How to Comply with GR 24/2026 in Indonesia, Competition Compliance for Centralised Commodity Exports

Understanding how to comply with GR 24/2026 in Indonesia is now an operational priority for every exporter, commodity trader, and upstream producer handling strategic natural resources. Government Regulation No. 24 of 2026 (Peraturan Pemerintah Nomor 24 Tahun 2026) requires the centralisation of exports of designated commodities through state-owned export enterprises (Export SOEs), introducing new registration, pricing, and documentation obligations that must be met during a transitional period ending no later than 31 December 2026. The regulation sits alongside commodity-specific Ministerial Regulations, such as MoT Reg No. 15/2026 for coal, and updated procedural rules from the Commission for the Supervision of Business Competition (KPPU), creating a multi-layered competition compliance challenge.

This guide sets out the eligibility criteria, step-by-step compliance process, required documents, timeline, costs, and common pitfalls so that exporters and in-house counsel can act immediately.

Overview of the Process and Who It Applies To

GR 24/2026 establishes a centralised export framework for commodities classified as Strategic Natural Resources (Sumber Daya Alam Strategis). The regulation mandates that exports of these commodities be channelled through designated Export SOEs, which act as principal exporters or intermediaries on behalf of commodity owners and producers. The stated objective is to optimise state revenue, stabilise domestic supply, and strengthen Indonesia’s position in international commodity markets.

The commodities covered by the regulation include, but are not limited to, coal, palm oil and palm-oil derivatives, and ferro-alloys. The precise list of Strategic Natural Resources is defined in the GR itself and elaborated in commodity-specific Ministerial Regulations issued by the Ministry of Trade (MoT). As of June 2026, coal is the first commodity to receive a dedicated implementing regulation (MoT Reg No. 15/2026), with additional commodity regulations expected to follow.

The entities that must comply span the entire export chain: commodity owners who hold title to the goods, trading companies acting as principals or agents, upstream producers who sell into the export market, and the Export SOEs themselves. Foreign-invested companies with export activities involving covered commodities are not exempt, they must either route shipments through an Export SOE or qualify under a specific exemption.

Enforcement and oversight responsibilities are shared among several authorities. The Ministry of Trade administers the registration, single-window submission, and commodity-specific rules. The KPPU monitors market conduct, investigates potential anti-competitive behaviour arising from the centralised structure, and applies its own procedural regulations (notably Peraturan KPPU No. 2/2026). The Ministry of State-Owned Enterprises supervises the Export SOEs, while Customs (Bea Cukai) verifies export declarations at the point of shipment. Competition compliance in Indonesia 2026 therefore requires engagement with multiple regulators simultaneously.

Eligibility and GR 24/2026 Requirements

Eligible Exporters: Domestic Owners vs Traders

GR 24/2026 distinguishes between commodity owners who hold legal title and traders who purchase for resale. Both categories must export through an Export SOE unless they fall within a recognised exemption. Commodity owners enter into offtake or consignment agreements with the designated Export SOE, which then executes the export transaction. Traders who previously exported independently must now either contract with an Export SOE or demonstrate that their shipments fall outside the regulation’s scope.

To be eligible to participate in the Export SOE channel, an exporter must hold a valid export licence (Surat Izin Usaha Perdagangan or equivalent), maintain an active corporate registration, and be able to prove its chain of title to the commodity. Companies must also demonstrate compliance with any domestic supply safeguarding obligations, for example, the domestic market obligation (DMO) applicable to coal producers, before they may route goods through an Export SOE for overseas sale.

Exemptions and Transitional Carve-Outs

Not all exports are captured. GR 24/2026 provides transitional carve-outs for certain categories of exporter and shipment type. Early indications suggest that small-volume exporters below commodity-specific thresholds set in the implementing MoT Regulations may continue to export directly during the transitional period. Exporters operating under long-term offtake agreements executed before the regulation’s effective date may also receive temporary relief, provided they register the agreement with the MoT and the relevant Export SOE before the transitional deadline of 31 December 2026.

The decision flow for determining coverage is straightforward: identify whether the commodity is listed as a Strategic Natural Resource, confirm ownership status and contractual arrangements, and then determine whether a valid exemption or transitional carve-out applies. If no exemption applies, the exporter must contract with an Export SOE before the next shipment.

When KPPU Scrutiny Is Likely to Arise

The centralisation model concentrates export volumes in a small number of Export SOEs, which inherently raises competition law concerns. The KPPU has signalled heightened attention to arrangements that could facilitate price fixing, market allocation, or abuse of a dominant position. Industry observers expect KPPU scrutiny to be triggered where an Export SOE holds a market share exceeding the thresholds set out in Indonesia’s competition law (Law No. 5 of 1999) or where pricing arrangements between the Export SOE and commodity owners appear to deviate from market benchmarks. Exporters whose combined volumes represent a significant share of a particular commodity’s export market should treat KPPU engagement as a near-certainty.

Step-by-Step Compliance Procedure for GR 24/2026

The following compliance steps for exporters in Indonesia represent the minimum procedural flow required to satisfy GR 24/2026, the relevant MoT implementing regulations, and KPPU notification requirements under the 2026 rules. Each step identifies the responsible party, the regulatory touchpoint, and the typical duration.

Step 1, Conduct Immediate Legal and Commercial Triage (Day 0–3)

Identify whether the commodity you export is classified as a Strategic Natural Resource under GR 24/2026. Map the ownership chain from producer to point of export. Review existing sales contracts and offtake agreements to determine whether they contain clauses that conflict with the Export SOE model. Freeze any pending export pricing decisions until the compliance position is clear. Notify senior management and the board that the regulation applies and that a compliance workstream must be initiated. The output of this step is a written triage memo confirming coverage, identifying contractual risks, and recommending next actions.

Step 2, Build the Internal Documentation and Compliance Pack (Day 3–14)

Collect all documents needed for GR 24/2026 compliance. This includes title documents, sales purchase agreements, pricing methodology workbooks, current export permits, customs documentation, and the company’s internal compliance policy. If no compliance policy exists, one must be drafted. Finance teams should prepare a margin workbook that shows the pricing benchmark used, cost build-up, and margin applied. All documents should be assembled in a single compliance pack that can be submitted to the Export SOE, the MoT’s single-window platform, and, if requested, to the KPPU during an investigation. See the required documents table below for the full checklist.

Step 3, Register with and Notify the Competent Authorities (Day 7–30)

Submit the required registration or notification to the designated Export SOE. The form and procedure differ by commodity; for coal, the registration requirements are set out in MoT Reg No. 15/2026. Simultaneously, notify the Ministry of Trade through the applicable registration channel. Where the centralised arrangement involves multiple exporters or producers coordinating volumes through a single Export SOE, consider whether a post-transaction notice must be filed with the KPPU under Peraturan KPPU No. 2/2026. The KPPU notification requirements under the 2026 rules apply where the arrangement meets specified market-share or transaction-value thresholds. The distinction is important: MoT registration is an administrative prerequisite for export clearance, while KPPU notification is a competition law obligation that triggers a separate review process.

Step 4, Prepare Price and Margin Certification and Submit via Single-Window (Day 14–30)

Prepare a price calculation pack that demonstrates how the export price was determined, including the benchmark price, cost elements, and the margin applied. GR 24/2026 requires that pricing through Export SOEs be transparent and commercially reasonable. Submit the price and margin evidence through the MoT single-window platform within the filing window specified in the relevant commodity regulation. For coal, the submission timeline is governed by MoT Reg No. 15/2026. Retain a time-stamped copy of the submission confirmation as evidence of compliance.

Step 5, KPPU Pre-Engagement and Risk Mitigation (Day 7–60, Concurrent)

Run a competition risk assessment in parallel with Steps 2–4. Prepare a short internal memo setting out the factual background, relevant market shares, the pro-competitive rationale for the Export SOE arrangement, and any efficiency justifications. If the risk assessment identifies potential exposure, for example, because the Export SOE arrangement could be characterised as a horizontal agreement or an abuse of dominance, consider voluntary engagement with the KPPU or, where anticompetitive conduct is suspected, a leniency application under the KPPU’s applicable procedures. Early engagement with external competition counsel is strongly recommended at this stage.

Centralised export arrangements do not automatically require KPPU pre-approval, but failing to notify where required can result in administrative penalties and protracted investigations under the KPPU enforcement process.

Step 6, Fulfil Post-Export Obligations and Maintain Records (Ongoing)

After each shipment, update internal records with customs declarations, Export SOE confirmations, pricing evidence, and any KPPU correspondence. Retain all export-related documentation for a minimum of five years, a period consistent with KPPU’s recommended compliance program framework and Customs (Bea Cukai) recordkeeping expectations. Conduct periodic internal audits, at least annually, to verify that the compliance program remains current and that all filings have been made on time. Update the internal compliance policy whenever new implementing regulations or KPPU guidance are issued.

Required Documents and Information for GR 24/2026

The documents needed for GR 24/2026 compliance span corporate, commercial, pricing, and regulatory categories. The table below lists the core documents, together with notes on the issuing party, format, and practical points to watch.

Common documentation pitfalls include submitting unsigned contracts, failing to show an unbroken chain of title, and presenting pricing workbooks that lack benchmark references. Each of these can delay or block the registration process with the Export SOE and the MoT. Exporters should designate a single compliance officer responsible for maintaining the compliance pack and ensuring all documents are current before each shipment.

Timeline for GR 24/2026 Obligations and Key Deadlines

The timeline for GR 24/2026 obligations operates on two tracks: the absolute regulatory deadlines set by the GR and implementing regulations, and the relative operational deadlines that apply to each individual export transaction. As of July 2026, several milestones have already passed, while the critical transitional deadline remains ahead.

The 1 June 2026 implementation date for coal means that coal exporters who have not yet registered with the designated Export SOE and submitted the required documentation under MoT Reg No. 15/2026 are already operating outside the prescribed framework. For other commodities, the transitional window remains open, but the final deadline of 31 December 2026 under GR 24/2026’s transitional clause is firm. Exporters should not wait until the final quarter of 2026 to begin compliance, the administrative registration and KPPU notification processes each take weeks, and delays in document preparation can push the timeline past the deadline.

Exact statutory filing windows and submission formats vary by commodity and by the specific MoT implementing regulation. Exporters should consult the relevant MoT regulation on the JDIH Kementerian Perdagangan portal and the KPPU regulation texts on the JDIH KPPU portal to confirm the applicable windows for their commodity.

Costs, Fees, and Tax Considerations

Complying with GR 24/2026 carries both direct regulatory costs and indirect compliance expenditures. The table below summarises the principal cost categories. Where exact statutory amounts are commodity-specific, exporters should verify current fee schedules on the official JDIH portals before budgeting.

The Export SOE may also charge a commission or service fee for facilitating the export transaction. These fees are typically negotiated as part of the Export SOE contract and will vary depending on commodity type, volume, and the specific SOE involved. Exporters should factor these charges into their margin calculations before finalising pricing workbooks.

What Changed in 2026: GR 24/2026 and Related Competition Compliance Rules

The 2026 regulatory landscape for commodity exports in Indonesia has shifted fundamentally. GR 24/2026 introduced the centralised Export SOE model, which replaced the previous system where multiple private exporters could ship Strategic Natural Resources independently. The regulation requires all covered commodity exports to pass through a designated Export SOE, which is responsible for price administration, single-window documentation, and coordination with the MoT and Customs.

The Ministry of Trade has issued Peraturan Menteri Perdagangan No. 15/2026 as the first commodity-specific implementing regulation, covering coal. This regulation sets out the registration procedure, technical submission requirements, pricing benchmarks, and filing windows that coal exporters must follow when routing exports through an Export SOE. Additional commodity-specific regulations for palm oil and ferro-alloys are expected during the second half of 2026.

On the competition side, the KPPU issued Peraturan KPPU No. 2/2026, which updates the commission’s procedural rules and powers. Early indications suggest that the updated regulation strengthens KPPU’s authority to investigate arrangements that concentrate export volumes and to require post-transaction notifications where market-share or value thresholds are met. The KPPU has also published updated guidance on its compliance program framework, encouraging exporters to adopt internal competition compliance programs aligned with the KPPU’s recommended structure.

The combined practical effect of these 2026 changes is significant: exporters face new registration obligations, mandatory price and margin disclosure, single-window submission requirements, and an elevated risk of KPPU investigation. Companies that have not begun their compliance process should treat these reforms as an immediate operational priority.

Common Pitfalls and How to Avoid Them

The following pitfalls are the most frequent causes of compliance failure, delayed shipments, and KPPU investigations under the GR 24/2026 regime. Each pitfall is accompanied by a concrete mitigation step.

• Missing or incomplete ownership proof. Exporters who cannot demonstrate an unbroken chain of title from producer to export point will be blocked at the registration stage. Mitigation: obtain and verify title documents, stockpile receipts, and warehouse certificates before initiating registration. Audit the chain of title annually.
• Unsigned or draft offtake contracts. Submitting draft or unsigned sales purchase agreements is one of the most common reasons for rejected registrations. Mitigation: ensure all contracts are fully executed, with clear price formulas and ownership transfer clauses, before filing with the Export SOE or MoT.
• Poor pricing justification. Price calculation workbooks that lack benchmark references, contain unexplained margins, or are unsigned will attract KPPU attention and may delay MoT single-window approval. Mitigation: use recognised international benchmarks, document all cost elements, and have the CFO or authorised officer sign the workbook.
• Late or omitted KPPU notification. Where the centralised arrangement meets notification thresholds, failing to file within the statutory window can result in administrative penalties and a full KPPU investigation. Mitigation: run a threshold analysis at Step 1 of the compliance process, engage competition counsel early, and file the notification as soon as the threshold is met.
• Inadequate recordkeeping. Failure to retain export documentation for the recommended minimum of five years leaves the company unable to respond to KPPU information requests or MoT audits. Mitigation: designate a compliance officer, implement a centralised document retention system, and schedule quarterly checks to verify completeness.
• Ignoring the transitional deadline. Exporters who delay compliance in the expectation that the 31 December 2026 deadline will be extended risk being unable to complete the registration and notification process in time. Mitigation: begin the compliance steps immediately and build a buffer of at least 60 days before the deadline.

If a deadline is missed, the consequences may include administrative fines imposed by the MoT, suspension of export privileges, and, where the KPPU identifies a competition law infringement, a formal investigation that can result in significant financial penalties for non-compliance. Exporters who discover a missed deadline should engage qualified competition counsel immediately to assess remediation options and manage any regulatory communication.

Sources

1. KPPU, Peraturan Komisi (KPPU official regulation pages)
2. JDIH KPPU, Peraturan KPPU Nomor 2 Tahun 2026 (PDF)
3. JDIH Kementerian Perdagangan, Peraturan Menteri Perdagangan No. 15/2026 (Coal)
4. Peraturan.go.id, National Legislation Repository
5. JDIH Kementerian Perdagangan, Ministry of Trade JDIH Repository
6. KPPU, Compliance Program Framework (Program Kepatuhan)