms the communities had allegedly suffered.
"A comprehensive baseline assessment, that will become the basis for negotiating the remedy to be provided, therefore requires more time in each community to appropriately document all the social harms suffered," they said.
They also called for the communities to be allowed to choose their representation, including NGOs or lawyers, and to engage in participatory mapping to clarify the extent of their customary rights that may have been impacted by the company's operations, as set out in the remedy framework's FPIC and participatory rights sections.
Lack of transparency
Another issue raised in the report is lack of transparency, with neither the affected communities nor the NGOs given access to the baseline assessment results despite multiple requests made to Remark Asia and the FSC.
"Transparency is key to building trust in the remedy process," Gemma Tillack, forest policy director at the Rainforest Action Network (RAN), told Mongabay. "We are calling on the FSC and APRIL/RGE Group to share the results of the baseline assessments so they can be scrutinised by interested stakeholders in addition to rightsholders and the appointed Third Party Verifier."
The NGOs said it's important for affected communities to have copies of the draft assessment to verify completeness and accuracy – confirming all rightsholders, impact areas and social harms were properly identified.
"Remark Asia failed to do this, leaving communities uninformed and excluded from a process that directly concerns their rights," the NGOs said.
In response, Remark Asia said FSC procedures require third-party verification before the baseline assessment can be published. Even then, only summaries can be released due to confidentiality concerns, according to Bhattacharjee, the FSC director-general.
"Much of the baseline assessment may include sensitive corporate information such as business intelligence that companies may prefer not to share with competitors, and more widely, and as an organization that takes its commitment to data protection seriously, we must respect that," she told Mongabay.
Jones of the FSC added that the information also includes specific details about violations against Indigenous peoples and communities, and thus "it would be irresponsible for that information to be shared publicly."
Tensions escalate
Citing the shortcomings identified in the social baseline assessment, and escalating conflicts between TPL and Indigenous Batak Toba communities, the NGOs called for suspension of the remedy framework process until improvements are made.
"The FSC remedy process will only succeed if there is a safe space for affected communities to participate," Tillack said. "This safe space has not yet been achieved in Indonesia as there are ongoing reports of intimidation, violence and criminalisation by the companies seeking FSC certification."
On May 26, hundreds of TPL workers held a demonstration to demand the government investigate and expel two Indigenous rights NGOs, AMAN Tano Batak and KSPPM, accusing them of provoking community resistance against TPL.
Around the same time, Indigenous rights activists and affected community members staged their own protest demanding the government shut down TPL.
On May 30, Indigenous rights activist and Goldman Environmental Prize winner Delima Silalahi received a package containing a bloodied dead bird from an unknown sender.
She said she believed the package was meant to intimidate her, noting that it came shortly after the TPL workers' protest. During that protest, the workers carried banners identifying Delima and two other activists by name and demanding their arrest.
TPL denied any involvement in either the workers' protest or the package sent to Delima.
The conflict has grown beyond the local Indigenous communities, with major religious institutions and academics also voicing opposition to TPL. Huria Kristen Batak Protestan (HKBP), North Sumatra's largest church with 6.5 million members, has called for TPL's closure.
"The presence of PT TPL has triggered various forms of social and ecological crises, ranging from environmental destruction and disruption of ecosystem balance, to a series of ecological disasters such as repeated flash floods, landslides, and the pollution of water, soil, and air, as well as climate change," church leader Victor Tinambunan said as quoted by local news outlet Tempo in May.
Similarly, the Catholic Church's Justice, Peace, and Integrity of Creation Commission (KPKC) of the Capuchins in Medan, the North Sumatra provincial capital, has also expressed opposition to TPL.
Responding to the allegation of threats against activists like Delima, Bhattacharjee said the FSC takes the allegations of threats against Delima and other activists very seriously, and stressed the need for investigations. But she noted that complaints must first be lodged through the company's grievance mechanism, not to the FSC directly. For its part, the FSC will monitor whether the company is responsive or not, Bhattacharjee said.
APRIL confirmed it has created a formal grievance mechanism for remedy-related complaints.
"Communities who have concerns or suggestions can submit a grievance and APRIL has committed to considering and acting to address the grievance," the company said.
The NGOs said corporate grievance mechanisms are no substitute for proper FPIC processes and are often distrusted due to past exclusion or intimidation.
"Moreover, as our investigation revealed, at least some communities remained unaware of the remedy framework process, a prerequisite to their accessing grievance mechanisms to complain about being excluded from the process," the NGOs said.
Shadow companies and FSC accountability
Some NGOs have called for suspension of the remedy process amid reports linking APRIL parent company RGE to shadow groups and companies, such as PT Mayawana Persada, engaged in deforestation and customary rights violations considered unacceptable by the FSC.
Most recently, Greenpeace published an investigative report that alleged RGE secretly controls 257 companies that together were responsible for 68,000 hectares (168,000 acres) of deforestation from 2021 to 2024.
RGE denied the allegations, saying its supply chain is free from shadow companies. It also denied control over specific investigated companies like Mayawana Persada and Phoenix Resources international.
Kiki Taufik, head of Greenpeace Indonesia's forest campaign, said RGE mischaracterized the report's main argument as being about a "shadow supply chain," in an apparent attempt to shift the focus away from the actual question of concealed corporate control.
He pointed out that RGE only explicitly denied controlling a few specific companies, but not the entire 257 shadow companies, which consist of 194 Indonesian and 63 overseas entities.
"The report painstakingly documents this evidence, and the accusation about the 194 Indonesian and 63 overseas companies has never been made before, contrary to RGE's claim in its response," Kiki said.
Jones said the FSC has hired a third party to review RGE's corporate scope as part of its remedy framework process, and that the due diligence review will consider the Greenpeace report.
"In the case that PT Mayawana Persada and PT Phoenix were to be found as part of the RGE group, this would be very difficult for FSC," she said. "If an organization engaging in a remedy process is not up front and forthright in the scope of their corporate group, we as FSC have the ability to suspend that agreement or to terminate it."
Despite calls for the process to be suspended until all shortcomings and concerns are resolve, both the FSC and APRIL insisted the remedy process must continue.
"Of course there are challenges," Bhattacharjee said. "But the answer to that is improving on the go. These are not things you figure out around the table. These are things you figure out on the ground while implementing. And then keep improving."
For its part, APRIL said that "remedy delayed would be remedy denied."
"We have heard directly from the rights holders and local communities that they are eager to see the remedy process move forward and start seeing more results-focused discussions," the company said. "We are all for having an effective, transparent and inclusive process but we've also heard it said at the recent FSC Remedy Forum that there will not be a perfect remedy process. We should instead focus on getting to meaningful, equitable outcomes for the environment and the local communities."
Jones said rightsholders at a two-day forum in Jakarta to discuss the remedy framework also expressed frustration with waiting and wanted a remedy process in place.
Hope for remedy
Ahmad Hanapi, an Indigenous Dayak villager from North Kalimantan province, on the island of Borneo, was among those who attended the forum in Jakarta. He said the remedy framework gives him hope.
His community has been in conflict with pulpwood company PT Adindo Hutani Lestari (AHL), a supplier to APRIL, and in 2024, he was reported by the company to the police for allegedly occupying the firm's concession.
"I got excited [when I learned about the remedy framework] because it concerns the rights of communities – it gives hope. People feel relieved to hear that their rights could be restored. So we're really happy. For communities like mine, it gives us hope and motivation," Ahmad told Mongabay.
Misman Faizan, a villager from Riau province in Sumatra, whose community been in conflict for decades with another APRIL supplier, PT Sumatera Riang Lestari (SRL), also shared the same hope.
"If possible, the process should continue," he told Mongabay. "If the policy runs smoothly, they say the aim is to restore community rights. But I'm not 100% convinced they can return the rights that are already within the concession area, because PT SRL is known to be a powerful company."
While APRIL acknowledges that AHL and SRL are among its suppliers and denies owning either company, both have been listed by APRIL as part of the impact areas under the remedy framework for Kalimantan and Riau, respectively. This confirms that AHL and SRL are within the scope of the remedy process, even as questions remain about corporate control and accountability.
The potential of delivering remedies to people like Ahmad and Misman is why it's important for all shareholders to keep improving on the remedy framework and its implementation, Jones said.
"I think that what we really need to be talking about is the potential, the opportunity and the potential that the remedy framework has for driving restoration outcomes and supporting communities in access to voluntary access to remedy processes. And that this is really important and we shouldn't lose sight of that," she said.
As Indonesia tests the limits of the FSC's ambitious new framework, the outcome could ripple far beyond its forests – shaping how global supply chains reckon with past environmental harm. For communities on the frontlines of conflict, the stakes aren't just about policy – they're about survival, recognition, and justice long overdue.
"We want to live off the forest like our ancestors did – using our land, planting our crops, exercising our rights," Ahmad said. "I don't want compensation. I want my land back."