Regulation Watch · Business Licensing · Indonesia, including foreign-exchange purchases and outbound foreign-currency transfers conducted through Indonesian banks by PT PMA companies and other bank customers in Bali.
Lower FX Thresholds Now Require Earlier Supporting Documents
Bank Indonesia PADG 13/2026 and PADG 15/2026 require supporting documents for outbound foreign-currency transfers above USD25,000 and underlying documents for monthly spot FX purchases above USD10,000.
- Published
- PADG 13/2026 was established on 18 June 2026 and PADG 15/2026 on 29 June 2026. Bank Indonesia published their official regulation pages on 18 June and 6 July 2026 respectively; the instruments do not state separate promulgation dates.
- Effective
- Both instruments took effect on 1 July 2026.
- Added to Watch
- 28 September 2026
Who is affected
PT PMA and PT PMDN companies; foreign investors and shareholders; exporters, importers and other businesses paying foreign suppliers, lenders, licensors, overseas employees or shareholders; directors, finance and treasury teams; expatriates and other Indonesian bank customers purchasing foreign currency against rupiah or sending foreign currency abroad.
Practical impact
A spot purchase of foreign currency against rupiah now needs an underlying transaction when the amount exceeds USD10,000 or its equivalent per month per transaction party, down from USD25,000. Separately, an outbound transfer in foreign currency above USD25,000 or its equivalent now needs supporting documents, down from USD50,000. The bank must check those transfer documents before accepting the payment order. The transfer rule also covers natural-resources exporters using a special DHE SDA account, but does not apply to a bank acting for itself or to a domestic transfer between accounts held by the same customer. A company that first buys the currency and then remits it abroad may therefore encounter both documentary tests.
Late discovery: Bank Indonesia issued two linked amendments that took effect on 1 July 2026. PADG 15/2026 lowered the monthly threshold for a spot purchase of foreign currency against rupiah that requires an underlying transaction from USD25,000 to USD10,000 per transaction party. PADG 13/2026 lowered the supporting-document threshold for an outbound foreign-currency transfer from above USD50,000 to above USD25,000.
The tests apply to different stages and should not be merged operationally. PADG 15 governs the purchase of foreign currency against rupiah, while PADG 13 governs the outbound transfer of foreign currency. Buying foreign currency under a documented import, loan, royalty, dividend, salary or other obligation does not remove the separate need to support the later remittance when its value exceeds USD25,000.
For an outbound transfer above USD25,000, the customer must give the bank the supporting documents and the bank must confirm completeness before accepting the payment order. The regulation identifies examples including invoices from overseas sellers of goods or services, loan documents, royalty and other intellectual-property obligations, shareholder-meeting documents supporting an overseas dividend, employment documents, domestic asset-liquidation records for a foreign party, and documents supporting an exemption or deferral from mandatory rupiah use.
The outbound-transfer exception is narrow. It covers a bank's own transaction and a domestic movement of deposits between accounts held by the same customer. The rule also applies to natural-resources exporters transferring foreign currency out through a special DHE SDA account.
PADG 13 included a transition for transfers above USD25,000 up to USD50,000 made during July 2026: a customer letter stating the date, amount and reason could be used temporarily, but the full supporting documents must be completed by 31 October 2026. PADG 15 gave July spot purchases above USD10,000 up to USD25,000 until 7 August 2026 for underlying-document submission and related bank-report correction; that deadline has already passed.
PT PMA finance teams should therefore move document collection ahead of the deal and payment date, rather than treating it as a bank follow-up. Monthly FX-purchase tracking, payment-purpose coding, approval records and bank-specific submission requirements should be reconciled before a transaction is released.
Required action
- Set treasury controls to identify cumulative monthly spot purchases of foreign currency against rupiah above USD10,000 or equivalent for each transaction party before the order reaches the bank.
- Prepare the underlying transaction record before a covered FX purchase and the supporting file before an outbound transfer above USD25,000; confirm the exact format and submission channel with the processing bank.
- For outward payments, retain documents that match the payment purpose, such as a foreign supplier invoice, loan agreement and interest or principal schedule, royalty or intellectual-property agreement, shareholder-meeting dividend record, employment document, asset-liquidation record, or applicable rupiah-use exemption or deferral document.
- Reconcile the beneficiary, purpose, currency, amount, invoice or contract, approval and payment date so the bank can verify the file without holding or rejecting the transaction.
- Review every July 2026 outbound transfer above USD25,000 up to USD50,000 that relied on the temporary customer letter and complete the prescribed supporting file no later than 31 October 2026.
- Review July 2026 spot FX purchases above USD10,000 up to USD25,000 whose transitional underlying-document and bank-report correction deadline was 7 August 2026, and promptly resolve any missing file with the bank.