22 Jul 2026
Implementation of BI Reg 5/2026 on the Natural-Resource Export Proceeds Framework

Background

On 29 May 2026, Bank Indonesia issued Bank Indonesia Regulation No. 5 of 2026 on the Second Amendment to Bank Indonesia Regulation No. 7 of 2023 on Foreign Exchange Export Proceeds and Foreign Exchange Import Payments ("BI Reg 5/2026"), which became effective on 1 June 2026.

BI Reg 5/2026 aligns Bank Indonesia’s regulatory framework with Government Regulation No. 36 of 2023 on Foreign Exchange Export Proceeds from Natural Resource Business, Management and/or Processing Activities, as most recently amended by Government Regulation No. 21 of 2026 ("GR 21/2026").

The regulation forms part of the Government's broader initiative to strengthen Indonesia's foreign exchange reserves, enhance external resilience and increase the contribution of natural-resource export proceeds (Devisa Hasil Ekspor Sumber Daya Alam or “DHE SDA”) to the domestic economy.

BI Reg 5/2026 governs the following key provisions:

1. mandatory deposit of DHE SDA through state-owned foreign exchange banks and applicable retention periods;

2. expansion of permitted DHE SDA placement instruments;

3. restrictions on conversion of DHE SDA into Rupiah; and

4. special arrangements for exporters operating under bilateral trade frameworks.

• Mandatory Deposit of DHE SDA Through State-Owned Banks

  Under BI Reg 5/2026, consistent with GR 21/2026, exporters must deposit 100% of their DHE SDA in the Indonesian financial system no later than the end of the third month following the month in which the relevant export declaration (Pemberitahuan Pabean Ekspor or “PPE”) is registered.

  For DHE SDA with a value of at least USD250,000 (or its equivalent) based on the PPE, exporters are required to place the proceeds into a special DHE SDA account maintained with a state-owned foreign exchange bank (“SOE Bank”). The implementing regulation of BI Reg 5/2026[1] further allows each exporter to open more than one special DHE SDA in the same or different SOE Bank.

  BI Reg 5/2026 also reflects the retention requirements introduced under GR 21/2026:

  1. Non-oil and gas sectors: Exporters must retain 100% of their DHE SDA in the Indonesian financial system for a minimum period of twelve (12) months from the deposit date.

  2. Oil and gas sectors: Exporters must retain at least 30% of their DHE SDA for a minimum period of three (3) months from the deposit date.

  The retention requirement may be satisfied through placement in the special DHE SDA account, banking instruments maintained with state-owned foreign exchange banks, eligible instruments issued by Bank Indonesia and the additional placement instruments described in Section B below.

• Expansion of Permitted Placement Instruments

  BI Reg 5/2026 broadens the range of instruments available for DHE SDA placement.

  1. In addition to the instruments previously available under the DHE SDA regime, exporters may now place DHE SDA in the following instruments issued by the Government of Indonesia in the domestic primary market:

  2. foreign-currency-denominated government bonds (Surat Utang Negara or “SUN”); and

  3. foreign-currency-denominated state sharia securities (Surat Berharga Syariah Negara or “SBSN”).

  In line with GR 21/2026, DHE SDA placed in foreign-currency-denominated SUN or SBSN cannot be withdrawn before the expiry of the relevant placement period. Where such securities are subject to a holding period, disposal may only occur after its expiry, through transactions in the secondary market.

  Bank Indonesia is also authorised to designate additional placement instruments in the future, provided that they remain consistent with the objectives and requirements of the DHE SDA regime.

• Restrictions on Conversion into Rupiah

  Another notable development under BI Reg 5/2026 is the introduction of stricter controls on the conversion of non-oil and gas DHE SDA into Rupiah.

  The regulation requires exporters to comply with conversion limits prescribed under GR 21/2026. As described in Section A above, exporters must deposit 100% of their DHE SDA in the Indonesian financial system. Under the current implementing policy, any conversion into Rupiah is limited to a maximum of fifty percent (50%) of the export value stated in the relevant PPE.

  These restrictions are intended to support onshore foreign currency liquidity and reinforce the policy objective of retaining export proceeds within the Indonesian financial system.

• Special Arrangements for Bilateral Trade Frameworks

  BI Reg 5/2026 incorporates the special regime introduced by GR 21/2026 for exporters operating under bilateral trade agreements, memoranda of understanding or other similar trade arrangements, as follows:

  1. at least thirty percent (30%) of the DHE SDA must remain placed for a minimum period of three months;

  2. DHE SDA may be placed in the special DHE SDA account with a foreign-exchange bank; and

  3. DHE SDA may be converted into Rupiah through a foreign-exchange bank.

Bank Indonesia is authorised to designate the banks eligible to facilitate these arrangements.

Transitional Provisions 

The updated DHE SDA framework applies to PPEs registered on or after 1 June 2026. PPEs registered before that date and already subject to monitoring by Bank Indonesia and/or the Financial Services Authority (OJK) are deemed to have complied with the applicable regulatory requirements.

Practical Implications 

The revised DHE SDA regime is likely to have significant implications for exporters, lenders and financial institutions.

Exporters should consider reviewing:

1. The existing account structures and banking arrangements;

2. compliance of the existing special DHE SDA account with the SOE Bank’s requirement;

3. treasury management arrangements in light of the revised retention and conversion restrictions; and

4. financing structures that rely on offshore collection account, cash sweeps or foreign currency liquidity.

Financial institutions and lenders involved in natural resource projects may also wish to reassess account bank provisions, cash management structures and financing documentation to ensure consistency with the revised framework.

ABNR Commentary

BI Reg 5/2026 serves as the principal implementing regulation for the policy reforms introduced by GR 21/2026. While GR 21/2026 established the substantive changes to Indonesia's DHE SDA regime, BI Reg 5/2026 provides the operational mechanisms through which those reforms will be administered and supervised by Bank Indonesia.

The amendments further demonstrate the commitment of the Government of Indonesia to increasing the onshore retention of export proceeds and strengthening domestic foreign currency liquidity. Although exporters may benefit from a broader range of placement instruments, the revised regime also introduces more stringent requirements concerning account banks, retention periods and currency conversion.

The underlying policy suggests that the Government views export proceeds as part of the national liquidity buffers, rather than merely as exporters’ working capital. This shift requires businesses engaged in natural resource sectors to not only rethink their banking and treasury arrangements, but also their entire approach to investment arrangements. A strategic question for exporters and financiers would be whether the expanded onshore placement instruments will provide returns and flexibility that rival offshore options. As the DHE SDA regime continues to evolve, businesses should undertake proactive scenario planning and closely monitor further regulatory developments.

By Partners Emir Nurmansyah (enurmansyah@abnrlaw.com), Serafina Muryanti (smuryanti@abnrlaw.com), Maher Sasongko (msasongko@abnrlaw.com), associate Muhammad Irsan (mirsan@abnrlaw.com), and trainee associate Hanif Khansa (hkhansa@abnrlaw.com)

This ABNR client alert is intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. It does not constitute legal advice and should not be relied upon as such. ABNR accepts no liability of any kind in respect of any statement, opinion, view, error or omission that may be contained in this update. You are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could affect your rights and obligations under Indonesian law.