On 20 May 2026, the President of the Republic of Indonesia enacted Government Regulation (“GR”) No. 24 of 2026 on the Governance of Export of Strategic Natural Resource Commodities (“GR 24/2026”), which took effect on 1 June 2026. Note that while GR 24/2026 is already in force, the requirement to export Strategic Commodities exclusively through the designated state-owned enterprise is subject to a separate transition deadline, discussed further below under “Transitional Arrangements”. GR 24/2026 marks a significant policy shift in Indonesia’s natural resources sector by centralising the export of designated strategic natural resources through state-owned enterprises. The new framework is intended to safeguard domestic supply stability, strengthen national economic resilience, increase value added, and support sustainable national development, particularly in response to concerns over under-invoicing.

In light of the foregoing development, we have highlighted the key features of GR 24/2026 that businesses engaged in of natural resource commodities should be aware of.

 

Key Takeaways

  1. GR 24/2026 centralizes the export of designated “Strategic Commodities” (initially coal, palm oil, and ferro alloy) through a state-owned enterprise to be specially assigned by the Government (widely expected, but not yet confirmed, to be PT Danantara Sumberdaya Indonesia).
  2. A narrow exemption is available for business actors with qualifying investment, divestment, and downstream processing commitments, subject to government approval – it is not an automatic right.
  3. Businesses must transition their export arrangements to the designated entity by 31 December 2026 (or an earlier date if set by the government), and existing sales contracts signed before 1 June 2026 will be evaluated by that entity.
  4. Key implementation details – including pricing/margin methodology, contract evaluation criteria, and further procedural rules – remain to be issued and should be monitored closely.

 

Scope of Commodities

The promulgation of GR 24/2026 does not necessarily bring all exports within the new centralised framework. Instead, GR 24/2026 selectively limits the type of commodities that are subject to this framework, particularly commodities that fall under the category of “Strategic Natural Resource Commodities” (Komoditas Sumber Daya Alam Strategis), or more simply, natural resource commodities designated by the government having regard to national interest, economic stability, domestic needs, and/or the strategic national management of natural resources (Article 1 (2) of GR 24/2026).

With the issuance of GR 24/2026, the Government of the Republic of Indonesia has determined the commodities subject to this regulation in the initial phase, which, pursuant to Article 2 of GR 24/2026, includes the following:

  1. coal;
  2. palm oil; and
  3. ferro alloy,

(collectively, “Strategic Commodities”).

Please note that the list of Strategic Commodities is non-exhaustive and remains at an initial stage. Other natural resources commodities may be included in this category upon further determination in the subsequent phase by the Coordinating Ministry for Economic Affairs (“CMoEA”) for non-food commodities and Coordinating Ministry for Food Affairs (“CMFA”) for food commodities, which the Ministry of Trade will further regulate the upcoming determination (Article 2 (2), (4), and (5) of GR 24/2026).

 

Designated Entity

The centrepiece of GR 24/2026 is the requirement that Strategic Commodities can only be exported by a state-owned enterprise specifically assigned by the government to conduct such export activities (the “Designated SOE”). As of the date of this note, the specific state-owned enterprise to be designated has not yet been formally confirmed. However, based on publicly available information and prevailing public expectations, PT Danantara Sumberdaya Indonesia (“DSI”) is widely understood to be the entity that may be designated as the Designated SOE. If so designated, DSI would act either as the owner of the goods or as the sole intermediary for the export of Strategic Commodities (Article 3 (1) of GR 24/2026).

Notwithstanding the above, GR 24/2026 provides an exemption from the requirement for Strategic Commodities to be exported through the designated state-owned enterprise. Such exemption may only be granted upon fulfilment of the following 2 (two) conditions:

  1. hold a contract or agreement with the Government of the Republic of Indonesia that includes, at a minimum, provisions on investment, divestment, and processing and/or refining in Indonesia; and
  2. subsequently obtain approval through a coordination meeting mechanism led by the CMoEA or CMFA.

(Article 4 (2) and (3) of GR 24/2026).

In this regard, the exemption is likely intended to accommodate business actors whose export activities form part of broader investment and downstream processing commitments in Indonesia. However, because the exemption remains subject to approval, it does not provide an automatic right to export independently of DSI or the designated state-owned enterprise. Its practical application will therefore depend on the relevant business actor’s ability to demonstrate that its agreement satisfies the required investment, divestment, and processing and/or refining commitments and obtain the requisite approval.

 

Export Control Mechanisms

The governance of the export of Strategic Commodities shall be conducted through:

  1. export control, including technical verification or tracing;
  2. regulation of export transportation and insurance; and/or
  3. other mechanisms in accordance with the prevailing laws and regulations.

For such purpose, the Designated SOE (i.e., likely DSI) is entitled to determine the selling price of the Strategic Commodities that it exports and may set a margin within a reasonable level in accordance with the prevailing laws and regulations (Article 3 (2) and (4) of GR 24/2026). Notably, GR 24/2026 does not itself prescribe the pricing methodology or define what constitutes a “reasonable” margin; businesses should monitor further implementing regulations on this point, as it is likely to be a key commercial concern.

The involvement of the Designated SOE in an export transaction includes, among others, the submission of (i) export documentation, (ii) sales contracts, and (iii) related documents by business actors to the Designated SOE, as well as the provision of additional data and information required by the Designated SOE, which may be carried out through government’s trade integrated systems such as Customs Exclusive Information System and Automation (CEISA), Sistem Indonesia National Single Window (SINSW), Sistem Informasi Perdagangan (Indonesia Trade or INATRADE), Sistem Informasi Monitoring Devisa Terintegrasi Seketika (Real Time Integrated Foreign Exchange Monitoring or SiMoDIS), and/or Minerba Online Monitoring System (Elucidation of Article 7 (a) of GR 24/2026).

Further provisions on the governance of the export of Strategic Commodities will be regulated by the relevant ministries and non-ministerial government institutions in accordance with their respective authorities, and supervision over the implementation of such governance will likewise be carried out by the relevant ministries and non-ministerial government institutions (Articles 5 and 6 of GR 24/2026).

It is worth noting that GR 24/2026 does not displace existing sector-specific export regulations (for example, those governing coal, palm oil, or mineral exports); such regulations continue to apply to the extent they are consistent with GR 24/2026 (Article 9 of GR 24/2026).

 

Transitional Arrangements

GR 24/2026 provides for a phased transition toward the centralisation of Strategic Commodity exports through the Designated SOE. Business actors involved in the export of Strategic Commodities are required to transition their export-related workstreams by 31 December 2026, unless the CMoEA determines an earlier date (Article 7(a) and (c) of GR 24/2026). Following the completion, export activities relating to Strategic Commodities will be conducted through or by the Designated SOE (i.e., DSI).

In addition, sales contracts signed before 1 June 2026 that remain effective when GR 24/2026 comes into force will be subject to evaluation by the Designated SOE (Article 8 of GR 24/2026). Notably, GR 24/2026 does not specify the criteria by which such contracts will be evaluated or the possible outcomes of that evaluation, leaving businesses with legacy export contracts uncertain. Accordingly, all businesses with existing export contracts for Strategic Commodities should anticipate that their arrangements may be further affected by the Designated SOE.

 

Concluding Remarks

GR 24/2026 is expected to strengthen the government’s oversight of Strategic Commodity exports, which is expected to improve transparency in commodity pricing, reduce the risk of under-invoicing, and ensure that the export of strategic natural resources is aligned with domestic supply, downstream processing, and broader national economic objectives. Businesses should also monitor for further implementing regulations expected to be issued by the Ministry of Trade and other relevant ministries, which are anticipated to flesh out the detailed procedures and technical requirements referred to above.

However, from a business perspective, centralisation may reduce the flexibility of business actors who have historically managed their exports independently and may introduce additional administrative and compliance requirements. Businesses may need to adjust their existing export arrangements, provide additional documentation and information to DSI, and potentially adapt existing contracts following DSI’s evaluation. There may also be practical uncertainty during the transition period, particularly as the detailed procedures and technical requirements for implementing the new export framework are expected to be further developed.

In light of these developments, business actors engaged in the export of natural resource commodities should proactively assess whether their existing arrangements, including offtake agreements, export agreements, sales agreements, and other related commercial arrangements, involve commodities that fall within the scope of Strategic Commodities under GR 24/2026. Where the relevant commodities are subject to the new framework, business actors should begin assessing the potential impact on their existing contractual and commercial arrangements and consider the steps required to transition their export activities to the Designated SOE. This may include reviewing existing contractual rights and obligations, assessing potential implications for pricing and margins, and considering whether any existing arrangements may qualify for the exemption under Article 4 of GR 24/2026.

 

 

Disclaimer: The information herein is of general nature and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. Specific legal advice should be sought by interested parties to address their circumstances.