Indonesia Overhauls Export Proceeds Requirements For Natural Resources.
The Government of Indonesia is set to introduce a revised regulatory framework governing the placement of export proceeds derived from natural resources (Devisa Hasil Ekspor Sumber Daya Alam or “DHE SDA”), scheduled to take effect on January 1, 2026.
Currently, the DHE SDA regime is governed by Government Regulation No. 36 of 2023 regarding Foreign Exchange Export Proceeds from the Business, Management and/or Processing of Natural Resources, as amended by Government Regulation No. 8 of 2025 (“GR 36/2023”). The forthcoming revision represents a recalibration of the existing framework, signalling a more centralised and structured approach to the domestic placement of export proceeds.
GR 36/2023 was originally introduced to strengthen Indonesia’s foreign exchange reserves and support the stability of the rupiah by regulating the treatment of foreign currency earnings from natural resource exports. However, recent developments, including increased foreign currency transactions, declining foreign currency placements, and persistent capital outflows by residents linked to investment deficits, have highlighted limitations in the effectiveness of the current regime.
The revised framework is intended to address these challenges by providing clearer guidance on the placement and use of DHE SDA, improving the management of export proceeds and strengthening support for the domestic financial system.
To provide a clearer picture of what these strategic considerations entail, we outline the key changes in the DHE SDA provisions under the revised government regulation.
Centralisation of Eligible Placement Institutions
One of the most consequential changes under the revised framework is the restriction of eligible placement institutions. Currently, DHE SDA may be placed not only with private and state-owned banks, but also with the Indonesia Eximbank (Lembaga Pembiayaan Ekspor Indonesia or “LPEI”). Under the new framework, placements will be limited exclusively to state-owned banks authorized to conduct foreign exchange activities.
The centralisation reflects a deliberate policy shift toward a more controlled and coordinated management of DHE SDA. This change significantly narrows the universe of eligible institutions and will require exporters that currently utilize private banks, foreign-owned banks, or LPEI to restructure their banking arrangements to channel export proceeds solely through designated state-owned banks.
Retention Period and Conversion Constraints
GR 36/2023 currently requires that, in general, 100% of DHE SDA be retained for a minimum of 12 months, reinforcing the policy objective of maintaining domestic foreign currency reserves and supporting the banking sector. This retention obligation remains a key mechanism for ensuring macroeconomic stability while governing the management of export proceeds.
However, the upcoming framework will introduce new limitations on currency conversion. Exporters will be permitted to convert DHE SDA into rupiah, but only up to a maximum of 50% of the retained funds. This change significantly reduces the current flexibility in managing liquidity needs and foreign exchange exposure.
Placement Instruments and Permitted Use of DHE SDA
Another notable development is the recognition of foreign-currency-denominated government securities (Surat Berharga Negara Valuta Asing or “SBN Valas”) as an eligible placement instrument for DHE SDA. While SBN Valas may offer higher returns than conventional deposits, exporters should be aware that funds cannot be freely withdrawn during the retention period, requiring careful consideration of both potential yields and short-term liquidity needs.
Concurrently, the scope of permitted uses of DHE SDA during the retention period has been broadened. Exporters will be able to utilise these funds for the repayment of loans, including working capital facilities, without the previous requirement that such goods or services be unavailable domestically. Together, these changes provide greater flexibility in both the placement and utilisation of DHE SDA.
As noted above, the revised DHE SDA framework will apply in full to export declarations (pemberitahuan pabean ekspor or “PPE”) issued on or after January 1, 2026. Export proceeds arising from declarations issued prior to that date will remain subject to transitional arrangements.
Conclusion
The new DHE SDA framework introduces a more structured and less discretionary regime for managing export proceeds by introducing stricter placement requirements, defined retention and conversion rules, and the inclusion of additional placement instruments such as SBN Valas. These measures are intended to reinforce domestic foreign currency reserves, support the stability of the rupiah, and improve regulatory oversight of export earnings.
At the same time, exporters may face reduced flexibility in currency conversion and bank selection. Compliance with these obligations is increasingly intertwined with strategic financial planning, making early preparation critical to navigating the transition to a centralised placement framework. Exporters are therefore advised to undertake a proactive review of banking arrangements and financing structures to ensure compliance and to mitigate the risk of sanctions under the transitional provisions of the revised framework. (29 December 2025)
