Regulation Watch · Business Licensing · Indonesia. The amendment applies to qualifying natural-resource exporters whose transactions fall within the special DHE SDA provisions for a bilateral trade agreement, memorandum of understanding or other trade arrangement, together with the banks designated for that implementation.
BI Activates Special DHE Oversight for Bilateral-Trade Exports
PBI 8/2026 and PADG 33/2026 activate special DHE supervision for qualifying natural-resource exporters, including inter-agency list matching, a published eligible-exporter list and a formal route to question or opt out of special treatment.
- Published
- Bank Indonesia established PBI 8/2026 on 29 September 2026 and PADG 33/2026 on 30 September 2026. The official PBI page was updated online on 8 October and the official PADG page was updated on 19 October. The related PP 21/2026 was established and promulgated on 6 May 2026 in State Gazette 2026 No. 50 and Supplement No. 7175.
- Effective
- PBI 8/2026 and PADG 33/2026 have applied since 30 September 2026. The coordinated special implementation applies to Export Customs Declarations (Pemberitahuan Pabean Ekspor or PPE) issued from 1 September 2026.
- Added to Watch
- 8 October 2026
- Updated
- 22 October 2026
Who is affected
PT PMA and PT PMDN natural-resource exporters, foreign and Indonesian shareholders and directors, exporters operating under a qualifying bilateral trade arrangement, designated Indonesian banks, and finance, treasury, customs, trade, legal and compliance teams responsible for export proceeds and SiMoDIS reporting.
Practical impact
PADG 33/2026 now supplies the formal operating procedure behind PBI 8/2026. The eligible-exporter list is set through inter-agency coordination, uses the NPWP as the single matching key and may use other agreed data, then is published through Bank Indonesia. An exporter may request information or confirmation from the Coordinating Ministry for Economic Affairs with copies to the Ministry of Finance and Bank Indonesia. Bank Indonesia may coordinate when designating the bank used for the special DHE SDA implementation, and its supervision may rely on the eligible-exporter list as well as natural-resource-marked PPE. The implementation applies to PPE issued from 1 September 2026. Bank Indonesia's October SiMoDIS notice identifies the eligible exporters used to supervise September PPE. A listed exporter must either comply with the Article 18A package as a whole or submit the prescribed opt-out statement by the date stated in the published list. The October 2026 list set that date at 16 October, and an exporter that filed the statement previously did not need to repeat it.
Bank Indonesia established PBI 8/2026 on 29 September 2026 and made it effective on 30 September. The official BI page was updated on 8 October with the regulation summary, signed instrument, frequently asked questions and supporting archive. The amendment is the third change to PBI 7/2023 on export proceeds and import-payment foreign exchange.
The amendment supports the special DHE SDA provisions for natural-resource exports carried out under a bilateral trade agreement, memorandum of understanding or other trade arrangement. The government basis is Article 18A of PP 36/2023 as most recently amended by PP 21/2026. This is a targeted route: the existence of an export, a foreign buyer or PT PMA status alone does not establish that the special provisions apply.
PBI 8/2026 makes two institutional changes material to exporters. Bank Indonesia may consider input or coordination results from other ministries and agencies when designating the bank for the special implementation, and the regulation expressly authorises BI supervision of natural-resource exporters that meet the relevant criteria. It also states that BI will take account of or coordinate with the competent ministries and agencies when implementing DHE SDA policy.
PADG 33/2026, established and effective on 30 September, now puts the operating steps into the implementing rule. The eligible-exporter list results from inter-agency coordination, uses the NPWP as the single matching key and is published through Bank Indonesia. An exporter that needs information or confirmation about its status may write to the Coordinating Ministry for Economic Affairs with copies to the Ministry of Finance and Bank Indonesia. A listed exporter that does not use the special treatment must submit the prescribed opt-out letter by the date stated in the publication.
Timing is tied to the customs declaration. BI states that the coordinated special implementation applies to PPE issued from 1 September 2026. Exporters should therefore isolate September declarations and later PPE, map them to the government trade arrangement relied on and confirm the designated bank before deciding how the proceeds may be received, placed, used or converted.
Bank Indonesia's October SiMoDIS notice adds an immediate election deadline. The October eligible-exporter list is the basis for supervising DHE SDA obligations for September PPE. An exporter on that list must treat the Article 18A duration, placement amount and designated bank as one indivisible package if it uses the special route. If it opts out, it must send the prescribed statement to Bank Indonesia with the stated government copies by 16 October 2026. A company that submitted the opt-out statement previously does not need to repeat it.
PBI 5/2026 remains part of the underlying framework. It limits ordinary DHE SDA receipt and placement to state-owned banks, adds specified foreign-currency government securities as placement instruments, regulates rupiah conversion and gives BI authority to designate a bank for the special bilateral-trade route. PBI 8/2026 does not restate those rules or create a new general retention percentage; it activates the coordinated application and supervisory basis for the qualifying special cases.
The practical control is a transaction-level evidence file. The PPE, export contract and invoice, customs data, qualifying trade-arrangement basis, designated-bank confirmation, receipt and account records, placement or use, conversion and SiMoDIS data should reconcile. Where the route or bank designation is uncertain, the exporter should obtain written confirmation before moving funds rather than attempting to correct the classification after a supervisory query.
Required action
- Check the October 2026 eligible-exporter list attached to PBI 8/2026 immediately. If the company is listed, document whether it will use the Article 18A special route or opt out.
- Reconcile the NPWP and other identifiers used for customs, tax, corporate and SiMoDIS records because PADG 33/2026 makes the NPWP the single key for inter-agency matching of the eligible-exporter list.
- If the company is unexpectedly included, omitted or mismatched, send a written information or confirmation request to the Secretary of the Coordinating Ministry for Economic Affairs with copies to the Director General of Economic and Fiscal Strategy at the Ministry of Finance and Bank Indonesia.
- If a listed exporter chooses not to use the special route and has not submitted the statement before, send the prescribed statement to the Head of Bank Indonesia's Department of Reporting Management and Compliance, with copies to the Secretary of the Coordinating Ministry for Economic Affairs and DJSEF, no later than 16 October 2026.
- Do not split the Article 18A package. A listed exporter that uses the special route must follow its duration, placement amount and designated-bank requirements together, and Bank Indonesia states that the choice is made once.
- Identify every natural-resource export linked to a bilateral trade agreement, memorandum of understanding or other government-recognised trade arrangement, and document whether the exporter and transaction meet the special-regime criteria.
- Separate PPE issued from 1 September 2026 from earlier declarations, because the coordinated special implementation applies from that PPE date even though PBI 8/2026 itself took effect on 30 September.
- Confirm with the relationship bank which bank Bank Indonesia has designated for the relevant special implementation before directing, placing, using or converting the export proceeds; do not assume that an existing account or ordinary DHE route is sufficient.
- Reconcile the PPE number and date, export value, customs and trade documents, proceeds received, bank account, placement or use, any rupiah conversion and the data reported through SiMoDIS or another required channel.
- Keep the company's registered SiMoDIS email and responsible officers current, monitor the account and inbox, and answer any Bank Indonesia reminder or clarification with complete evidence within the period stated in the notice.
- Where eligibility, bank designation or treatment of a September PPE is unclear, obtain written confirmation from the designated bank or Bank Indonesia before moving the funds or treating the transaction as compliant.