16 Jul 2026
The Next Phase of Indonesia's Strategic Commodity Export Regime: What Private Exporters Need to Know

Following the issuance of Government Regulation No. 24 of 2026 on the Governance of Exports of Strategic Natural Resource Commodities (“GR 24/2026”), Indonesia’s export centralization regime has now entered its implementation phase. Building on the framework established under GR 24/2026 (for a more detailed overview of the regulation, please refer to our previous newsletter: Indonesia Introduces Export Centralization Regime for Strategic Natural Resource Commodities — Government Regulation No. 24 of 2026 | ABNR - Counsellors at Law), the Ministry of Trade (“MOT”) has now introduced a series of implementing regulations that set out how the new export framework will operate for certain strategic commodities. These exports will be channeled through the state-owned enterprise focused on natural resources exports, PT Danantara Sumberdaya Indonesia (“Export SOE”).

On 29 May 2026, MOT issued three key implementing regulations on three strategic commodities, namely:

1. MOT Regulation No. 15 of 2026 on Policy and Regulatory Framework for the Export of Coal as a Strategic Natural Resource Commodity (“MOT Reg. 15/2026”);

2. MOT Regulation No. 16 of 2026 on Policy and Regulatory Framework for the Export of Palm Oil as a Strategic Natural Resource Commodity (“MOT Reg. 16/2026”); and

3. MOT Regulation No. 17 of 2026 on Policy and Regulatory Framework for the Export of Ferro Alloy as a Strategic Natural Resource Commodity (“MOT Reg. 17/2026”).

Each regulation sets out the detailed operational framework for exporting of the respective strategic commodity, within MOT’s regulatory authority. Although palm oil, coal, and ferro alloy are prioritized, the framework of GR 24/2026 also allows the Government of Indonesia to revise and expand the list of strategic natural resource commodities through inter-ministerial coordination led by the relevant coordinating ministers. Issued to implement GR 24/2026, the regulations came into force on 1 June 2026 and provide for a transitional period until 31 December 2026, with full implementation commencing on 1 January 2027.

These MOT regulations principally address the operational aspects of the new centralized export regime, including the licensing requirements, export documentation, reporting obligations, and transitional arrangements required for exports to be conducted through the Export SOE.

Overview of Key Implementing Regulations

1. Coal Export Framework under MOT Reg. 15/2026

    

   MOT Reg. 15/2026 implements the coal export provisions under GR 24/2026 and establishes the regulatory framework governing Indonesia’s transition to a centralized coal export model.  The regulation, effective 1 June 2026, introduces a phased transition toward a state-controlled export model and replaces the previous coal export framework under MOT Regulation No. 23 of 2023 on Export Policies, as amended.

    

   At the same time, exporters are still required to hold coal Registered Exporter (Eksportir Terdaftar) status. Such licensing does not replace the mandatory export channel through the designated Export SOE; rather, it constitutes a prerequisite for compliance and a supporting document in the customs export process. The regulatory framework establishes a multi-layered compliance structure comprising government designation, exporter registration, technical verification, customs submission, and ongoing reporting obligations. 

The centralized export framework applies to several categories of coal and coal-related products classified under the following HS Codes:

In addition, MOT Reg. 15/2026 introduces a mandatory verification requirement for coal exports. Pursuant to this requirement, export activities must be subject to Verification or Technical Traceability conducted by a duly appointed surveyor, and the results of such verification must be formalized in a Surveyor Report. The Surveyor Report then becomes one of the mandatory supporting documents for customs submission, an additional prerequisite before export clearance. The commodities listed in the table above are all subject to Verification or Technical Traceability, as expressly set out in the Annex to MOT Reg. 15/2026

In terms of administrative and technical compliance, MOT Reg. 15/2026 further mandates the use of integrated electronic systems in the export process. Export-related data are to be processed through INATRADE and SINSW, with taxpayer identification data verified against electronic records sourced from OSS. In addition, the Surveyor Report must be submitted electronically through INATRADE and forwarded to SINSW. This is intended to streamline the process by reducing manual steps and improving coordination across systems.

From a practical standpoint, MOT Reg. 15/2026 is likely to require a recalibration of coal export arrangements, particularly for market participants that have traditionally managed coal export flows directly with overseas buyers. The new framework may affect contract structures, document flow, and operational timing, and it will therefore be important for exporters to review their existing arrangements to ensure alignment with the designated export channel, verification requirements, and reporting obligations. At the same time, the new regulatory framework may also bring greater clarity and consistency in the export process, particularly from a documentary and compliance standpoint.

2. Palm Oil Export Framework under MOT Reg. 16/2026

MOT Reg. 16/2026 introduces a significant restructuring of Indonesia’s export regime for palm oil and certain palm oil derivative products. The regulation forms part of the Government’s broader move towards a centralised, or ’single-gate‘, export framework for selected strategic commodities, under which exports of covered palm oil products must be channelled through the Export SOE. It replaces the previous framework under MOT Regulation No. 26 of 2024 on Export Policies of Palm Oil Derivative Products, as amended.

The stated policy objectives include safeguarding domestic supply, supporting the People’s Cooking Oil Program (Program Minyak Goreng Rakyat or “MGR”), strengthening oversight of palm oil exports, and improving governance of trade in strategic natural resource commodities.

From both a legal and commercial perspective, MOT Reg. 16/2026 may materially alter the role of private exporters in export transactions. Business actors that previously acted as the exporter of record for covered products may need to reassess their role under the new framework, including whether they will continue as holders of Export Rights (Hak Ekspor), or instead operate as suppliers, domestic sellers, processors, logistics providers, service providers, or other contractual counterparties to the Export SOE.

The regulation applies to the following strategic palm oil commodities:

The inclusion of UCO and palm oil derivative residues warrants particular attention. Unlike CPO and RBDPO, these products are frequently traded by businesses that are not vertically integrated within the palm oil production chain, such as traders and collectors. As exports of these products become subject to the centralized export framework, affected businesses should assess whether their existing direct-export business models remain viable and whether alternative commercial arrangements with the Export SOE will be required.

Under the new regime, the Export SOE must obtain an Export Approval (Persetujuan Ekspor) from the Ministry of Trade, which serves as a mandatory customs supporting document. MOT Reg. 16/2026 distinguishes between two principal types of Export Approval:

1. Export Approvals under the MGR Program, covering CPO, RBDPO, RBDPL, UCO, and palm oil derivative residues; and

2. Export Approvals under the Acceleration Program (Program Percepatan) for certain palm oil derivative products.

The issuance of an Export Approval is linked to the availability of Export Rights (Hak Ekspor). Importantly, MOT Reg. 16/2026 appears to separate the entitlement to Export Rights from the execution of the export itself. In practice, this may mean that business actors can continue to generate or hold Export Rights, while the export transaction for covered products must be implemented through the Export SOE.

The introduction of a centralised export mechanism, and the separation between Export Rights and export execution, may have significant implications for existing commercial arrangements. Export contracts that remain in force, or that require delivery during or after the transition period, should therefore be reviewed to assess whether they remain operationally and legally workable under the new framework.

3. Ferro Alloy Export Framework MOT Reg. 17/2026

MOT Reg. 17/2026 further regulates the centralized export mechanism introduced under GR 24/2026, as it applies to exports of ferro alloy and related products. With the enactment of this regulation, the previous provisions on Surveyor Reports (Laporan Surveyor) for ferro alloy exports by private exporters, set out under MOT Regulation No. 23 of 2023 on Export Policies, as amended, have been revoked and replaced.

At its core, MOT Reg. 17/2026 formally designates ferro alloys as a strategic commodity, consistent with GR 24/2026. Under this new framework, the export of ferro alloys will be managed exclusively by the Export SOE, with exemptions available for private businesses that meet certain domestic investment requirements.

The types of ferroalloys that are designated to be exclusively exported by the Export SOE are as follows: 

Under the previous framework MOT Reg. 23/2023, the export of the above ferro alloys was open to a wide range of exporters (including individuals, institutions, and both incorporated and unincorporated entities) provided that they held both a Business Identification Number (Nomor Induk Berusaha or NIB) and, where relevant, a Surveyor Report. MOT Reg. 17/2026 significantly alters this landscape by restricting ferro alloy export activities exclusively to the Export SOE. As a result, private business entities are no longer eligible to act as direct sellers of ferro alloys in international markets. Nevertheless, the Export SOE itself remains subject to the requirement to obtain Surveyor Reports for such export activities.

Notwithstanding the above, MOT Reg. 17/2026 provides exemptions for certain business actors from the centralized exporting regime. These exemptions are applicable for business actors holding ongoing contracts with the Government for the export of ferroalloy commodities, where such contracts cover specified aspects and have been endorsed through inter-ministerial coordination meetings. These aspects include:

1. investment; 

2. divestment; and 

3. domestic processing and/or refining activities.

Additionally, exports of ferroalloy products that are not subject to Surveyor Report (as described in part B of the table above) may also be exempted from the centralized exporting regime. This exemption may be granted to private businesses through the obtainment of an Exemption Letter (Surat Keterangan) issued by the Export SOE. 

At present, however, there is limited clarity on the types of contracts that would qualify for exemption, as well as the procedures and requirements for obtaining the Exemption Letter from the Export SOE. Further implementing regulations or guidance may therefore be issued to provide greater detail on the eligibility criteria and application process for such exemptions.

Transitional Arrangements

The three MOT regulations provide for a transitional period from 1 June 2026 until 31 December 2026, during which exporters may continue to conduct exports under existing arrangements, subject to the new centralized export mechanism. Across all three commodities, exports during the transition must be conducted through the designated Export SOE and will be subject to enhanced reporting and documentation requirements. In particular, exports facilitated by the Export SOE must be conducted through:

1. the submission of export reports and supporting documentation (including export contracts and related documents) to the Export SOE; and/or

2. the submission of additional required data or information through an integrated system connected to the Export SOE.

These transitional requirements appear to facilitate the gradual implementation of the centralized export regime while enabling the relevant authorities to establish the necessary administrative and reporting infrastructure ahead of its full implementation on 1 January 2027.

While the transitional framework is broadly consistent across the three commodities, each regulation preserves certain existing export entitlements. For coal exports, exporters remain subject to the applicable export reporting obligations while complying with the new reporting and documentation requirements through the Export SOE. For palm oil, Export Approvals issued prior to the enactment of MOT Reg. 16/2026 remain valid until their respective expiry dates, although exports under those approvals may only be carried out through the Export SOE during the transition period. Similarly, exporters of ferro alloys holding a valid Surveyor's Report may continue to export until 31 December 2026, provided that such exports are undertaken through the Export SOE.

ABNR Observations

The newly issued implementing regulations give further shape to the new centralized export framework. However, a number of important commercial points remain open, particularly from the perspective of private exporters and other market participants that will need to deal with the Export SOE.

The most important of these is the export pricing mechanism. GR 24/2026 provides that the Export SOE may determine the export selling price and apply a “reasonable” margin. However, the current regulations do not yet explain how this price or margin will be determined in practice. In particular, there is no clear guidance yet on whether:

1. the export selling price will be linked to a recognized international or domestic benchmark, such as an index-based price;

2. the price set by the Export SOE will operate as a floor price, reference price, or other administrative benchmark, similar to the approach used for certain other regulated commodities; or

3. there will be a prescribed methodology for determining, reviewing, or validating the Export SOE’s “reasonable” margin.

Until these points are clarified, the pricing mechanism is likely to remain an area of commercial uncertainty. This may be particularly relevant for private exporters and offtakers whose existing contracts rely on fixed pricing, index-linked pricing, formula-based pricing, or pricing tied to shipment or bill of lading dates.

Separately, although GR 24/2026 provides for certain exemptions from the centralized export regime, the current implementing regulations do not appear to fully address the scope or practical application of those exemptions. Further guidance will therefore be important to determine which products, transactions, exporters, or contractual arrangements may fall outside the centralized export mechanism, and what procedures or supporting documents will be required to rely on any exemption.

Pending further guidance, affected businesses should treat these issues as areas of regulatory and commercial uncertainty. Private exporters and other market participants should review how the new regime may affect their pricing arrangements, margins, payment flows, contractual commitments, and ability to perform existing export contracts.

By partners Emir Nurmansyah (enurmansyah@abnrlaw.com), Serafina Muryanti (smuryanti@abnrlaw.com), Maher Sasongko (msasongko@abnrlaw.com), associates Rizal Harahap (kharahap@abnrlaw.com), Kenny Poltak (kadrianus@abnrlaw.com), and Hikmatu Shalihah (hshalihah@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.