PP 24/2026: coal, palm-oil and ferro-alloy exports must go through a state export enterprise (Danantara Sumberdaya Indonesia, DSI) — in force since 1 June 2026 with a transition to 31 December, and the DSI portal goes live on 1 January 2027 while the regulation itself is to be amended in November
Government Regulation 24/2026 on Governance of the Export of Strategic Natural Resource Commodities was established and promulgated on 20 May 2026 (State Gazette 2026 No. 58) and has been in force since 1 June 2026. For a first stage it covers coal, palm oil and ferro alloy, which may be exported only by a state export enterprise (BUMN Ekspor), either as owner or as sole intermediary; the enterprise sets the selling price and may add a reasonable margin (Article 3). Exports must go through it by 31 December 2026 at the latest, and contracts signed before 1 June 2026 that are still running are evaluated by it (Articles 7 and 8). The Coordinating Ministry for Economic Affairs said on 6 November that the enterprise is PT Danantara Sumberdaya Indonesia (DSI), acting as sole intermediary without taking title to the goods, that its portal (NADI) goes live on 1 January 2027, and that PP 24/2026 is to be amended in November. We found this regulation on 11 November, so the entry is published after the fact.
Key points
- Source and dates: Peraturan Pemerintah Nomor 24 Tahun 2026 tentang Tata Kelola Ekspor Komoditas Sumber Daya Alam Strategis, established and promulgated 20 May 2026 (President Prabowo Subianto; State Secretary Prasetyo Hadi), State Gazette 2026 No. 58, Supplement No. 7178, in force 1 June 2026 (Article 10). We read the signed copy on the BPK regulation database (seven pages) and the Coordinating Ministry's press release HM.02.04/395/SET.M.EKON.3/11/2026 of 6 November 2026.
- Scope (Article 2): for the first stage the strategic commodities are coal, palm oil and ferro alloy. Others are designated later in stages at a coordination meeting led by the Coordinating Minister for Economic Affairs (non-food) or the Coordinating Minister for Food (food), and the types are set in a trade ministerial regulation. For the first three that is Permendag 15/2026 (coal), 16/2026 (palm oil) and 17/2026 (ferro alloy), which we have not read.
- The rule (Articles 3–4): strategic commodities may be exported only by a state export enterprise, as owner or as sole intermediary; that enterprise sets the selling price and may set a reasonable margin. Governance may include export control with verification or technical tracing and arrangements for transport and insurance. The enterprise route may be waived for businesses that have a contract or agreement with the Government containing at least investment, divestment and domestic processing or refining, decided at a coordination meeting. Supervision lies with each responsible minister (Article 6).
- Transition (Articles 7–8): exports may go through the state export enterprise until 31 December 2026 at the latest; a coordination meeting evaluates this within three months of the regulation's start, and the Coordinating Minister may set an earlier deadline; after the deadline only the state export enterprise may export. Sales contracts signed before 1 June 2026 and still in force are evaluated by the enterprise (Article 8).
- How the ministry describes it (6 November release): DSI acts as sole intermediary, and negotiation and commercial transactions stay between exporter and buyer. DSI does not take over ownership of the goods, checks contract documents and approves the draft export declaration (PEB). Import-export licensing (lartas), domestic market obligations (DMO), inspection, shipping and export-proceeds (DHE) duties stay with the exporter, and HS codes do not change. Documents pass through the DSI portal (NADI) before they go to CEISA, and DSI does a post-clearance check after export and repatriation of funds, asking exporters to explain any differences. About 100 exporters, around half of the export value of the three commodities and about 340 contracts, tested the portal. The three commodities were about USD 66.13 billion, or 23.4% of national exports, in 2025 (ministry figures).
- Open point: the regulation says the enterprise sets the selling price and acts as owner or sole intermediary, while the ministry describes an intermediary that leaves commercial negotiation with the parties. The ministry says PP 24/2026 is to be amended, with completion targeted for November 2026.
- Roadmap (6 November release): amendment of PP 24/2026 targeted for November 2026, then adjustment of Permendag 15, 16 and 17 of 2026 (including how long Registered Exporter status is valid), Permendag 16/2021 and PMK 155/2022. For the portal: system function test and technical briefing on 15 November 2026; piloting and opening of NADI account registration from 15 December 2026; go-live on 1 January 2027 for normal export declarations (BC 3.0 and BC 3.3); and extension in the first and second quarters of 2027 to free-trade-zone and special-economic-zone declarations, corrected declarations and the SSm Ekspor service.
- What we have not seen: Permendag 15, 16 and 17 of 2026, any DSI guidance or fee terms, and the amended regulation, which is not out as of 11 November.
What this means for your Indonesian entity
If you export coal, palm-oil products or ferro alloy from Indonesia, or buy them from Indonesian exporters, the route of every shipment changes: exports go through the state export enterprise, and the ministry says the portal goes live on 1 January 2027 for normal export declarations. Practical steps: confirm with your Indonesian counterparty that it will take part in the DSI portal briefing on 15 November and register an account when registration opens on 15 December; check whether your sales contracts signed before 1 June 2026 and still running are being evaluated under Article 8; allow time in shipment planning for the extra step, a contract check and approval of the draft export declaration before it goes to customs; and note that licensing, DMO, inspection, shipping and export-proceeds duties stay with the exporter. The legal text and the ministry's description do not yet line up on who sets the price and who owns the goods in transit, and an amendment is planned for November, so read any pricing or title clause in your contracts again when the amended regulation appears. We cannot say whether a particular exporter qualifies for the exception for businesses with a government contract on investment, divestment and domestic processing. This is orientation, not advice, and we have not read the trade ministerial regulations that implement it.
Sources
- BPK regulation database — PP Nomor 24 Tahun 2026 tentang Tata Kelola Ekspor Komoditas Sumber Daya Alam Strategis (LN 2026 No. 58, TLN No. 7178; ditetapkan and diundangkan 20 May 2026, in force 1 June 2026; primary source listing)
- BPK regulation database — PP Nomor 24 Tahun 2026, signed copy (PDF, seven pages)
- Kementerian Koordinator Bidang Perekonomian — Perluas Fleksibilitas DHE SDA dan Siapkan Go-Live Portal DSI, Pemerintah Pastikan Ekspor Tetap Lancar (press release HM.02.04/395/SET.M.EKON.3/11/2026, 18:59 WIB, 6 November 2026)
- DDTCNews — PP 24/2026 Mungkinkan Pemerintah Perluas Kebijakan Ekspor Satu Pintu (14 June 2026; secondary)
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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