05 Oct 2026 · TAMA Insight
Indonesia Updates Export Licensing Framework Through Fourth Amendment to Export Regulation
Indonesia has further refined its export licensing framework through Minister of Trade Regulation No. 5 of 2026 on the Fourth Amendment to Minister of Trade Regulation No. 23…
Indonesia has further refined its export licensing framework through Minister of Trade Regulation No. 5 of 2026 on the Fourth Amendment to Minister of Trade Regulation No. 23 of 2023 concerning Export Policy and Regulation (“Permendag 5/2026”). The regulation forms part of the continuing amendments to the export regime established under Permendag 23/2023 and remains in force as of the date of this article.
Permendag 5/2026 introduces a number of procedural and administrative changes, including greater integration of electronic licensing processes, simplified document submission, mechanisms for withdrawing certain applications, and more specific arrangements concerning re-export. These changes should be read together with the subsequent Minister of Trade Regulation No. 12 of 2026, which constitutes the fifth amendment to Permendag 23/2023 and introduces additional controls over export business licensing.
1. Position of Permendag 5/2026 within the Export Licensing Framework
Permendag 5/2026 does not establish a separate export licensing regime. Rather, it amends Permendag 23/2023, which provides the principal framework for export policy and regulation in Indonesia.
Permendag 23/2023 has been amended several times, initially through Minister of Trade Regulation No. 11 of 2024 and Minister of Trade Regulation No. 21 of 2024, followed by Minister of Trade Regulation No. 9 of 2025. Permendag 5/2026 constitutes the fourth amendment to the regulation, while Permendag 12/2026 subsequently introduced further changes as the fifth amendment.
Permendag 5/2026 took effect on 1 April 2026. Accordingly, provisions of Permendag 23/2023 that were amended or supplemented by Permendag 5/2026 must be read in their amended form from that date.
For exporters, this means that the applicable export licensing requirements should be assessed based on the consolidated framework rather than by referring solely to the original text of Permendag 23/2023.
2. Greater Integration of Electronic Export Licensing
One of the principal features of Permendag 5/2026 is the further integration of the export licensing process into the government’s electronic systems.
Under the existing framework, export licensing applications are submitted electronically through the Indonesia National Single Window (SINSW) and processed through the Inatrade system. Permendag 5/2026 further develops this approach by reducing the need for exporters to repeatedly submit documents that are already electronically available through government systems connected to SINSW.
Where documents required for an export licence are already available electronically through another ministry or government institution connected to SINSW, exporters are not required to upload the same documents again.
This approach is intended to reduce administrative duplication while maintaining the exporter’s responsibility for the accuracy and completeness of the data and documents submitted through the electronic system.
The changes therefore do not eliminate documentary compliance. Rather, they shift part of the process from repeated document submission toward inter-system data integration and electronic verification.
3. Simplification of Administrative and Reporting Requirements
Permendag 5/2026 also introduces changes intended to simplify certain administrative obligations applicable to exporters.
Under the previous framework, exporters could be required to submit various reports concerning export realization and other administrative matters. Where substantially similar information is already recorded through an integrated electronic government system, the amended framework reduces the need for separate reporting.
The practical effect is that exporters may increasingly rely on data already captured through government systems rather than submitting the same information through multiple administrative channels.
At the same time, exporters remain responsible for the accuracy of information submitted electronically. Incorrect or misleading information may still expose an exporter to administrative consequences under the applicable export licensing framework.
Accordingly, the simplification of reporting should not be understood as a reduction of substantive compliance responsibilities. Instead, it primarily concerns how compliance information is submitted and recorded.
4. Automated Export Approval and Digital Processing
The amendments also support a more automated approach to certain export licensing processes where the relevant requirements and supporting information are already integrated into government systems.
Where the required electronic data has been properly integrated and validated, certain licensing processes may proceed with reduced manual intervention. This reflects a broader policy direction toward digitalisation of Indonesia’s business licensing and trade administration.
The underlying distinction between export licensing statuses under Permendag 23/2023 remains relevant, including the distinction between Registered Exporter (Eksportir Terdaftar) and Export Approval (Persetujuan Ekspor) requirements applicable to particular goods.
Consequently, digitalisation does not replace the substantive requirement to determine whether a particular commodity requires an export licence. Rather, it changes the manner in which the relevant licensing process may be administered.
5. New Mechanisms for Application Cancellation and Re-Export
Permendag 5/2026 also introduces mechanisms that were not previously addressed in the same manner under the original framework.
One such development concerns the ability to cancel certain applications for export certificates or licences. This provides exporters with a more defined administrative mechanism where an application no longer needs to proceed.
The regulation also provides a more specific framework concerning re-export. This is relevant where goods involved in an export transaction need to be returned or otherwise processed through a re-export arrangement, including circumstances involving rejection by the destination country or discrepancies in the goods.
The introduction of more specific re-export provisions provides a clearer regulatory basis for transactions that cannot proceed according to the original export arrangement and require the goods to be dealt with through a subsequent export process.
6. Transitional Treatment for Certain Commodities
Permendag 5/2026 also contains transitional arrangements for certain commodities.
Under the relevant transitional provision, exports involving specified tariff or HS codes that had already obtained a registration number and date for the export customs declaration before the effective date of Permendag 5/2026 may proceed without an Export Approval where the provision applies.
The commodities covered include certain types of sea cucumber, including Holothuria lessoni, Thelenota ananas, Thelenota anax, and Thelenota rubralineata, as well as the Sahul crocodile (Crocodylus halli) under the specified tariff classifications.
The transitional treatment is particularly relevant for exporters whose transactions were already registered before 1 April 2026. It distinguishes those transactions from new export activities undertaken after the amendment became effective.
Accordingly, the timing of the customs declaration and its registration may be relevant when determining whether the transitional provision can be relied upon.
7. Relationship with the Fifth Amendment under Permendag 12/2026
Permendag 5/2026 should also be considered alongside Permendag 12/2026, which constitutes the fifth amendment to Permendag 23/2023.
Permendag 12/2026 does not repeal the framework introduced through Permendag 5/2026. Instead, it introduces additional provisions concerning the government’s ability to control export business licensing, including the suspension, freezing, or revocation of export licences in circumstances involving national interests, public interests, government programmes, or directions from the President.
The two amendments therefore operate at different levels of the same export framework. Permendag 5/2026 focuses substantially on procedural simplification, digital integration, and the administration of export licensing, while Permendag 12/2026 adds further mechanisms for governmental control over export licensing.
For exporters, the practical consequence is that regulatory simplification should not be viewed separately from the government’s continuing authority to control export activities where the relevant conditions are met.
8. Practical Implications for Exporters
Exporters should assess their licensing procedures against the amended and consolidated version of Permendag 23/2023 rather than relying solely on the original regulation.
In particular, exporters should consider whether their existing procedures properly reflect the electronic application process through SINSW and Inatrade, including the use of information already available through connected government systems. Internal compliance procedures should also continue to ensure the accuracy of electronically submitted data and documents.
Exporters involved in transactions requiring cancellation of applications or re-export should also consider the procedures introduced under Permendag 5/2026. For commodities subject to transitional treatment, the timing and registration of the relevant export customs declaration may likewise need to be reviewed.
Finally, exporters should read the fourth and fifth amendments together. While Permendag 5/2026 facilitates the administration of export licensing through digital integration and procedural simplification, Permendag 12/2026 adds further mechanisms through which export licences may be controlled, suspended, frozen, or revoked in specified circumstances.
Conclusion
Permendag 5/2026 represents a further development of Indonesia’s export licensing framework, particularly through the integration of electronic systems, simplification of administrative requirements, and the introduction of more specific mechanisms for application cancellation and re-export.
As the fourth amendment to Permendag 23/2023, it should not be read in isolation. The subsequent Permendag 12/2026 further modifies the same framework by introducing additional government control mechanisms. Exporters should therefore assess their licensing and compliance procedures against the consolidated export regime, taking into account both the procedural changes introduced by Permendag 5/2026 and the subsequent controls introduced through Permendag 12/2026.
This alert is part of a series examining recent developments in Indonesia’s trade and regulatory framework. Please feel free to contact us should you wish to discuss these developments further.
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