Decree of the Minister of Energy and Mineral Resources Number 229.K/MB.01/MEM.B/2026 Tightens Supervision of the Transportation and Sale of Minerals and Coal

Introduction

On June 3, 2026, the Ministry of Energy and Mineral Resources (“MEMR”) issued Decree of the Minister of Energy and Mineral Resources Number 229.K/MB.01/MEM.B/2026 on the Increase of Supervision over the Transportation and/or Sale of Mineral and/or Coal Commodities (“MEMR Decree 229/2026”). MEMR Decree 229/2026 strengthens supervision over the transportation and sale of mineral and coal commodities to support the optimization of state revenue from the mining sector.

The Government issued MEMR Decree 229/2026 to prevent the loss of state revenue from the mineral and coal mining sector. The Government enhances supervision over practices such as under-invoicing, transfer pricing, as well as the manipulation of quantity and quality reports of transported or sold mining commodities.

Key Provisions

Subject of Enhanced Supervision

As stipulated in the FIRST Dictum, the government enhances supervision over the transportation and/or sale of mineral and coal commodities. This enhanced supervision applies to holders of:

1. Mining Business Licenses (Izin Usaha Pertambangan, “IUP”);

2. Special Mining Business Licenses (Izin Usaha Pertambangan Khusus, “IUPK”);

3. IUPK as the Continuation of Contract/Agreement Operations;

4. Contracts of Work (Kontrak Karya);

5. Coal Mining Cooperation Agreements (Perjanjian Karya Pengusahaan Pertambangan Batubara, “PKP2B”); and

6. Transportation and Sales Licenses.

Enhanced Supervision Measures

The SECOND Dictum regulates the enhanced supervision over the transportation and sale of mineral and coal commodities through the following measures:

1. Ensuring that surveyors conduct technical verification transparently and accountably through the Sales Verification Module (Modul Verifikasi Penjualan, “MVP”) application system;

2. Ensuring the conformity of commodity sales reports with production fee (royalty) payments on the Electronic Non-Tax State Revenue (Penerimaan Negara Bukan Pajak Elektronik, “e-PNBP”) application system;

3. Blocking royalty payment transactions on the e-PNBP system based on a request from the Ministry of Finance;

4. Providing recommendations to the Ministry of Finance to conduct physical export examinations and/or upgrade commodity status to a physical examination priority based on intelligence data; and

5. Imposing sanctions on surveyors who fail to conduct technical verification in accordance with laws and regulations.

Coordination of Supervision with the Ministry of Finance

The Minister of Energy and Mineral Resources may coordinate with the Minister of Finance in implementing the supervision as stipulated in the THIRD Dictum. Such coordination may be conducted through:

1. Exchanging intelligence data and/or information related to the transportation and sale of commodities;

2. Optimizing and improving the integrated digital service information system for non-tax state revenue;

3. Conducting joint operations for supervision and law enforcement against violations in transportation and sales activities;

4. Examining the conformity of the quantity of commodities to be exported with the quantity stated in the proof of royalty payment associated with the State Revenue Transaction Number (Nomor Transaksi Penerimaan Negara, “NTPN”); and/or

5. Rejecting the use of a State Revenue Transaction Number where the quantity exceeds the quantity stated in the proof of royalty payment.

Coordination of Transportation Supervision with the Ministry of Transportation

The Minister of Energy and Mineral Resources may coordinate with the Minister of Transportation in implementing supervision over the transportation and sale of mineral and coal commodities as stipulated in the FOURTH Dictum. Such coordination supports the implementation of supervision over the transportation activities of mineral and coal commodities.

Transitional Provisions

If any errors are found in MEMR Decree 229/2026 in the future, the government will make corrections in accordance with the provisions of laws and regulations as stipulated in the FIFTH Dictum.

Closing

The enactment of MEMR Decree 229/2026 strengthens supervision over the transportation and sale of mineral and coal commodities to support the optimization of state revenue from the mining sector. This enhanced supervision applies to holders of IUP, IUPK, IUPK as the Continuation of Contract/Agreement Operations, Contracts of Work, PKP2B, and Transportation and Sales Licenses. To support its implementation, the government implements several supervisory measures, including technical verification by surveyors through the Sales Verification Module application, matching sales reports with production fee (royalty) payments on the e-PNBP system, blocking royalty payments on the e-PNBP system based on requests from the Ministry of Finance, providing recommendations for physical export examinations based on intelligence data, and imposing sanctions on surveyors who fail to conduct technical verification in accordance with applicable laws and regulations. MEMR Decree 229/2026 also opens avenues for coordination between the Minister of Energy and Mineral Resources and the Minister of Finance through the exchange of intelligence data and information, the optimization of the non-tax state revenue information system, joint supervision and law enforcement operations, examinations of the conformity of export commodity quantities with proof of royalty payments, and the rejection of the use of a State Revenue Transaction Number where the quantity exceeds the quantity stated in the proof of royalty payment. Additionally, the Minister of Energy and Mineral Resources may coordinate with the Minister of Transportation in implementing supervision over the transportation and sale of mineral and coal commodities. Therefore, mining businesses must ensure the conformity of sales data, royalty payments, and commodity verification processes to support compliance with the supervision mechanisms regulated under MEMR Decree 229/2026, while remaining mindful of potential corrections should any errors be found in the ministerial decree in the future.