Legal News Update
Contributors: Almaida Askandar, S.H., MBA, Nita Damayanti, S.H., and Renata Luisa Kusuma S.H.
Published on 13 June 2026 by IABF Law Firm, Jakarta, Indonesia.
The New Authority of BUMN Export in the Field of Strategic Natural Resource Commodities
The Government of Indonesia has issued Government Regulation No. 24 of 2026 on the Governance of Export of Strategic Natural Resource Commodities (“GR 24/2026”) on 20 May 2026, which came into effect on 1 June 2026. The regulation reflects the Government’s policy to strengthen state involvement in managing strategic natural resources and ensure that the economic benefits generated from such resources contribute more directly to national development and public welfare. GR 24/2026 establishes a new framework for exporting strategic natural resource commodities and introduces a central role for a designated State-Owned Export Enterprise (“BUMN Export”).
I. BUMN Export as the Sole Exporter of Strategic Commodities
GR 24/2026 defines BUMN Export as a state-owned enterprise that receives a specific mandate from the Government to carry out export activities for Strategic Commodities.
The regulation further provides that a BUMN may include:
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- an enterprise wholly-owned or majority-owned by the State through direct capital participation; or
- an enterprise in which the State possesses special rights.
One of the most notable changes introduced by GR 24/2026 is the requirement that Strategic Commodities (as explained below) may only be exported through a designated BUMN Export. Under the regulation, BUMN Export may carry out exports either as the owner of the commodities or as the sole intermediary for export transactions involving Strategic Commodities. In addition, BUMN Export is granted the authority to determine the selling price of Strategic Commodities and establish reasonable margins in accordance with prevailing laws and regulations.
This framework represents a significant departure from the existing export regime, as it places a designated state-owned enterprise at the center of export activities for commodities that are considered strategically important by the Government.
II. Initial Strategic Commodities
GR 24/2026 defines Strategic Commodities as natural resource commodities designated by the Government by taking into account national interests, economic stability, domestic needs, and the management of national strategic natural resources.
The implementation of the regulation will be carried out gradually. As an initial phase, the Government has designated the following commodities as Strategic Commodities:
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- coal;
- palm oil; and
- ferroalloys.
The Government may also expand the list of Strategic Commodities in future stages through a coordination meeting led by the relevant coordinating minister and attended by ministries and government institutions with authority over the relevant sector.
III. Operational Implications for Business Actors
The new framework will have practical implications for exporters of Strategic Commodities.
Based on GR 24/2026, exports of the initial Strategic Commodities are expected to be conducted through BUMN Export no later than 31 December 2026. The elucidation of the regulation further clarifies that exports conducted through BUMN Export include the submission of export reports, export documents, sales contracts, and other supporting documents by business actors to BUMN Export.
Business actors may also be required to provide additional data and information through systems integrated with BUMN Export, including the Customs Excise Information System and Automation (CEISA), the Indonesia National Single Window System (SINSW), the Trade Information System (INATRADE), the Real-Time Integrated Foreign Exchange Monitoring Information System (SiMoDIS), and the Mineral and Coal Online Monitoring System (MOMS).
In addition, sales contracts executed before the effective date of GR 24/2026 that remain valid after 1 June 2026 will be subject to evaluation by BUMN Export.
IV. Exemptions from the BUMN Export Requirement
GR 24/2026 recognizes that certain business actors may already be operating under specific contractual arrangements with the Government.
Accordingly, the regulation provides for potential exemptions from the requirement to export through BUMN Export. Such exemptions may be available for business actors that have agreements with the Government containing commitments relating to:
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- investment;
- divestment; and/or
- domestic processing and refining activities.
The granting of any exemption is not automatic and will be determined through a coordination meeting involving the relevant ministries and government institutions.
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Disclaimer
This news update is prepared for general informational purposes only. The content does not constitute legal advice, a legal opinion, or counsel from IABF Law Firm. The information contained herein may not reflect the most current developments. Any quotation, distribution, or use of this information for any purpose is solely at the user’s own risk.
