Board of Governors Regulation No. 16 of 2026 Restricts the Holding of DHE SDA Exclusively in State-Owned Banks

Introduction

On 29 June 2026, Bank Indonesia ("BI") issued Board of Governors Regulation No. 16 of 2026 on the Third Amendment to Board of Governors Regulation No. 4 of 2023 concerning Export Proceeds and Foreign Exchange for Import Payments ("PADG No. 16 of 2026"), which took effect on 1 June 2026.

PADG No. 16 of 2026 amends, inserts, and repeals a number of provisions previously stipulated under Board of Governors Regulation No. 4 of 2023 on Export Proceeds and Foreign Exchange for Import Payments ("PADG No. 4 of 2023"), as amended by Board of Governors Regulation No. 4 of 2025 concerning the Second Amendment to Board of Governors Regulation No. 4 of 2023 on Export Proceeds and Foreign Exchange for Import Payments ("PADG No. 4 of 2025"). PADG No. 16 of 2026 updates the provisions governing the administration, deposit, placement, and utilization of Foreign Exchange Proceeds from Natural Resource Exports ("DHE SDA") within Indonesia's financial system.

Through PADG No. 16 of 2026, BI introduces several adjustments, including:

• restricting the placement of DHE SDA into Indonesia's financial system solely through a Special DHE SDA Account ("Reksus DHE SDA") maintained with a State-Owned Bank ("Bank BUMN");
• limiting banking placement instruments for DHE SDA solely to foreign currency Special DHE SDA Accounts and foreign currency deposits maintained with State-Owned Banks;
• removing instruments issued by the Indonesia Eximbank ("LPEI"), while adding Government Bonds ("SUN") and/or Sharia Government Securities ("SBSN") denominated in foreign currency and issued by the Government in the domestic primary market as placement instruments, together with the mechanism for their utilization;
• limiting the utilization of DHE SDA from the non-oil and gas sector that may be converted into Indonesian Rupiah, together with BI's supervision thereof; and
• granting BI the authority to designate banks for the implementation of special provisions under bilateral trade agreements or other understandings or international agreements in the field of trade.

Comparison

The following are the key changes introduced under PADG No. 16 of 2026.

Exclusive Placement of DHE SDA in State-Owned Banks

Pursuant to Article 2 paragraph (2)(b) and Article 21 paragraph (1), natural resource exporters with an export value of at least USD250,000.00 (two hundred and fifty thousand United States dollars) or its equivalent are required to deposit DHE SDA into Indonesia's financial system through a Special DHE SDA Account maintained with a State-Owned Bank.

This provision shifts the mechanism for depositing DHE SDA, which previously could be carried out through an authorized foreign exchange bank or LPEI. Accordingly, exporters that continue to maintain DHE SDA accounts outside State-Owned Banks are required to make the necessary adjustments by opening or transferring their Special DHE SDA Accounts to a State-Owned Bank.

Limit on the Conversion of DHE SDA into Rupiah (Maximum 50%)

Pursuant to Article 38A, DHE SDA derived from sectors other than oil and natural gas mining may be converted into Indonesian Rupiah through spot or forward transactions conducted with a State-Owned Bank.

The amount converted is limited to a maximum of 50% (fifty percent) of the Export Value, calculated based on the aggregate DHE SDA deposited in each month. Exporters are required to ensure that such conversion remains within the prescribed limit.

Any violation of this provision may be subject to administrative sanctions in accordance with the prevailing laws and regulations.

The following illustrates the calculation:

PT D, a forestry-sector natural resource exporter, deposits DHE SDA as follows:

• USD1,000,000.00 (one million United States dollars) on 10 November 2026 in respect of PPE dated 5 September 2026 into a foreign currency Special DHE SDA Account maintained with Bank M (State-Owned Bank); and
• USD800,000.00 (eight hundred thousand United States dollars) on 20 November 2026 in respect of PPE dated 10 October 2026 into a foreign currency Special DHE SDA Account maintained with Bank R (State-Owned Bank).

Accordingly, the maximum amount of DHE SDA that may be converted into Indonesian Rupiah by PT D in November 2026 is 50% (fifty percent) of USD1,800,000.00 (one million eight hundred thousand United States dollars), namely USD900,000.00 (nine hundred thousand United States dollars).

Solution for Purchasing Foreign Currency to Cover Shortfalls

Article 40A provides a solution for natural resource exporters that lack sufficient foreign currency to satisfy the minimum DHE SDA placement requirement (30%), or that have converted DHE SDA into Indonesian Rupiah in excess of the maximum limit of 50%.

Such exporters are permitted to purchase foreign currency from a State-Owned Bank in an amount equal to the shortfall or excess, provided that they submit the required underlying document in the form of a certificate issued by the competent authority.

Obligations and Sanctions for State-Owned Banks

Pursuant to Article 62, State-Owned Banks are responsible for ensuring that DHE SDA is placed in domestic instruments in accordance with the applicable provisions and for ensuring that its utilization by exporters complies with the prevailing regulations.

Where a State-Owned Bank fails to fulfil these obligations, BI may impose administrative sanctions.

Failure to ensure the placement of DHE SDA in domestic instruments is subject to an obligation to pay 0.01% (zero point zero one percent) of the amount involved in the violation, with a minimum amount of IDR10,000,000.00 (ten million rupiah) and a maximum amount of IDR1,000,000,000.00 (one billion rupiah).

Failure to ensure the proper utilization of DHE SDA is subject to an obligation to pay IDR1,000,000.00 (one million rupiah) for each violation, with an aggregate maximum of IDR10,000,000.00 (ten million rupiah).

Compliance Monitoring Mechanism and Reminder Issued by Bank Indonesia

Pursuant to Articles 83 and 84, BI implements a monitoring mechanism to oversee exporters' compliance with their obligations relating to the deposit and placement of DHE SDA.

Where BI identifies indications of non-compliance based on the monitoring results, BI will issue a reminder to the exporter through the Foreign Exchange Monitoring and Information System (SIMODIS) or other media designated by BI.

Exporters are required to follow up on such reminder within the prescribed period by submitting evidence demonstrating fulfilment of their obligations as proof of compliance and to avoid the imposition of administrative sanctions under the applicable regulations.

Closing

PADG No. 16 of 2026 introduces several significant changes to the obligations concerning the placement of DHE SDA, including the requirement to place DHE SDA through Special DHE SDA Accounts maintained with State-Owned Banks, the limitation on the conversion of DHE SDA into Indonesian Rupiah, the removal of LPEI's role, and the addition of DHE SDA placement instruments.

In light of these provisions, natural resource exporters and State-Owned Banks need to adjust their operational mechanisms, account management, fund placement, and internal monitoring systems to align with the new regulatory framework. Given that BI also strengthens its compliance monitoring mechanism and the imposition of administrative sanctions, all parties involved in the administration of DHE SDA should ensure that all obligations are fulfilled in a timely manner in order to minimize legal and administrative risks.