DSI Risk Tracker

Legal basis

This regulation is based on Article 33 of the 1945 Constitution (UUD 1945), which mandates that strategic SDA are controlled by the state for the prosperity of the people. Its objectives are to optimize state revenue, maintain domestic supply, strengthen economic resilience, and increase product added value.

Execution framework

Exports of strategic natural resource commodities, including coal, palm oil, and ferro alloy, will be managed through a State-Owned Export Enterprise during the transition period from 1 June to 31 December 2026. Business actors are required to submit export documents, sales contracts, and related data through integrated government systems such as CEISA, SINSW, INATRADE, SiMoDIS, and MOMS, while exemptions may be granted for companies with government-recognized commitments on investment, divestment, or domestic processing/refining.

Main objects affected

• Strategic commodities including coal, palm oil, and ferro alloy.
• Export management including the determination of selling prices, profit margins, commodity verification, logistics, and export insurance.
• Existing contracts between suppliers and buyers

Risk mapping

• Ambiguous price and margin standard
• Business actors may be exempted if they have commitments on investment, divestment, or domestic processing/refining, but there are no measurable thresholds or minimum requirements.
• Pre-existing export contracts must be evaluated by BUMN Ekspor, but the regulation does not explain what happens if those contracts are deemed non-compliant, creating potential contract dispute risks, while the dispute resolution mechanism remains unclear
• Many technical details are delegated to ministries and agencies, which may create delays, overlapping authority, or bureaucratic bottlenecks during the short transition period

Strategic implication

• Indonesia centralizes the export of initial strategic natural resource commodities, namely coal, palm oil, and ferro alloy, through a State-Owned Export Enterprise, strengthening the state’s bargaining power in setting selling prices and margins in the global market.
• Export control through the State-Owned Export Enterprise may serve as an instrument to accelerate downstream processing, as business actors seeking exemptions must demonstrate commitments related to investment, divestment, or domestic processing/refining.
• Mandatory reporting of export documents and sales contracts through systems connected to CEISA, SINSW, SiMoDIS, and MOMS increases state visibility over export transactions, commodity values, and potential under-invoicing practices.
• State-led export management enables stronger control over the allocation, distribution, and stabilization of strategic commodities to ensure domestic supply before exports are released to international markets.
• The regulation reflects a shift in the state’s role from being primarily a regulator to becoming a direct commercial manager of strategic natural resources, aiming to capture added value and export margins for national interests.

DSI impact

While the regulation aims to create a long-term structural shift by strengthening the state’s role in price-setting and accelerating domestic downstream processing, the current impacts are more transitional and operational. These include bureaucratic disruption, and uncertainty surrounding the evaluation of pre-existing private export sales contracts.