Entering into force on 1^st of June, 2026, the Government Regulation No. 24 of 2026 regarding Export Governance for Strategic Natural Resources commodities (“GR 26/2026”) introduces a centralized state-managed paradigm for the export of key commodities. The Government establishes a specialized State – Owned Enterprise namely PT Danantara Sumber Daya Indonesia (“Export SOE”).

GR 26/2026 grants the Export SOE with statutory powers to regulate markets and acts as:

1. The Sole Exporter: The Export SOE holds the exclusive mandate to export designated strategic natural resources by 31 December 2026;
2. Price Determinant: The Export SOE is empowered to fix and determine the export selling price of these commodities; and
3. Margin Regulation: The Export SOE holds the authority to determine and enforce profit margin deemed proper and aligned with national economic interest.

At an initial phase, the GR 26/2026 will focus coal, palm oil and ferro alloys. GR 26/2026 mandates a full transition to this centralized model in the near term. During the transition period between the date of the enactment and 31 December 2026, the Export SOE will serve as a sole intermediary for coal exports. From 31 December 2026 onward, all designated strategic natural resources commodities (including coals) must be exported exclusively through this Export SOE.

Export contracts executed prior to 1 June 2026 remain legally valid and binding. However, performance under these pre-existing contracts is now subject to the direct supervision and evaluation of the Exports SOE. Notably, GR 26/2026 is silent on the scope of this evaluation, including whether or not pre-existing contracts can be amended to satisfy the Export SOE’s requirements.

According to the Ministry of Trade Regulation No. 15 of 2026 on Export Policies and Regulations for Strategic Natural Resources Coal which serves as the implementing regulation, private business entities may continue to export coal until 31 December 2026, provided that:

1. Export activities may only be conducted through the Exports SOE acting as the sole intermediary. Consequently, private exporters are required to:

1. reporting and submitting export documents, sales contract and other related documents to the Export SOE; and
2. providing supplementary data and information upon request by the Export SOC via various integrated digital platforms.

2. The coal trading company or IUP holder (the exporter) must hold a Registered Coal Exporter Permit (Exportir Terdaftar), valid until 31 December 2026.
3. Submitting export realization reports to the Ministry of Trade.

In conclusion, private business entities may currently continue their export activities under existing sales contracts, subject to supervision by the Export SOE. However, after 31 December 2026, private entities will be prohibited from exporting coal, as all export activities will become the exclusive purview of the Export SOE.

If you have any questions or would like to discuss further about this topic, please do not hesitate to contact our partner Arselan Ruslan (arselan@ansslaw.com) or your usual contact at ANSS Counsellors at Law.

***

Disclaimer

The contents of this publication include legal updates, transaction or case highlights, activities, awards, news, and legal insight, and are provided solely for educational and informational purposes. ANSS assumes no responsibility for any loss or consequences arising from the use of this information. The use of this site or publication does not create an attorney - client relationship.