Over the past several years, commitments and pledges on ‘no deforestation, no peat, no exploitation’ (NDPE) have been made throughout the Indonesian palm oil sector, primarily in response to pressure from NGOs and the public. The NDPE pledges aimed to transform an industry with social and environmental challenges into one that works for people, nature and business. Companies with NDPE policies whose non-forest land (APL) concessions hold forests, peatlands, and other high conservation value (HCV) areas have a commitment to protect these areas, but to date have largely been unsure how to do so. This paper presents several legal options for moving high conservation stock (HCS) forests and HCV areas in APL land into protection.