Indonesia’s export regime for strategic natural resources may soon undergo one of its most significant structural changes in recent years. The Government is reportedly preparing a regulation that would centralize the export of certain commodities through PT Danantara Sumber Daya Indonesia (“DSDI”), which is expected to function as the primary intermediary between domestic producers and international buyers.
Under the current export framework, companies exporting commodities such as crude palm oil (“CPO”) and coal are generally permitted to negotiate and transact directly with foreign purchasers. The proposed framework would fundamentally alter this arrangement by requiring exports to be conducted through DSDI rather than independently by producers or private exporters.
This proposed regulation is reportedly intended to address under-invoicing in export activities, a practice of reporting export prices below their actual value. According to the Government, under-invoicing can reduce potential tax and royalty revenues, limit the inflow of foreign exchange into the domestic economy, and weaken oversight of national trade flows. The proposed framework is also viewed as part of a broader effort by the Government to strengthen Indonesia’s bargaining power in global commodity markets.
Which Commodities Will Be Affected?
At the initial stage, the policy is expected to apply to exports of CPO and coal, while additional strategic commodities may later be included on the recommendation of the Government. The proposed regulation would reportedly authorize the Government to amend the list of strategic natural resource commodities subject to the scheme and to designate additional commodities based on recommendations made through a coordinating meeting involving the relevant ministries and non-ministerial government agencies.
Implementation Timeline and Transitional Arrangements
To facilitate implementation of the new framework, Danantara has indicated that all existing contracts will be respected, but DSDI may review export agreements whose pricing is considered below prevailing global market benchmarks. There is a transitional period for companies to give exporters sufficient time to adjust to the new regime.
According to publicly available information, the transition period for the proposed export regime was expected to run from June 1, 2026, to August 31, 2026, although, to date, no official publication or regulation has been issued by the Government. During this initial phase, exporters would reportedly be permitted to continue transacting directly with foreign buyers under the existing framework. However, exporters would be required to submit all export reports, transaction values, pricing information, and supporting documentation to DSDI. This transition period appears intended to provide the Government with greater visibility into export activities and pricing practices before the centralized export mechanism becomes fully operational.
Following the transition period, the next phase of implementation is expected to commence. At this stage, export activities, including negotiations, contracting, invoicing, and payment processing, would reportedly be conducted through DSDI rather than directly by exporters.
The transitional provisions, according to publicly available information, further stipulate that, until December 31, 2026, exports of strategic natural resource commodities may only be carried out through a designated state-owned export enterprise. Following the expiration of this transitional period, the centralized export mechanism is expected to become fully operational.
Unresolved Questions Around Pricing and Commercial Terms
Another notable aspect of the proposed framework concerns pricing authority. Under the new structure, DSDI would reportedly negotiate export prices with international buyers on behalf of producers and the State, while producers would be required to channel their commodities through DSDI prior to export.
Despite the broad authority envisioned for DSDI, the mechanism governing domestic pricing between producers and DSDI remains unclear. To date, no detailed guidance has been issued regarding how purchase prices will be determined, the applicable pricing formula, or the safeguards that will be implemented to ensure fairness and transparency for producers operating in the new system.
Ultimately, while the Government frames the proposed export body as a mechanism to combat under-invoicing and strengthen oversight of export revenues, many market participants view it as a far broader strategic shift. Beyond its objectives relating to taxation and monitoring, the policy could mark the beginning of a more centralized approach to commodity trade, allowing the State to exert greater control over foreign exchange inflows, strengthen Indonesia’s bargaining position in global markets, and play a more direct role in strategic exports.
However, the success of such a system will largely depend on whether it can improve transparency and economic resilience without creating excessive bureaucracy, inefficiency, or concentrated control over the country’s export ecosystem.
What This Means for Business
Companies involved in Indonesia’s commodity export sector should closely monitor developments relating to the proposed framework. If implemented in its current form, the regime may require significant adjustments to existing export structures, pricing arrangements, contractual frameworks, reporting obligations, and foreign buyer relationships.
It is also recommended that companies assess their existing offtake contracts, particularly provisions relating to changes in law and required contractual notices/approvals, considering that the proposed regulatory framework change could significantly alter existing export structures by requiring DSDI to act as the export intermediary. (4 June 2026)
For more information, please contact:
Michael S. Carl, Senior Foreign Counsel, SSEK
MichaelCarl@ssek.com
