BGN Regulation 10/2026: Strengthening the Use of Domestic Products and the Involvement of Business Actors in the MBG Program

Introduction

On 27 July 2026, the Head of the National Nutrition Agency enacted National Nutrition Agency Regulation Number 10 of 2026 on the Use of Domestic Products and the Involvement of Micro Enterprises, Small Enterprises, Individual Companies, Cooperatives, Merah Putih Village/Sub-District Cooperatives and Village-Owned Enterprises (“BGN Regulation 10/2026”), which took effect on 18 August 2026. BGN Regulation 10/2026 sets out guidelines concerning the prioritization of the use of Domestic Products as well as the involvement of local business actors in the supply chain and logistics of the Free Nutritious Meals Program (“MBG”). This regulation was issued to implement the mandate of Article 38 paragraph (3) of Presidential Regulation Number 115 of 2025 concerning the Governance of the Implementation of the Free Nutritious Meals Program.

Key Provisions

• Priority Use of Domestic Products

As stipulated in Article 2, the implementation of the Free Nutritious Meals Program (“MBG”) prioritizes the use of Domestic Products throughout the supply chain and logistics. Such Domestic Products include products from the agricultural, livestock, fisheries and/or marine, plantation, and industrial sectors. In its implementation, the use of Domestic Products shall continue to be carried out by taking into account the technical specifications of the goods and/or services required, food safety and quality standards, supply availability, and government pricing policies in accordance with the provisions of laws and regulations.

• Requirements for the Involvement of Business Actors

Article 3 stipulates that business actors that may participate in the implementation of the Free Nutritious Meals Program (“MBG”) include Micro Enterprises, Small Enterprises, Individual Companies, Cooperatives, Merah Putih Village/Sub-District Cooperatives (“KDKMP”), and Village-Owned Enterprises (“BUM Desa”). Such business actors must satisfy administrative and technical requirements in order to participate in the implementation of the MBG Program.

• Zoning Hierarchy for the Involvement of Business Actors

To ensure the involvement of business actors from the local area in the implementation of the Free Nutritious Meals Program (“MBG”), Article 5 establishes a tiered involvement mechanism based on the location of the Nutrition Fulfillment Service Unit (“SPPG”). An SPPG must involve business actors domiciled and conducting their business activities in the sub-district where the SPPG is located. If business actors are not available in such area, the SPPG may involve business actors from the nearest sub-district within the same regency/municipality. If such business actors are also unavailable, the involvement may be expanded to the nearest regency/municipality within the same province, and, as the final stage, the SPPG may involve business actors from outside the province.

Article 6 stipulates that the involvement of such business actors shall take the form of providing Local Food and/or Processed Food raw materials, supporting goods and services, as well as other supporting goods and services. The provision of raw materials includes the procurement, provision, and/or distribution of food raw materials that comply with quality, food safety, and nutritional standards. Meanwhile, supporting goods and services include storage, cold-chain facilities, transportation, and distribution of food raw materials and/or meals, while other supporting goods and services include packaging services, equipment provision, cleaning, information technology, handling of food leftovers, waste and domestic wastewater, as well as other goods and services that support the implementation of the MBG Program.

In its implementation, with reference to Article 7, the involvement of business actors shall be carried out through the stages of data collection and validation. Data collection shall be conducted by KPPG with the involvement of regency/municipality regional governments and provincial regional governments, while validation shall be conducted by KPPG based on the results of such data collection. The validation results shall subsequently be submitted through SIPGN, with the technical guidelines for the involvement of business actors to be determined by the Head.

• Strict Prohibitions in the Supply Chain Ecosystem

Article 9 stipulates prohibitions applicable to business actors and managers of Nutrition Fulfillment Service Units (“SPPG”) in the implementation of the Free Nutritious Meals Program (“MBG”). Business actors involved in the provision of Local Food and/or Processed Food raw materials are prohibited from disregarding the provisions on the use of Domestic Products, conducting price transactions without adhering to government pricing policies, submitting false data or documents, transferring the implementation of the provision to another party without the written approval of the National Nutrition Agency (“BGN”), engaging in unfair business competition, collusion, corruption, and/or nepotism, or obstructing the implementation of the Supply Chain Ecosystem.

Meanwhile, SPPG managers are prohibited from disregarding the provisions on the use of Domestic Products; establishing, owning, controlling, or being affiliated with a new business entity to act as a provider; or obstructing or restricting the involvement of Micro Enterprises, Small Enterprises, Individual Companies, Cooperatives, Merah Putih Village/Sub-District Cooperatives (“KDKMP”), and Village-Owned Enterprises (“BUM Desa”) that have satisfied the requirements. SPPG managers are also prohibited from engaging in price mark-ups, accepting remuneration, commissions, or gifts in any form from business actors, disregarding transparency of information concerning raw material requirements and menu planning in accordance with nutritional standards, or reducing the quality of menus below the standards established by BGN.

For such violations, Article 10 establishes different sanctions for business actors and SPPG managers. Business actors may be subject to a written warning, temporary suspension of the implementation of cooperation, revocation of their involvement in the implementation of the MBG Program, and inclusion on the blacklist for a minimum period of 1 (one) year. Meanwhile, SPPG managers may be subject to a written warning, temporary suspension of SPPG operations, and/or disciplinary sanctions in accordance with the provisions of laws and regulations in the field of personnel applicable to SPPG heads, nutrition supervisors, and financial supervisors. The procedures for imposing such sanctions shall subsequently be stipulated through technical guidelines by the Head of BGN.

Transitional Provisions

Article 16 stipulates that agreements entered into prior to the promulgation of this Agency Regulation must be adjusted to comply with the provisions stipulated in this Agency Regulation. Such adjustments to the agreements must be made within a maximum period of 90 (ninety) days as of the promulgation of this Agency Regulation.

Closing 

BGN Regulation 10/2026 strengthens the governance of the MBG Program’s supply chain by placing emphasis on the use of Domestic Products and the involvement of local business actors in the implementation of the program. The provisions concerning business actor requirements, regional prioritization, data collection and validation stages, as well as prohibitions and sanctions, provide a clearer framework for business actors and SPPG managers in carrying out their respective roles. Accordingly, the implementation of the MBG Program is expected not only to support the fulfillment of the public’s food and nutritional needs, but also to promote the empowerment of regional business actors, strengthen the food supply chain, and generate broader economic impacts for local communities.

For business actors and SPPG managers, these provisions also give rise to obligations to ensure compliance with administrative and technical requirements, provisions concerning the use of Domestic Products, as well as food quality and safety standards. In addition, agreements existing prior to the promulgation of BGN Regulation 10/2026 must be promptly adjusted within a maximum period of 90 (ninety) days. Compliance with these provisions is important to maintain transparency, accountability, and the sustainability of the implementation of the MBG Program.