Minister of Trade Regulation Number 15 of 2026 on the Centralization of Coal Exports through State-Owned Enterprises

Introduction

On 29 May 2026, the Ministry of Trade issued Minister of Trade Regulation Number 15 of 2026 on Policies and Regulations on the Export of Strategic Natural Resource Commodity Coal (“MOT Regulation 15/2026”), which took effect on 1 June 2026. This regulation centralizes the authority for the exportation of coal commodities from the customs territory exclusively to State-Owned Enterprise (“SOE”) entities assigned with a special mandate.

MOT Regulation 15/2026 addresses the urgent need for more centralized and controlled management of natural resources. This regulation implements the mandate of Article 2 paragraph (5) and Article 5 of Government Regulation Number 24 of 2026 on the Governance of Strategic Natural Resource Commodity Exports. In addition, this regulation strengthens state control over coal commodities to safeguard economic stability, ensure the fulfillment of domestic needs, and strategically restructure the international trade ecosystem.

 

Comparison

MOT Regulation 15/2026 revokes Article 52C and Annex I governing coal export requirements under Minister of Trade Regulation Number 23 of 2023 on Policies and Regulations on Exports (“MOT Regulation 23/2023”), together with all amendments thereto, as most recently amended by Minister of Trade Regulation Number 12 of 2026 (“MOT Regulation 12/2026”).

 

Key Provisions

Export Monopoly by SOEs

Pursuant to Article 2 paragraph (1), only Export SOEs are entitled to carry out the exportation of Strategic Natural Resource Commodity Coal from the territory of Indonesia. To exercise this monopoly, Article 2 paragraph (2) requires Export SOEs to obtain a Business License in the form of an ET for Coal before conducting customs activities. These licensing documents serve as mandatory supporting customs documents when submitting an Export Customs Declaration.

Requirements for ET for Coal Application

Article 3 provides that the Minister of Trade has the authority to issue an ET for Coal. Based on the details set out in the Annex to MOT Regulation 15/2026, Export SOEs must submit several documents to obtain this license. The application requirements include:

1. A Business License in the form of a Special Production Operation Mining Business License (IUP) for Transportation and Sales or a Coal Transportation and Sales License; 
2. Proof of official appointment as an Export SOE by the Government of the Republic of Indonesia; 
3. Proof of registration in the data application system managed by the ministry responsible for energy and mineral resources (ESDM), particularly if such system has not yet been integrated with SINSW; and 
4. A stamped declaration letter guaranteeing that the exported coal originates from a lawful mining operation and complies with applicable laws and regulations. 

Technical Verification and Export Realization Reporting Obligations

Pursuant to Article 4 paragraph (1), the government imposes a verification or technical traceability obligation for every planned coal commodity export. A Surveyor authorized by the Minister will conduct the physical and administrative inspection to issue the LS. Following the completion of customs activities, Article 7 paragraph (1) requires exporters to submit an electronic export realization report to the Minister, regardless of whether the export is successfully realized or not realized at all. If businesses fail to comply with this reporting obligation, Article 8 paragraph (1) stipulates that the ministry will impose administrative sanctions on the relevant exporter.

 

Transitional Provisions

Pursuant to Article 11, ET for Coal licenses held by private entities that were issued before 1 June 2026 remain valid until a maximum date of 31 December 2026, or for a shorter period if the validity of their business license expires before that deadline. However, they are only entitled to export coal through an Export SOE intermediary by submitting reports, export supporting documents, and a copy of the sales contract into the Export SOE system.

After the deadline of 31 December 2026, Article 11 letter e stipulates that export rights shall be transferred entirely to Export SOEs. If private exporters violate the procedures during this transitional period, including failure to submit monthly realization reports or misuse of the LS, Articles 8 and 9 provide for the imposition of administrative sanctions.

 

Closing

MOT Regulation 15/2026 marks a significant change in coal governance by centralizing export authority exclusively to SOEs as of 1 June 2026 in order to maintain economic stability and domestic supply. This policy, which revokes the export rights of private parties, requires Export SOEs to obtain an ET for Coal and imposes mandatory technical traceability by Surveyors as well as electronic export realization reporting, accompanied by the possibility of administrative sanctions. As a transitional measure, private exporters remain permitted to export through SOE intermediaries until a maximum date of 31 December 2026, after which all export rights shall be transferred entirely to SOEs.