Regulation Watch · Business Licensing · Indonesia, for exports of covered coal, palm-oil products and ferro-alloy, including exports and supply arrangements involving Indonesian PT PMA and PT PMDN producers, processors, traders and logistics providers.
Strategic-Resource Exports Shift to State Enterprise in 2027
PP 24/2026 and Permendag 15-17/2026 allow transitional private exports of covered coal, palm-oil products and ferro-alloy only through 31 December 2026 before the export channel shifts to the designated state export enterprise, subject to documented exceptions.
- Published
- PP 24/2026 was established and promulgated on 20 May 2026. Permendag 15/2026, Permendag 16/2026 and Permendag 17/2026 were established and promulgated on 29 May 2026 in State Bulletin Nos. 347, 348 and 349 respectively.
- Effective
- The four instruments took effect on 1 June 2026. Their transition permits qualifying existing private-export routes through 31 December 2026 at the latest; from 1 January 2027 covered exports may be conducted only by the designated BUMN Ekspor unless a documented exception applies or the government sets an earlier handover date.
- Added to Watch
- 6 October 2026
Who is affected
Indonesian exporters, producers, processors and traders of covered coal, palm-oil products and ferro-alloy, including PT PMA businesses; foreign and domestic shareholders; directors; the designated BUMN Ekspor; overseas buyers; and licensing, customs, trade-compliance, tax, finance, logistics, insurance and contract teams supporting those exports.
Practical impact
Indonesia has replaced the ordinary private-export model for the initial strategic natural-resource commodities with a state-enterprise channel. During 1 June-31 December 2026, exports may continue under previously issued permissions, but exporters must deliver the prescribed reports and export documents to the BUMN Ekspor. Coal exporters continue using their own valid Eksportir Terdaftar and Surveyor Report during the transition. Palm-oil controls retain the relevant domestic-market obligations. The ferro-alloy rule divides 15 eight-digit HS 7202 tariff lines among prohibited goods, goods requiring a Surveyor Report and goods exportable without one. From 1 January 2027 at the latest, the BUMN Ekspor becomes the owner or sole intermediary for covered exports. A limited exception may apply to businesses with a government contract or agreement containing investment, divestment and domestic processing or refining commitments, but the required confirmation or certificate must be secured before relying on it.
The government established and promulgated PP 24/2026 on 20 May 2026 and made it effective on 1 June. The regulation initially designates coal, palm oil and ferro-alloy as strategic natural-resource commodities and provides that they may be exported only by a designated state-owned export enterprise, acting as owner or sole intermediary. Permendag 15/2026, 16/2026 and 17/2026, all promulgated on 29 May and effective on 1 June, supply the commodity-specific operating rules.
Implementation is staged. From 1 June through 31 December 2026, qualifying private exporters may continue using permissions issued under the transition, but they must submit the required reports and export documents to the BUMN Ekspor. The government may set an earlier completion date. From 1 January 2027 at the latest, the covered exports must move to the BUMN Ekspor channel, covering pre-clearance, customs-clearance and post-clearance processes.
The transition is not uniform across commodities. Covered coal includes anthracite, thermal coal, lignite and peat within relevant HS 2701-2703 classifications; an existing Eksportir Terdaftar remains usable only until its earlier expiry or 31 December 2026, together with the required Surveyor Report. Palm-oil products remain subject to the applicable Export Approval, reporting and domestic-market obligations, including Minyakita distribution requirements. The ferro-alloy rule classifies 15 eight-digit HS 7202 lines into prohibited goods, goods requiring a Surveyor Report and goods exportable without one during the transition.
PP 24/2026 permits an exception for a business whose government contract or agreement contains investment, divestment and domestic processing or refining commitments. The implementing framework requires documentary confirmation before a non-BUMN exporter can use that route. A business should not treat its foreign-investment status, processing activity or government relationship alone as an automatic exemption.
Exporters should now complete product and HS-code mapping, validate every transitional licence and report, identify the BUMN Ekspor process and renegotiate 2027 commercial terms. Contracts signed before 1 June 2026 require particular attention because the regulation calls for the BUMN Ekspor to evaluate continuing sales contracts rather than preserving them automatically.
Late discovery: the four instruments were issued in May 2026 and took effect on 1 June, but they were not previously recorded in the Regulation Watch ledger. The year-end private-export cutoff and the mandatory state-enterprise channel from 2027 make the change material and time-sensitive for affected investors and operating companies.
Required action
- Map every planned 2026-2027 shipment to the exact commodity description and HS code under Permendag 15/2026, 16/2026 or 17/2026; do not assume that every coal, palm-oil or ferro-alloy product receives identical treatment.
- For shipments through 31 December 2026, verify that the exporter still holds the required existing licence or approval, Surveyor Report or other supporting document, and submit the required export reports and documents to the designated BUMN Ekspor.
- Coal exporters should confirm the validity end date of their Eksportir Terdaftar; an existing registration expires on its stated earlier date or on 31 December 2026 at the latest.
- Palm-oil exporters should revalidate the applicable Export Approval, reporting and Minyakita domestic-market obligations, including the required distribution chain and allocations, before committing shipment volume.
- Ferro-alloy exporters should classify each product against the 15 eight-digit HS 7202 lines and document whether it is prohibited, requires a Surveyor Report, or may be exported without one during the transition.
- Renegotiate 2027 supply, agency, pricing, freight, insurance, payment, tax and liability terms with the BUMN Ekspor and overseas buyer, and test the pre-clearance, customs-clearance and post-clearance workflow before the handover date.
- If relying on the government-contract exception, obtain the required BUMN Ekspor confirmation or certificate and retain the underlying government agreement showing the qualifying investment, divestment and domestic processing or refining terms.
- Review contracts signed before 1 June 2026 because PP 24/2026 requires the BUMN Ekspor to evaluate continuing sales contracts; do not assume a legacy contract preserves the private-export route after the transition.