Export-proceeds retention eases for some mining exporters from 1 September — but only if a shareholder is American, Chinese, Hong Kong, Australian or Canadian

Banking & FXPP 21/2026 Pasal 18AUpdatedUpdated: September 16, 2026

Indonesia requires exporters of natural resources to park their export proceeds (DHE SDA) onshore: outside oil and gas, that means 100% of proceeds held for 12 months in a state-owned foreign-exchange bank — a significant working-capital lock-up. From 1 September 2026, Article 18A of PP 21/2026 (the second amendment to PP 36/2023) relaxes this for a narrow group: mining exporters may instead retain a minimum of 30% for a minimum of three months, and may use private and foreign banks rather than only state banks. The catch is the eligibility test. A company qualifies only if it is a PT in mining **and** has at least one shareholder from the United States, China, Hong Kong, Australia or Canada holding at least 10%. Japan is not on that list — so a Japanese-owned mining exporter stays on the 100%/12-month rule regardless of how large its stake is. The government identified 64 qualifying exporters out of 537 reviewed.

Key points

  • Standard rule, unchanged: natural-resource exporters outside oil and gas must place 100% of export proceeds (DHE SDA) in a state-owned foreign-exchange bank for 12 months. Oil and gas exporters place a minimum 30% for a minimum of three months.
  • The Article 18A relaxation, effective for export declarations (PEB) issued from 1 September 2026: a minimum of 30% for a minimum of three months, and the funds may sit at designated private or foreign banks rather than only state banks, with conversion permitted at private banks.
  • Eligibility is three cumulative tests: (1) the exporter is a PT operating in mining; (2) at least one shareholder is from the United States, China, Hong Kong, Australia or Canada; (3) that shareholder holds at least 10%. The five countries were selected as the largest sources of mining investment in Indonesia.
  • Japan is not among the five qualifying shareholder countries. A Japanese-invested mining exporter therefore remains subject to the full 100%/12-month obligation. Note the asymmetry: Japanese banks (MUFG, SMBC Indonesia) do appear on the list of banks approved to hold these accounts, but that is a separate list from the shareholder-nationality test.
  • Fifteen banks are designated to hold Article 18A accounts — five state-owned (Mandiri, BRI, BNI, BTN, Bank Syariah Indonesia) and ten private or foreign (Standard Chartered, Deutsche Bank, MUFG, JP Morgan Chase, Citibank, Bank of China, ICBC Indonesia, China Construction Bank Indonesia, SMBC Indonesia, HSBC Indonesia).
  • Scope of the relief: reviewing export data from March 2025 to July 2026 across 537 taxpayer numbers, the government identified roughly 64 exporters — about 12% — that meet the Article 18A criteria.
  • Administration sits with the Coordinating Ministry for Economic Affairs, working with the Ministry of Finance and Bank Indonesia.

What this means for your Indonesian entity

Unlike most items we file under Banking & FX, this one is a binding obligation rather than macro commentary — if your entity exports natural resources, the retention rule decides how much of your own export revenue you can actually deploy, and when. Three checks. (1) Establish which regime you are in: oil and gas (30%/3 months), general natural resources (100%/12 months), or eligible mining under Article 18A (30%/3 months). Most exporters are not in mining and the relaxation does not reach them. (2) If you are a mining exporter, test the shareholder register against the five-country list and the 10% threshold before assuming relief — this is a shareholder-nationality test, not a size or sector test, and Japanese, Korean, Singaporean and European shareholdings do not qualify as things stand. (3) Model the cash-flow difference honestly in your forecast: 100% locked for 12 months against 30% for three months is a materially different working-capital position, and it affects intercompany funding plans and covenant headroom. Where proceeds sit in a foreign-currency account, the month-end revaluation treatment does not change — only the restriction on moving the money does.

Sources

This page summarises publicly available information for orientation. It is not tax, legal, or accounting advice, and regulations change. Verify against the linked primary sources and contact us before acting on anything here.

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