Indonesia is entering a new chapter in the governance of its natural resource exports. Under a Government Regulation announced in May 2026, the government has introduced a one-gate export system in Indonesia for three strategic commodities — crude palm oil (CPO), coal, and ferro alloy — to be channelled exclusively through PT Danantara Sumberdaya Indonesia (PT DSI).
The policy arrives amid growing fiscal pressure and the government's broader effort to strengthen state revenue collection. For years, policymakers have argued that practices such as under-invoicing, transfer pricing, and profit shifting through offshore trading hubs have reduced the economic value Indonesia captures from its commodity exports.
President Prabowo Subianto has publicly claimed that under-invoicing and profit-shifting practices may have cost the country more than USD 900 billion since the 1990s.
Against this backdrop, PT DSI is being positioned as a state-backed marketing and trading facility that will play a much larger role in Indonesia's commodity export chain. While exporters previously dealt directly with overseas buyers, the government is now seeking greater visibility over export pricing, volumes, and foreign exchange flows generated by strategic commodities.
The Road Map Toward a One-Gate Export System
Implementation will occur in three phases, each building progressively toward full centralization through PT DSI.
PT DSI will act primarily as a data reviewer and export monitor. Exporters will continue conducting exports independently, while PT DSI participates as a co-exporter with access to export-related information and reporting systems.
PT DSI will begin operating as a trader. Exporters that are operationally ready may start channeling exports through PT DSI on a voluntary basis.
PT DSI will become the sole exporter for coal, CPO, and ferro alloy products. At this stage, PT DSI will purchase commodities directly from domestic producers, assume trading risks, and resell products to international buyers.
⚠ Mandatory compliance deadline — all exporters must be ready.
A fundamental change in transaction structure
What was previously a direct export relationship between Indonesian producers and overseas customers will become a two-step transaction: first between the producer and PT DSI, and then between PT DSI and the international buyer.
What Changes for Businesses?
The most immediate impact will be felt in commercial arrangements and contractual relationships. Government officials have repeatedly stated that existing long-term contracts will continue to be respected under the principle of sanctity of contract. However, pricing mechanisms are expected to receive much closer scrutiny.
Long-term commodity contracts often rely on benchmark-based pricing formulas that adjust at the time of shipment. These pricing mechanisms are precisely where the government believes under-invoicing and transfer pricing risks may arise, making them a key focus of future oversight.
At the same time, businesses continue to seek greater clarity regarding implementation. Industry associations, including the Indonesian Coal Mining Association (APBI), have highlighted the limited availability of technical guidance and warned that a relatively short transition period could create operational challenges.
The concern is practical rather than theoretical. Many producers already operate under contracts that specify product quality, shipment schedules, payment terms, and pricing formulas negotiated well before this policy was introduced. Integrating PT DSI into those arrangements may require significant operational adjustments across the supply chain.
Market reactions have already begun to emerge. In the palm oil sector, several market participants have reportedly delayed transactions while waiting for greater certainty regarding implementation. Such uncertainty has raised concerns about temporary disruptions to trading activity, pricing mechanisms, logistics arrangements, and cash flow management.
Tax Implications to Watch
Beyond commercial considerations, the policy also carries significant tax implications. Once PT DSI becomes the exporting party, several tax rules that currently assume direct exports by producers will require adjustment.
One of the most important areas is VAT refunds. The Directorate General of Taxes (DGT) is currently preparing to implement regulations governing VAT restitution for exports conducted through PT DSI. For many exporters, particularly those in capital-intensive industries, VAT refunds represent a critical component of working capital management. Any changes to refund procedures could therefore have a direct impact on liquidity.
Additional regulations are also being prepared regarding export duties, natural resource non-tax state revenue (PNBP), and other export-related levies to ensure alignment with the new export structure.
Looking Beyond the Transition
While many technical details are still being finalized, the broader direction of policy is becoming increasingly clear. Indonesia is moving toward a more centralized, data-driven, and closely monitored export framework for strategic commodities.
For coal, palm oil, and ferro alloy exporters, the challenge extends beyond understanding the mechanics of PT DSI. Companies should begin evaluating how the new framework may affect each of the following areas:
Existing contracts — Evaluate how the new framework may affect existing contracts and whether long-term agreements align with the incoming two-step transaction structure.
Pricing structures — Benchmark-based pricing formulas common in long-term commodity contracts are a key focus of government oversight regarding under-invoicing and transfer pricing risk.
Supply chains — Integrating PT DSI into existing arrangements may require significant operational adjustments across the supply chain.
Foreign exchange management — Greater government visibility over foreign exchange flows generated by strategic commodities will affect how exporters manage currency exposure.
Transfer pricing positions — The shift to a two-step transaction model introduces new transfer pricing considerations between domestic producers and PT DSI.
Indirect tax obligations — VAT refund procedures, export duties, PNBP, and other export-related levies will require alignment with the new export structure.
Businesses that assess these implications early will be better positioned to navigate the transition before the one-gate export system becomes fully operational in 2027.
Discuss the impact on your business
To discuss how the new export framework may affect your company's trade structure, transfer pricing arrangements, VAT position, or broader tax obligations, reach out to TaxPrime's advisors for a tailored assessment.
Bayu Rahmat Rahayu is an Experienced Transfer Pricing Professional and a specialist in Natural Resources Taxation. He is recognized for his expert knowledge in the extractive industry, specifically within the mining sector. His background combines high-level enforcement with deep regulatory insights.
