Regulation Watch · Business Licensing · Indonesia. The regulation applies nationally to businesses operating across the trade chain, including PT PMA and PT PMDN importers, exporters, producers, distributors, agents, wholesalers, retailers, direct-selling companies, shopping-centre and supermarket operators, warehouse owners, managers and tenants, and producers or importers of regulated goods. It also affects their directors, shareholders, foreign managers, customs, procurement, logistics, product-compliance, licensing and legal teams.
Indonesia Rewrites Trade, Distribution and Warehouse Controls
Government Regulation 3/2026 immediately amends Indonesia's trade-administration framework for import controls, distribution chains, direct selling, warehouses, shopping centres, retailers, regulated products, inspections and administrative sanctions.
- Published
- Established and promulgated in Jakarta on 15 January 2026 in State Gazette 2026 No. 5, Supplement No. 7156. It was first recorded by Regulation Watch on 11 October 2026 as a late-discovered instrument.
- Effective
- 15 January 2026, the date of promulgation specified by Article II.
- Added to Watch
- 11 October 2026
Who is affected
PT PMA and PT PMDN importers, exporters and producers; distributors, agents, wholesalers and retailers; direct-selling and multi-level-marketing companies; shopping-centre and supermarket operators; warehouse owners, managers and tenants; manufacturers, importers and packers of goods subject to Indonesian-language labelling, mandatory SNI or technical requirements, K3L registration or type approval; foreign and Indonesian directors and managers; and licensing, customs, product, commercial, warehouse, logistics, legal and compliance teams.
Practical impact
PP 3/2026 changes 66 provisions of PP 29/2021 and aligns trade administration with the current risk-based licensing system. Import supervision now expressly covers the NIB as importer identification, import business licensing, technical verification and destination-port requirements, with post-customs supervision by the Ministry of Trade. Indirect distribution must be supported by written agreements, appointments or transaction evidence, and each distributor, agent, wholesaler and retailer must hold licensing matching its actual role. Distributors must control a registered warehouse. Warehouse owners, managers or tenants storing goods for trade must keep prescribed stock records, produce them to inspectors and report staple or important goods electronically each month. The regulation also refreshes direct-selling controls, shopping-centre and supermarket licensing, Indonesian-language labels, mandatory product registration, K3L goods registration and trade-measurement requirements. It replaces the separate 2019 unregistered-warehouse sanctions regulation and the earlier presidential regulations on K3L goods and traditional markets, shopping centres and modern stores.
Government Regulation 3/2026 was established and promulgated on 15 January 2026 in State Gazette 2026 No. 5, Supplement No. 7156, and took effect that day. It changes 66 provisions of PP 29/2021 on trade administration and does not provide a general grace period. The amendment is intended to align trade rules with the current risk-based licensing framework and reorganised government responsibilities for food and non-food commodities.
For importers, the revised supervision framework expressly covers the NIB used as importer identification, import business licensing, technical verification or tracing and destination-port requirements. Customs supervises in the customs area, while the Ministry of Trade supervises after the goods pass through it and may also work with customs in the customs area. Importing goods contrary to an import restriction is an administrative violation, and the Minister may request that the finance minister prohibit an offending importer from further import activity.
The domestic distribution rules now focus on verifiable commercial relationships and correct licensing. Distributors, agents and franchises need written agreements; wholesalers and retailers need an agreement, appointment or written transaction evidence. Distributors, agents, wholesalers and retailers must hold the licence matching their role, while distributors must also control a registered warehouse. Producers outside the domestic-producer category must appoint a distributor or agent to distribute goods to retailers, and an exclusive distributor or agent appointment prevents appointment of another for the same goods and brand in that territory.
Warehouse compliance is operational. Every owner, manager or tenant storing goods for trade must keep records of the goods owner and NIB, product, unit, opening stock, receipts, dispatches, dates, origin, destination and remaining stock, plus sale prices for staple and important goods. The records must be available to trade inspectors when required, authorities may request current availability data, and warehouses holding staple or important goods must report the records electronically each month. Commercial warehouse contracts should therefore authorise lawful data disclosure and allocate filing responsibility.
The amendment also refreshes product and retail controls. Producers and importers must register goods subject to mandatory SNI or technical requirements before domestic sale or import and place the registration number on the goods or packaging. Electrical, electronic and hazardous-chemical goods meeting the K3L criteria must be registered before market circulation unless an express exception applies. Indonesian-language label duties continue to cover domestic, imported and locally packed goods, including e-commerce and direct-selling channels. Shopping centres and supermarkets must hold risk-based trade licensing, and own-brand sourcing rules protect identifiable MSME producers.
Direct-selling businesses receive a more detailed compliance framework. Marketing plans and codes of ethics must be in Indonesian and cover prescribed commercial, commission, complaint and dispute terms. Exclusive distribution rights must be traceable to the trademark owner or ownership record. The regulation prohibits pyramid schemes, unlisted products, services and investment products, sales through unauthorised indirect or online channels, and use of a virtual office or co-working space without a permanent physical workspace as the licensed address.
Enforcement can move beyond warnings. Inspectors may secure goods or locations and require truthful data. The Minister may order goods temporarily withheld from circulation, re-exported or destroyed, while specified goods may instead be auctioned or donated. Sanctions include temporary suspension, closure of a business or warehouse, withdrawal of goods, administrative fines and licence freezing or revocation. A revoked business licence generally cannot be re-applied for until five years after revocation.
PP 3/2026 also revokes PP 33/2019 on sanctions for unregistered warehouses, Presidential Regulation 63/2018 on K3L goods registration and Presidential Regulation 112/2007 on traditional markets, shopping centres and modern stores. Operators should use the amended PP 29/2021 framework together with current ministerial and sector implementing rules rather than treating those older instruments as stand-alone compliance bases.
Late discovery: PP 3/2026 took effect in January 2026 but was not previously present in the Regulation Watch ledger. The official national regulation database, signed gazetted text and Ministry of Trade JDIH record now provide the primary-source basis for publication without changing the regulation's true legal dates.
Required action
- Reconcile every active trade role against the company's NIB, KBLI, importer identification, sector business licence and PB-UMKU. A company acting as importer, distributor, agent, wholesaler, retailer, direct seller, warehouse operator or shopping-centre operator should not rely on a licence for a different role.
- Audit import files so commodity restrictions, approvals, technical verification, destination ports, quantities and customs declarations are complete and consistent. Build a pre-clearance check and a post-customs evidence file for each regulated shipment.
- Document the distribution chain. Distributors, agents and franchises need written agreements; wholesalers and retailers need a written agreement, appointment or transaction evidence. Confirm exclusivity, territory, goods, brand, term and termination, and retain the supporting trademark chain where direct-selling rights depend on it.
- For each warehouse used to store goods for trade, confirm registration and the correct warehouse classification, and keep records of the goods owner and NIB, product, unit, opening stock, receipts, dispatches, dates, origin, destination, remaining stock and—where applicable—sale price.
- Give warehouse contracts an express authority for the owner, manager or tenant to provide stock data requested by the competent authority. Where staple or important goods are stored, implement the required monthly electronic warehouse report and retain submission evidence.
- Review all goods sold in Indonesia for Indonesian-language labelling and identify goods requiring mandatory SNI or technical registration, K3L registration, type approval or another sector registration before import or market circulation. Confirm that the registration number is placed on the goods or packaging where required.
- Shopping-centre and supermarket operators should reconcile their trade licences, construction approvals and premises, own-brand sourcing and MSME arrangements. Own-brand products made by an MSME must identify that MSME, and a supermarket may not force an MSME with its own brand to use the supermarket's brand.
- Direct-selling companies should revalidate exclusive distribution rights, Indonesian-language marketing plans and codes of ethics, seller age and identity controls, permitted channels, product lists and anti-pyramid safeguards; virtual offices or co-working spaces without a permanent physical workspace are prohibited for the licensed business address.
- Prepare an inspection-response protocol that can rapidly provide truthful records and preserve goods or locations placed under official security measures. Do not move secured goods or break official seals, and escalate any order to stop circulation, re-export or destroy goods immediately.