Since 1997, various provisions have been incorporated into Indonesia’s environmental law which relate to corporate criminal liability. Other laws relating to natural resource management have also had provisions on corporate criminal liability inserted into them. These laws are problematic because they often fail to distinguish between corporate criminal liability and corporate officers’ criminal liability, and as do the courts in their interpretation and application of them. Currently in Indonesia, an officer may be held liable for a crime committed by their corporation, even without being at fault or appearing as a defendant in the trial. Indonesia’s environmental law can therefore be said to be applying a rather extreme version of individual vicarious liability in environmental cases, in which a corporate officer is punished merely because of their position as a high-ranking officer of a corporation. This practice seems to be the result of an erroneous interpretation of corporate criminal liability. We argue that the Indonesian interpretation of environmental corporate criminal liability is not only ineffective but also harmful and inconsistent with theories of corporate criminal liability. We also argue that corporate criminal liability should be distinguished from the liability of corporate officers. While corporate criminal liability places criminal liability on the corporation as a legal entity, officers' criminal liability places the criminal liability on the corporate officers as individuals. A corporate officer should only be criminally liable if they can be blamed for an environmental crime committed by the corporation.

自1997年以来，印尼公司的环境法中已纳入与公司刑事责任有关的各种规定。其他与自然资源管理有关的法律中也加入了有关公司刑事责任的规定。这些法律是有问题的，因为它们常常无法区分公司的刑事责任和公司管理人员的刑事责任，而法院在解释和适用它们时也是如此。目前在印度尼西亚，即使没有过失或在审判中作为被告出庭，军官也可能对其公司所犯的罪行承担责任。因此，可以说印度尼西亚的环境法在环境案件中适用了个人替代责任的一种极端形式，在该法令中，仅因其担任公司高级官员的职位而受到公司官员的惩罚。这种做法似乎是对公司刑事责任的错误解释的结果。我们认为，印度尼西亚对环境公司刑事责任的解释不仅无效，而且有害且与公司刑事责任理论不符。我们还认为，公司的刑事责任应与公司管理人员的责任区分开。公司刑事责任将刑事责任置于公司作为法人实体的位置，而官员的刑事责任则将刑事责任置于公司人员作为个人的责任。