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Legal Updates

Government Regulation Number 24 of 2026 Mandates the Export of Strategic Natural Resource Commodities Through State-Owned Enterprises

8 June 2026
Ivonnie Wijaya & Steven Aristides Wijaya
Legal Updates
Peraturan Pemerintah Nomor 24 Tahun 2026 Wajibkan Ekspor Komoditas Sumber Daya Alam Strategis Melalui BUMN

Introduction

On 20 May 2026, President Prabowo Subianto enacted Government Regulation Number 24 of 2026 on the Governance of Strategic Natural Resource Commodity Exports (“GR 24/2026”), which took effect on 1 June 2026. The Government intends to directly oversee the implementation of exports of strategic natural resource commodities. 

Through GR 24/2026, the Government seeks to maintain domestic supply stability, strengthen national economic resilience, increase value-added benefits, and ensure the sustainability of national development. The Constitution mandates that the State shall control and utilize natural resources for the greatest prosperity of the people. Market conditions and global challenges require the Government to take firm measures in establishing export control policies so that the supply of strategic commodities remains secure and provides maximum benefits to the national economy.

 

Key Provisions

Designation of Strategic Natural Resource Commodities

Pursuant to Article 2 paragraphs (2) and (3), the Government shall designate strategic commodity status in stages. In the initial stage, the Government designates three primary commodities as Strategic Natural Resource Commodities, i.e. coal, palm oil, and ferroalloy (iron alloy). Furthermore, Article 2 paragraph (4) provides that the relevant coordinating minister shall designate other strategic commodities through an interministerial coordination meeting mechanism. The Elucidation of Article 2 paragraph (1) emphasizes that these strategic commodities affect the livelihood of a large portion of the population and perform functions such as allocation, distribution, and stabilization.

Export Monopoly by State-Owned Enterprises

Article 3 paragraph (1) provides that the State-Owned Export Enterprise (BUMN Export) shall exercise full control over the export of strategic commodities, whether acting as the owner or as the sole intermediary. Furthermore, Article 3 paragraphs (2) and (4) provide that BUMN Export is authorized to independently determine the selling price of such commodities and establish profit margins within reasonable limits in accordance with the prevailing laws and regulations. The governance of strategic commodity exports also includes export control mechanisms, transportation arrangements, and export insurance, as provided under Article 4 paragraph (1).

Exemption from Export Through State-Owned Enterprises

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Pursuant to Article 4 paragraph (2), the Government exempts business entities that have entered into contracts or agreements with the Government, provided that such contracts contain at least the following three provisions:

  • Investment;
  • Divestment; and
  • Domestic processing and/or refining.

Article 4 paragraph (3) provides that the relevant coordinating minister shall determine the granting of such exemption through a coordination meeting.

 

Transitional Provisions

Article 7 letter a provides that business entities shall channel all exports of strategic commodities through BUMN Export no later than 31 December 2026. The Elucidation of Article 7 letter a explains that during this transitional period, business entities shall report export documentation and integrate their corporate information systems (such as CEISA, SINSW, INATRADE, SiMoDIS, and/or the Minerba Online Monitoring System (MOMS)) with the system integrated with BUMN Export.

The Government shall evaluate the implementation of this transitional period within three months after 1 June 2026. Article 7 letter c provides that the relevant minister may establish an earlier deadline for the obligation to export through BUMN Export prior to 31 December 2026 based on the results of such evaluation. In addition, Article 8 instructs BUMN Export to evaluate all sales contracts executed before 1 June 2026 that remain in effect.

 

Closing

GR 24/2026 centralizes control over the export of strategic natural resource commodities, which in the initial stage include coal, palm oil, and ferroalloy, through the export monopoly of BUMN Export in order to maintain supply stability and national economic resilience. Under this regulation, BUMN Export is granted authority over export governance, the determination of selling prices, and export margins, while exemptions from the obligation are available only to business entities whose contracts with the Government contain commitments relating to investment, divestment, and domestic processing. In response to this new governance framework, business entities are required to promptly integrate their information systems and channel all export activities through BUMN Export no later than 31 December 2026. They must also prepare for the evaluation of existing sales contracts by BUMN Export that remain in force.

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