Introduction
Indonesia’s Government Regulation No 24 of 2026 on the Governance of Exports of Strategic Natural Resource Commodities represents a major restructuring of the country’s export architecture. Signed on 20 May 2026 and effective from 1 June 2026, the regulation initially applies to coal, palm oil and ferroalloy, three commodities with substantial significance for Indonesia’s export earnings, industrial policy and resource governance.
The central feature of the regulation is the appointment of a state-owned export enterprise as the principal channel for international sales of these commodities. The framework supports the role of PT Danantara Sumberdaya Indonesia (DSI), a state-owned enterprise established to perform strategic resource-related functions. During the transitional period, existing exporters may continue operating, but they must progressively migrate their reporting, contracts and transaction processes into the new framework by 31 December 2026.
The reform has been described as an export reordering because it does not merely impose a new licence or reporting form. It changes who may control the commercial pathway from producer to foreign buyer. The government is seeking greater visibility over export volumes, pricing, margins, foreign exchange flows and downstream development. At the same time, the model creates substantial legal and commercial questions concerning market access, contractual autonomy, pricing authority, competition, transparency and the treatment of private investment.
The Regulatory Architecture
Government Regulation No 24/2026 establishes a category of strategic natural-resource commodities whose export governance may be assigned to an Export State-Owned Enterprise. At the initial stage, the category covers coal, palm oil and ferroalloy. The regulation therefore targets commodities that are both commercially significant and closely connected with Indonesia’s resource sovereignty and industrial development objectives.
Under the new structure, the designated state-owned enterprise may act as the exporter or as the sole intermediary between producers and foreign buyers. The significance of this arrangement is that private producers may no longer control the entire export transaction independently. Instead, the state-appointed enterprise becomes the institutional gateway through which the relevant commodity is marketed and exported.
The framework is divided into phases. Phase I operates from 1 June to 31 December 2026, unless the government determines another date through the designated coordination mechanism. Phase II is scheduled to begin on 1 January 2027 or after the end of Phase I. The phased structure acknowledges that an immediate transition would be difficult. Exporters have existing supply contracts, shipping arrangements, banking relationships, customers, hedging positions and compliance systems. A transition period gives the government time to build operational capacity while allowing businesses to adapt.
The regulation also appears to give the Export SOE authority to determine export selling prices and margins within the limits of reasonableness and applicable law. This is a consequential provision. It means that the reform is not limited to administrative coordination. It potentially affects the commercial terms on which producers sell into international markets.
The Transitional Obligation
The period until 31 December 2026 should not be understood as a suspension of the new regime. It is better understood as a migration period. Existing exporters may continue participating in trade, but they must progressively provide information and align transactions with the new system.
The transition requires businesses to examine their existing export arrangements in detail. Relevant information may include export reports, sale and purchase contracts, shipping documents, customer data and other records necessary for the state-owned export enterprise to understand the flow of commodities. Companies must also assess whether their contracts contain provisions that restrict assignment, require consent for intermediaries, or determine pricing and delivery obligations in ways that conflict with the new model.
This is where the reform becomes an intellectual-property and compliance issue only in a limited sense. The regulation is principally an export-governance measure, not an intellectual-property statute. Nevertheless, compliance may involve commercially sensitive information, proprietary trading arrangements, customer databases, logistics methods, data systems and brand-related material. Companies should therefore consider how information is shared, who may access it, and whether confidentiality protections are adequate.
The transition also creates a documentation challenge. Businesses that previously managed compliance through ordinary customs and trade records may now need to maintain a more structured evidentiary trail demonstrating that transactions have been reported and migrated correctly. In a centralised export system, inconsistencies between contracts, invoices, shipping documents and declarations may have consequences beyond an ordinary customs discrepancy because they may be interpreted as a failure to comply with the state-led export channel.
Government Objectives
The government’s stated policy logic is connected to resource nationalism, value capture and strategic economic management. Indonesia is a major producer and exporter of natural resources, but the government has long sought to ensure that resource wealth contributes more directly to domestic industrialisation. Centralising exports may allow the state to obtain better information about the quantity and price of exported commodities and to coordinate foreign sales with domestic processing objectives.
A central export channel may also help address information asymmetry. If individual producers negotiate separately with international buyers, the government may have limited visibility into actual transaction prices, discounts, intermediary margins and market demand. A designated export enterprise can theoretically aggregate data and use it to improve bargaining power or detect under-invoicing and other forms of leakage.
The policy may also strengthen the government’s ability to connect exports with downstream investment. Indonesia has repeatedly pursued policies designed to promote domestic processing rather than the export of minimally processed resources. A centralised export mechanism could be used to favour buyers or transactions that support domestic refining, processing or industrial partnerships.
However, these objectives depend on institutional performance. Centralisation does not automatically produce better prices, greater transparency or stronger domestic value creation. It may produce those outcomes only if the Export SOE has adequate expertise, transparent pricing rules, operational independence and effective accountability.
Conclusion
The framework marks a significant move toward state-directed governance of Indonesia’s strategic commodity exports. By placing coal, palm oil and ferroalloy within a centralised export framework, the government aims to improve visibility, strengthen bargaining capacity and connect export activity with national industrial objectives.
The reform’s success will depend on implementation rather than policy ambition alone. Centralisation may improve coordination, but it may also produce delay, pricing uncertainty, competition concerns and contractual disruption. The decisive question is whether the Export SOE operates transparently, efficiently and subject to meaningful accountability.
For affected businesses, the migration deadline should be treated as a substantive compliance milestone. Companies must understand the new export channel, review their contracts, organise transaction data and plan for possible changes to pricing and payment structures. A carefully managed transition could make the regulation a tool for greater resource governance. A poorly managed one could shift risk from the state to producers and foreign buyers without delivering equivalent economic benefits.
References
- Government Regulation of the Republic of Indonesia on the Governance of Exports of Strategic Natural Resource Commodities (PP No 24/2026), enacted 20 May 2026.
- Aceris Law, ‘Indonesia’s New Commodity Export Regime: Resource Nationalism and International Arbitration’ (6 June 2026) <https://www.acerislaw.com/indonesias-new-commodity-export-regime-resource-nationalism-and-international-arbitration/> accessed 29 July 2026.
- SMM, ‘Indonesia PP No 24/2026: DSI Takes Control, Nickel, Ferro Alloys and the NPI Grey Zone’ (10 June 2026) https://news.metal.com/newscontent/103948538-smm-analysis-indonesia-pp-no242026-dsi-takes-control-nickel-ferro-alloys-and-the-npi-grey-zone> accessed 29 July 2026.
- Government of Indonesia, Ministry of Trade, regulatory materials concerning export governance for strategic natural-resource commodities (2026).
- International Energy Agency, Coal 2025: Analysis and Forecast to 2030 (IEA 2025).
- United States Department of Agriculture, Foreign Agricultural Service, Indonesia: Oilseeds and Products Annual (2025).
- United Nations Conference on Trade and Development, Handbook of Statistics 2024: International Trade and Commodities (UNCTAD 2024).