03 Oct 2026 · TAMA Insight
Indonesia Revises the Accounting Framework for Upstream Oil and Gas Non-Tax State Revenue
Indonesia has introduced a revised accounting framework for non-tax state revenue (Penerimaan Negara Bukan Pajak or PNBP) generated from upstream oil and gas activities through Minister of Finance…
Indonesia has introduced a revised accounting framework for non-tax state revenue (Penerimaan Negara Bukan Pajak or PNBP) generated from upstream oil and gas activities through Minister of Finance Regulation No. 64 of 2026 on Technical Guidelines for PNBP Accounting from Upstream Oil and Gas Activities (Regulation 64/2026). The regulation replaces Minister of Finance Regulation No. 115 of 2023 (Regulation 115/2023) and took effect on 27 August 2026.
The amendments address several aspects of upstream PNBP accounting, including revenue classification, the recognition of receipts affected by the specific natural gas pricing policy (Harga Gas Bumi Tertentu or HGBT), foreign currency translation, receivable presentation, and the frequency of transfers from the oil and gas account to the State Treasury.
For upstream oil and gas stakeholders, the changes call for a review of accounting policies, reporting systems, reconciliation procedures, and coordination arrangements. The principal amendments are outlined below.
1. Revised Classification of Upstream PNBP
Regulation 115/2023 classified upstream oil and gas PNBP into two principal categories: natural resources revenue and other PNBP arising from upstream activities, including fines, interest, and penalties.
Regulation 64/2026 introduces a separate category for other natural resources PNBP, expressly covering production bonuses and domestic market obligation (DMO) oil revenue. These receipts are therefore distinguished from general upstream PNBP in the revised classification under Article 2(1).
The change has implications for the presentation and reconciliation of upstream revenue. Accounting records and reporting structures will need to distinguish among:
- oil and gas production-related natural resources PNBP;
- other natural resources PNBP, including production bonuses and DMO oil revenue; and
- other upstream PNBP, such as fines, interest, and penalties.
This classification is also relevant to the legal character of the receipts. The explanation to Article 31(3)(c) of Law No. 22 of 2001 on Oil and Natural Gas identifies production bonuses as one form of state bonus. The revised classification provides a more distinct accounting treatment for these receipts.
In practical terms, the relevant accounting and reporting functions should review their chart of accounts, operational-to-ledger mapping, and reconciliation procedures with the State Oil and Gas Account (Rekening Minyak dan Gas Bumi), having regard to the applicable accounting arrangements under Minister of Finance Regulation No. 212/PMK.02/2021.
2. Net-Basis Recognition for HGBT-Affected PNBP
One of the more substantive changes concerns the accounting treatment of PNBP affected by HGBT.
Under Regulation 115/2023, the impact of the specific natural gas pricing policy was disclosed in the notes to the financial statements, while the general gross-basis recognition principle remained applicable.
Regulation 64/2026 adopts a different approach. Annex I, Chapter II, Section A.6 expressly provides for net-basis recognition for PNBP affected by HGBT as an exception to the general gross-basis principle.
Under this treatment, the relevant PNBP is recognised net of the HGBT-related adjustment. The adjustment is not separately presented as an expense item for this purpose. The exception is limited to receipts affected by HGBT; other upstream PNBP remains subject to the general gross-basis principle.
The amendment therefore requires a distinction between HGBT-affected receipts and other upstream revenue when preparing accounting records and financial statements. Relevant reporting schedules and reconciliation processes should be reviewed to reflect the prescribed net amount.
The treatment may also be relevant to subsequent calculations that use recognised upstream PNBP as an input, including certain state revenue-sharing and regional revenue-sharing processes. The applicable calculation basis should, however, be determined by reference to the specific provisions governing each calculation rather than assuming that every downstream allocation is automatically adjusted in the same manner.
3. Foreign Currency Translation at the Reporting Date
Regulation 64/2026 revises the exchange-rate basis for foreign currency PNBP reported in operational reports.
Under Regulation 115/2023, foreign currency PNBP was translated into rupiah using the exchange rate applicable when the receivable was recognised. Under the revised framework, the translation uses Bank Indonesia’s middle exchange rate on the reporting date, as provided in Annex I, Chapter VI, Section A.4.
The revised approach also addresses the calculation of the State’s share of oil and gas sales. Under Annex II, Chapter IV, Section A.4, foreign currency gas sales for both export and domestic markets are translated using Bank Indonesia’s middle rate at the year-end reporting date.
The same provision addresses foreign currency adjustment components, including overlifting and underlifting receivables, which are subject to year-end translation using the prescribed rate.
These amendments establish a reporting-date translation basis for the relevant PNBP and adjustment components. They also require the accounting functions responsible for sales reporting, receivables, and state-share calculations to review their foreign currency remeasurement procedures.
The revised translation basis is relevant to the data used in oil and gas revenue-sharing calculations, including Dana Bagi Hasil (DBH). In particular, the reporting-date exchange rate should be reflected in the relevant PNBP data submitted for DBH calculation, in accordance with the applicable provisions of Minister of Finance Regulation No. 35 of 2026.
4. Prescribed Rounding of PNBP Receivables
Regulation 64/2026 introduces express rounding requirements for the presentation of PNBP receivables under Annex I, Chapter III, Section A.4.
Rupiah-denominated receivables must be presented in full rupiah, with fractions below 0.50 rounded down and fractions of 0.50 or more rounded up.
Foreign currency receivables must be presented in United States dollars to two decimal places. The prescribed rule requires rounding down where the third decimal place is below 5 and rounding up where it is 5 or higher.
These requirements apply to the preparation of financial statements for fiscal year 2026 under Article 5 of Regulation 64/2026.
Accordingly, relevant accounting systems and reporting templates should be reviewed to ensure that the prescribed rounding is applied consistently at the receivable presentation stage. This should also be considered alongside the reporting and classification requirements applicable to the State Oil and Gas Account under Minister of Finance Regulation No. 212/PMK.02/2021.
5. Revised Frequency of Transfers to the State Treasury
Regulation 64/2026 also revises the frequency of transfers (pemindahbukuan) of natural resources PNBP from the oil and gas account to the State Treasury.
Under Regulation 115/2023, transfers were generally conducted monthly, toward the end of the month. The revised provision in Annex II, Chapter III, Section D.1 establishes a minimum frequency of once every quarter. More frequent transfers remain permissible where considered necessary by the relevant leadership.
The amendment provides greater flexibility in transfer scheduling. It does not, however, displace the separate requirements governing when PNBP becomes payable and must be deposited.
Government Regulation No. 44 of 2025 continues to govern relevant PNBP payment and deposit obligations, including administrative penalties for late payment. The revised transfer frequency should therefore be read together with the applicable payment deadlines and other requirements under the general PNBP framework.
For the parties involved in upstream revenue administration, including SKK Migas or BPMA and the relevant treasury functions, transfer schedules and reconciliation procedures should be reviewed against the revised quarterly minimum and any applicable operational requirements.
The timing of transfers should also be considered in connection with the reporting information required for DBH calculations under Minister of Finance Regulation No. 35 of 2026. The change in transfer frequency should not be treated as an extension of any separate statutory reporting or payment deadline.
6. Practical Considerations for Upstream Stakeholders
Taken together, Regulation 64/2026 requires attention to several interconnected areas of upstream PNBP administration.
Accounting policies and chart of accounts. The revised classification requires separate treatment of other natural resources PNBP, including production bonuses and DMO oil revenue. Accounting policies and ledger mapping should reflect the distinction.
HGBT-related reporting. PNBP affected by HGBT must be recognised on a net basis under the specific exception in Regulation 64/2026. Reporting procedures should distinguish these receipts from those that remain subject to gross-basis recognition.
Foreign currency remeasurement. The use of Bank Indonesia’s middle rate at the reporting date requires relevant systems and schedules to accommodate year-end translation, including for gas sales and overlifting or underlifting adjustments.
Receivable presentation. The prescribed rounding conventions should be reflected in accounting system settings, reporting templates, and review procedures for fiscal year 2026 financial statements.
Transfer and reconciliation arrangements. The quarterly minimum transfer frequency should be incorporated into cash management and reconciliation planning, while preserving compliance with the applicable PNBP payment, deposit, and reporting requirements.
These operational considerations should be assessed alongside Law No. 9 of 2018 on Non-Tax State Revenue and the sector-specific rules governing upstream oil and gas revenue administration.
7. Effective Date and Continuing Application
Regulation 64/2026 took effect on 27 August 2026 and replaces Regulation 115/2023. Its transitional provision requires the prescribed receivable presentation and rounding requirements to be applied in preparing fiscal year 2026 financial statements.
The regulation therefore establishes the revised technical accounting framework for upstream oil and gas PNBP, while the broader statutory and sectoral provisions governing PNBP payment, administration, and revenue sharing continue to apply to the extent relevant.
For upstream contractors and government revenue administrators, the immediate task is to assess whether existing accounting policies, reporting systems, foreign currency schedules, and transfer procedures are consistent with the revised requirements.
This update forms part of our continuing review of regulatory developments affecting Indonesia’s energy and natural resources sectors. Please feel free to contact us should you wish to discuss the implications of Regulation 64/2026 for your operations or reporting arrangements.
Disclaimer: Here
For additional insights on Indonesian immigration compliance and global mobility matters, explore our related publications:
Indonesia Establishes Carbon Trading Framework for the Waste Sector
Indonesia Updates Preclinical In Vivo Toxicity Testing Guidelines
POJK 13/2026: Regulation of Stock Exchange Shareholders and Ownership Structure
