18 June 2026

In 2026, the Government issued two amendments to Government Regulation No. 36 of 2023 (“Regulation 36”) on Export Proceeds from Natural Resource Business, Management, and/or Processing Activities, namely Government Regulation No. 2 of 2026 (“Regulation 2”) issued on 14 January 2026 and Government Regulation No. 21 of 2026 (“Regulation 21”) issued on 6 May 2026. Regulation 2 and Regulation 21 introduce new requirements for the handling of export proceeds from natural resources, particularly regarding the requirement to deposit such proceeds with an Indonesian state-owned bank and the expanded scope of the provisions relating to exporters affiliated with states that are party to bilateral trade agreements.

Framework

Repatriation

Exporters must repatriate natural resource export proceeds into the Indonesian financial system. Regulation 36 defines these proceeds as foreign exchange derived from the export of goods originating from the commercial exploitation, management, and/or processing of natural resources, including mining, plantation, forestry, and fisheries (“Export Proceeds”).

Exporters with Export Proceeds valued at a minimum of US$250,000 or its equivalent in the export declaration must deposit the funds into a special account at a state-owned foreign exchange bank (“State-Owned Bank”) no later than the end of the third month following the month of export declaration registration.

Exporters that have repatriated and deposited non-oil and gas Export Proceeds into a special account must maintain 100% of the funds for at least 12 months from the placement date. Exporters in the oil and gas sector must maintain at least 30% of the Export Proceeds in the special account for at least three months from the placement date.

Exporters are required to deposit Export Proceeds from all sectors into (i) special accounts and banking instruments at a State-Owned Bank, (ii) instruments issued by Bank Indonesia, and/or
(iii) sovereign debt instruments and/or state sharia securities denominated in foreign currency.

Export Proceeds placed in the form of banking instruments at a State-Owned Bank or with Bank Indonesia are prohibited from being withdrawn before the maturity date of the relevant instrument. Export Proceeds placed in the form of sovereign debt instruments and/or foreign-currency-denominated state sharia securities are prohibited from being withdrawn before the expiry of the applicable placement period.

Authorised uses of Exports Proceeds

Exporters are authorised  to utilise Export Proceeds maintained in the special account for the payment of (i) export duties and other export-related levies, (ii) loans, (iii) imports, (iv) profits/dividends, and/or (v) other investment-related purposes, such as foreign currency transfers and repatriations for capital, royalties, compensation for losses and expropriation, and proceeds from asset sales, among others.

Where such payments are made through an escrow account, the exporter must maintain the escrow account with the Indonesian Export Financing Institution (Lembaga Pembiayaan Ekspor Indonesia) (“Indonesia Eximbank”) (exclusively for exporters that are debtors of Indonesia Eximbank) and/or foreign exchange banks.

Export Proceeds deposited into a special account for a minimum period of 12 months are permitted to be utilised by the exporter for (i) payment of government obligations, (ii) dividend payments, (iii) payments for the procurement of goods and services, and (iv) repayment of loans for the procurement of capital goods and working capital, all of which must be denominated in foreign currency (“Eligible Uses of Export Proceeds”), and/or (v) conversion into Rupiah at a State-Owned Bank.

In the event of conversion into Rupiah, the exporter is required to ensure that the maximum amount of Export Proceeds eligible for conversion does not exceed 50% of the export value specified in the export declaration.

Where less than 50% of the Export Proceeds is converted into Rupiah, the remaining unconverted Export Proceeds are permitted to be utilised for payments under the Eligible Uses of Export Proceeds.

Tax incentives

Exporters are eligible for tax incentives on income generated from the placement of Export Proceeds. Under Government Regulation No. 22 of 2024 on Income Tax Treatment of Income from the Placement of Natural Resource Export Proceeds in Certain Monetary and/or Financial Instruments in Indonesia, income derived from certain monetary and/or financial instruments - such as deposits, term deposits, promissory notes, and other monetary instruments designated by the Minister of Finance - is subject to a final income tax rate of 0% where the placement period exceeds six months.

Sanctions

Exporters that fail to (i) repatriate and deposit Export Proceeds, (ii) establish or transfer an escrow account, and/or (iii) comply with the provisions regarding the maximum limit for conversion into Rupiah, may be subject to administrative sanctions in the form of suspension of export services.

Other key provisions

Exporters affiliated with states that are party to bilateral trade agreements, memoranda of understanding, or other trade arrangements remain obligated to place at least 30% of Export Proceeds from the mining sector for a minimum period of three months from the date of deposit into a special account at a foreign exchange bank. Exporters are permitted to convert mining-sector Export Proceeds into Rupiah at foreign exchange banks designated by Bank Indonesia.

Regulation 21 has expanded the scope of the provision above by including memoranda of understanding and other trade arrangements in addition to bilateral trade agreements. Furthermore, the foreign exchange banks authorised for the placement of Export Proceeds and the conversion of Export Proceeds into Rupiah will be designated by Bank Indonesia, whereas Regulation 2 did not provide for such designation.

Transitional policies

  • For export declarations issued on or after 1 June 2026, the provisions set forth in Regulation 21 shall apply.
  • For export declarations issued prior to 1 June 2026 that are currently subject to compliance monitoring by Bank Indonesia and/or the Financial Services Authority (Otoritas Jasa Keuangan), such declarations are deemed to have fully satisfied all applicable obligations.