Mandatory Placement of Export Proceeds in the Mining Sector

Feb 28, 2026 | News

Mandatory Placement of Export Proceeds

The mining sector plays a strategic role in Indonesia’s economic structure. Its substantial contribution demonstrates that natural resource management is closely linked not only to production activities but also to national financial stability. Since 17 February 2025, the Government has extended the mandatory placement period for foreign exchange proceeds derived from exports of natural resource commodities (Devisa Hasil Ekspor Sumber Daya Alam – DHE SDA) in special DHE SDA accounts through the enactment of Government Regulation No. 8 of 2025. In this article, SIP Law Firm examines the scope, objectives, and impact of the DHE SDA placement obligation.

 

Scope of the DHE Obligation in the Mining Sector

 

The mineral and coal (minerba) subsector plays an essential role in Indonesia’s economy. According to data from the Ministry of Energy and Mineral Resources (MEMR), as of 18 December 2025, Non-Tax State Revenue (Penerimaan Negara Bukan Pajak – PNBP) in the energy and mineral resources sector reached IDR 228.05 trillion, with the largest contribution coming from the mineral and coal subsector, amounting to IDR 124.63 trillion.

As reported by Hukum Online, export activities constitute a primary source of foreign exchange earnings for the state. In Indonesia, exports originate from various sectors, including mining. Through mining export activities, the state generates foreign exchange earnings from natural resource exports (DHE SDA), which carry significant value and directly influence national financial stability. Pursuant to Article 1 point 3 of Government Regulation No. 36 of 2023 concerning Foreign Exchange Proceeds from the Exploitation, Management, and/or Processing of Natural Resources (“GR 36/2023”), DHE SDA refers to foreign exchange proceeds derived from the export of goods resulting from the exploitation, management, and/or processing of natural resources.

To strengthen national economic resilience, President Prabowo Subianto mandated the retention of 100% of DHE SDA within the domestic financial system through Government Regulation No. 8 of 2025 concerning Amendments to Government Regulation No. 36 of 2023 (“GR 8/2025”), enacted on 17 February 2025. Article 7 paragraph (1) of GR 8/2025 expressly provides:

“DHE SDA that has been deposited and placed by the exporter into the special DHE SDA account as referred to in Article 6 must remain placed at 100% (one hundred percent) within the Indonesian financial system for a certain period of time.”

The “certain period of time” referred to in Article 7 paragraph (1) of GR 8/2025 is 12 months from the date of placement in the special DHE SDA account. Accordingly, exporters in the mineral and coal sector (excluding oil and gas) must place 100% of their DHE SDA within the national financial system for 12 months.

The exclusion of oil and gas means that DHE SDA placement for this subsector remains subject to Article 7 paragraph (1) of GR 36/2023, which requires placement of at least 30% for a minimum period of three months from the date of placement in the special DHE SDA account.

The extension of the placement period applies not only to mining license holders that directly export commodities, but also to business entities engaged in processing or refining activities that subsequently export their products. Therefore, the DHE SDA obligation functions not merely as an administrative requirement, but as a fiscal instrument embedded throughout the natural resource export value chain.

 

Objectives of the DHE Policy: Economic Control and Downstream Development

 

The policy requiring DHE SDA placement for 12 months plays a strategic role in national economic management. As reported by Indopremier, domestic placement of DHE SDA aims to maintain rupiah exchange rate stability, strengthen foreign exchange reserves, and increase liquidity within the national financial system. This measure aligns with the state’s constitutional mandate under Article 33 of the 1945 Constitution of the Republic of Indonesia.

Law No. 2 of 2025 concerning the Fourth Amendment to Law No. 4 of 2009 on Mineral and Coal Mining (“Mining Law”) emphasizes the importance of increasing added value through domestic processing and refining. The mandatory domestic placement of DHE SDA provides the state with an additional instrument to ensure that the economic benefits of exports do not immediately flow abroad, but instead support domestic investment, including the development of mineral processing facilities.

In this context, the DHE SDA policy bridges monetary policy and industrial policy. The state not only regulates production and export of mining commodities but also controls the foreign exchange flows generated. Downstream development, therefore, represents not merely an industrialization process but a strategy of economic sovereignty integrating natural resource management, financial stability, and national industrial development.

Also read: Legal Accountability for Environmental Damage in the Mining Sector

 

Impact of the Mandatory Placement of DHE SDA in Special Accounts

 

The requirement to place DHE SDA in special accounts for 12 months has generated positive effects for the banking industry. As noted by Hukum Online, the policy has the potential to increase foreign exchange reserves, strengthen Indonesia’s economic foundation, and attract exporter participation.

Beyond its impact on banking, the policy enhances state oversight of export activities in the mining sector. By mandating DHE SDA placement, the Government gains more accurate data on export volumes, transaction values, and corporate financial flows. This mechanism contributes to improved transparency and fiscal compliance in a sector that has historically faced governance scrutiny.

However, despite these benefits, the 12-month placement obligation also poses challenges for business actors. The policy creates significant operational and financial consequences, particularly affecting corporate cash flow and liquidity. It may limit companies’ flexibility in fulfilling overseas payment obligations, financing operations, and managing short-term investment needs.

To mitigate potential adverse impacts, Haykal Hubeis, Secretary General of the Indonesian Processing and Refining Industry Association (AP3I), identified three key measures: conducting thorough financial and cash flow analysis, reviewing investment portfolios, and enhancing operational efficiency.

Accordingly, the DHE SDA placement policy must be accompanied by adaptive implementation mechanisms to ensure that national economic strengthening objectives are achieved without undermining business certainty and operational sustainability in the mining sector.

The mandatory placement of export proceeds from natural resource exports (DHE SDA) reflects the state’s constitutional mandate to manage natural resources for the prosperity of the people. This policy supports the mining downstream agenda by ensuring that export-derived economic benefits contribute to domestic industrial development, while significantly impacting both the banking industry and mining business actors. Ultimately, the successful implementation of the DHE SDA policy depends on balancing national economic control objectives with business certainty for the mining industry.***

Also read: Indonesia’s Mining Regulations and Their Impact on Foreign Investors

 

Regulations:

  • Undang-Undang Dasar Negara Republik Indonesia (“UUD 1945”). 
  • Undang-Undang nomor 2 Tahun 2025 tentang Perubahan Keempat atas Undang-Undang Nomor 4 Tahun 2009 tentang Pertambangan Mineral dan Batubara (“UU Minerba”)
  • Peraturan Pemerintah Nomor 36 Tahun 2023 tentang Devisa Hasil Ekspor dari Kegiatan Pengusahaan, Pengelolaan, dan/atau Pengolahan Sumber Daya Alam (“PP 36/2023”) 
  • Peraturan Pemerintah Nomor 8 Tahun 2025 tentang Perubahan atas Peraturan Pemerintah Nomor 36 Tahun 2023 tentang Devisa Hasil Ekspor dari Kegiatan Pengusahaan, Pengelolaan, dan/atau Pengolahan Sumber Daya Alam (“PP 8/2025”)

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