09 Jun 2026
Indonesia Introduces Export Centralization Regime for Strategic Natural Resource Commodities — Government Regulation No. 24 of 2026

On 20 May 2026, the Indonesian Government enacted Government Regulation No. 24 of 2026 on the Governance of Exports of Strategic Natural Resource Commodities ("GR 24/2026"), which introduces a centralized export regime under which exports of certain strategic natural resource commodities must be conducted through a designated state-owned enterprise. This regulation became effective on 1 June 2026. GR 24/2026 reflects the Government’s policy objective to strengthen state oversight of strategic export sectors, enhance revenue transparency and foreign exchange inflows, and support Rupiah stability.

GR 24/2026 establishes a centralized export mechanism under which exports of designated strategic commodities must be channeled through designated state-owned enterprises, reportedly PT Danantara Sumberdaya Indonesia (the "Export SOE"). Under this framework, the Export SOE will become the sole export channel for the relevant commodities.[1]

GR 24/2026 initially covers three prioritized commodities: (i) coal; (ii) palm oil; and (iii) ferroalloys, with the Government retaining discretion to expand the list.[2] Current prioritization appears focused on commodities making significant contributions to national export revenues. The initial list is therefore not exhaustive, and businesses in relevant critical mineral sectors (and their related products), should remain alert to the possibility of future inclusions

The shift is significant. Under the current regime, producers and exporters may deal directly with offshore buyers and determine commercial terms independently. However, under GR 24/2026, exports of covered commodities must initially be routed through the Export SOE, effectively removing the ability of private exporters to export such commodities directly, and once fully implemented, the Export SOE will act as the seller and exporter of record.

Transitional Period

GR 24/2026 sets a transitional deadline ending no later than 31 December 2026, during which export activities must gradually transition to the Export SOE model. During this period, the Government will conduct periodic evaluations and may adjust the timeline depending on the implementation outcomes.[3]

After the expiry of the transitional period, direct exports of strategic commodities by private exporters will no longer be permitted as export of strategic commodities can only be performed by Export SOE. Export contracts signed before 1 June 2026 remain valid but will be subject to review by the Export SOE.[4]

Export contracts entered into before 1 June 2026 may continue during the transitional period. However, such contracts will be subject to review and coordination with the Export SOE in accordance with the transition mechanism to be further regulated by the Government.

Export Governance and Pricing

Under GR 24/2026, the export selling price will be determined by the Export SOE, which may apply a commercial margin within reasonable limits.[5] This represents a material change from the current regime, where export prices are generally negotiated directly between sellers and buyers.

GR 24/2026 also introduces a broader governance framework, including:

• export controls, including verification and traceability requirements;

• regulation of transportation and export insurance arrangements; and

• potential use of other control mechanisms under applicable laws.[6]

The framework anticipates increasing integration with national systems such as CEISA, INATRADE, and SINSW, pointing towards real-time monitoring and data centralization.[7]

Limited Exemptions

GR 24/2026 allows limited exemptions from the centralization requirement where a business holds an existing Government contract covering:

1. investment commitments;

2. divestment obligations; or

3. domestic processing or refining. [8]

Exemptions require coordinating minister-level approval, indicating they will be selective and discretionary.[9]

Key Implications for Businesses

GR 24/2026 centralizes export through a single state-owned channel, with significant implications across the value chain:

• Structural change to export model. Existing export arrangements will require fundamental restructuring. Private producers and traders will transition from acting as sellers and exporters in their own name to the role of domestic suppliers or feedstock providers to the Export SOE. The terms on which commodities are delivered to the Export SOE — including purchase price, volume obligations, and logistics arrangements — remain to be established through implementing regulations and/or commercial negotiation with the Export SOE.

• Impact on existing contracts. Existing sale and export contracts will need to be aligned to reflect Export SOE involvement. Existing sale and export contracts will require careful review and, where necessary, renegotiation to reflect the mandatory involvement of the Export SOE as contracting party. In particular, delivery obligations, force majeure clauses, change-of-law provisions, and price mechanisms may all potentially be materially affected.

• Financing and security considerations. Trade finance and structured financing arrangements that rely on export receivables or offtake contracts as security will require careful reassessment. Where financing structures assume a direct contractual relationship between a private exporter and an offshore buyer, as is commonly the case in commodity prepayment and receivables-backed facilities, the requirement of the Export SOE as the seller of record may affect the validity, enforceability, and practical operation of such arrangements.

• Regulatory uncertainty. While GR 24/2026 establishes the overarching framework, many key aspects remain subject to further implementing regulations, including: the designation and structure of Export SOE; detailed export procedures; transition arrangements; and pricing mechanisms and margin controls.

Businesses should expect further regulatory developments in the near term and are advised to monitor the issuance of implementing regulations closely.

ABNR Observations

GR 24/2026 marks a major policy shift, reflecting the Government's intention to increase state control over strategic commodities and their export flows. The regulation is expected to have material implications for existing export arrangements, commercial relationships, financing structures and supply chains involving the affected commodities.

At this stage, however, the practical implementation of the regime remains uncertain, as a number of key features continue to depend on implementing regulations and the operational framework to be adopted by the Export SOE.

The transitional period until 31 December 2026 provides a window for regulatory development, stakeholder engagement and operational readiness.

Pending further clarity, as discussed above, businesses in affected sectors should consider preliminary internal assessments covering:

• existing export and customer arrangements;

• export-linked financing and receivables structures;

• logistics and operational frameworks; and

• contractual obligations potentially affected by changes to export flows.

Given the evolving regulatory landscape, any such review should be treated as preliminary and updated as implementing regulations are issued. ABNR will continue to monitor regulatory developments closely and will provide further updates as the implementation framework becomes clear.

By partners Ayik C. Gunadi (agunadi@abnrlaw.com), Novario Asca H. (nhutagalung@abnrlaw.com), Mahatma Hadhi (mhadhi@abnrlaw.com), and senior associate Abdurachman Sidik (aalatas@abnrlaw.com).

This ABNR News and its contents are intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. They do not constitute legal advice and should not be relied upon as such. Accordingly, ABNR accepts no liability of any kind in respect of any statement, opinion, view, error, or omission that may be contained in this legal update. In all circumstances, you are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could adversely affect your rights and obligations under Indonesian law.