Overview
The Government of Indonesia has introduced a new export governance framework for strategic natural resource commodities through Government Regulation No. 24 of 2026 on the Export Governance of Strategic Natural Resource Commodities (“GR 24/2026”), issued on 20 May 2026 and effective from 1 June 2026.
GR 24/2026 establishes a centralized framework under which designated strategic natural resource commodities are exported through a designated state-owned company for export purposes. The Government has identified PT Danantara Sumberdaya Indonesia (“DSI”) as the relevant company, acting either as owner or as the sole intermediary.
The framework forms part of the Government’s broader effort to strengthen oversight and transparency in strategic commodity exports, support domestic supply and national economic resilience, reduce mis-invoicing and improve the integrity of trade and export-proceeds data.
Key Provisions
For coal, for example, registered-exporter authorization issued before the new regulation remains valid until 31 December 2026 or its earlier expiry. Such authorization, together with the applicable surveyor documentation, may be used for transitional coal exports through DSI. The applicable transitional arrangements also require reporting and submission of export documents, sales contracts and other relevant information.
Businesses should therefore maintain contemporaneous documentation supporting pricing adjustments and other relevant comparability factors while monitoring further binding technical rules or guidance.
Conclusion
GR 24/2026 represents a significant change in Indonesia’s governance of strategic natural-resource exports, initially covering specified coal, palm-oil and ferro-alloy products. The principal compliance issue during the 2026 transition is how the new reporting and oversight framework interacts with each exporter’s existing authorizations, commodity-specific requirements, transaction structures and contracts.
Businesses exporting covered products should promptly map their products against the applicable tariff classifications; confirm the validity and transition treatment of their licenses, approvals and surveyor documentation; review contracts signed before 1 June 2026 and maintain appropriate pricing documentation for potential DSI evaluation; and establish processes for timely submission of required contracts, export documents and transaction data.
Businesses entering new export arrangements should also address DSI’s role expressly in their contracting, invoicing, documentation, information-sharing and operational workflows.
For more information or inquiries, please contact:
Andika Mendrofa at andika.mendrofa@nusaadvocates.com
Shanti Prameshwara at shanti.prameshwara@nusaadvocates.com
Sharon Solomon at sharon.solomon@nusaadvocates.com
Following the recent amendments to Law No. 4 of 2009 on Mineral and Coal Mining and Government Regulation No. 96 of 2021 on the Implementation of Mineral and Coal Mining Activities, the Minister of Energy and Mineral Resources has issued the mandated implementing regulation.
Ministry of Energy and Mineral Resources Regulation No. 5 of 2025 updated guidelines for renewable energy Power Purchase Agreements in Indonesia, aiming to enhance investor clarity and expand coverage to a broader range of energy sources.
KBLI 2025 has been officially implemented in the AHU Online and OSS systems since 15 June 2026, requiring businesses to review the alignment of their KBLI classifications, corporate records, and licensing with the new classification framework.
