Business

Changes to Import Policies and Regulations: Adjustments to Import Licensing, Reporting Obligations, and Administrative Sanctions for Importers

By Saka Wibisono & Partners | November 3, 2026

Overview

The Indonesian Government, through the Ministry of Trade, has issued Minister of Trade Regulation Number 18 of 2026 concerning the Second Amendment to Minister of Trade Regulation Number 16 of 2025 on Import Policies and Regulations (“MOT Regulation 18/2026”).

The Regulation introduces several adjustments to Indonesia’s import regulatory framework, particularly concerning import licensing procedures, Import Approvals (Persetujuan Impor or “PI”), Surveyor Reports (Laporan Surveyor or “LS”), reporting obligations, and administrative sanctions applicable to importers.

MOT Regulation 18/2026 amends Minister of Trade Regulation Number 16 of 2025, as previously amended by Minister of Trade Regulation Number 37 of 2025. These amendments are intended to improve the administration of import licensing procedures, provide greater legal certainty for business actors, and strengthen regulatory supervision over import activities.

Adjustments to Import Licensing and Approval Procedures

One of the principal amendments concerns the procedures for obtaining and amending import business licences. Under Article 12, the Regulation clarifies the examination, automatic issuance, and rejection of import licensing applications submitted through the INATRADE System.

Furthermore, Article 19 introduces adjustments to the automatic issuance of amended import licences and their respective validity periods. These provisions are intended to streamline administrative procedures while maintaining compliance with the applicable import requirements.

The Regulation also introduces changes to the extension of Import Approvals under Article 22, particularly in circumstances involving delays in the arrival of imported goods. Importers must pay close attention to the validity periods of their Import Approvals and ensure that the relevant shipment documentation, including Bills of Lading (B/L) or Air Waybills (AWB), is properly maintained to support extension applications where applicable.

Surveyor Reports and Import Documentation Requirements

Further adjustments are introduced concerning the examination of import documentation and the issuance of Surveyor Reports.

Articles 25, 29, and 31 address the consistency of information contained in Import Approvals, customs declaration documents, and Surveyor Reports, including circumstances in which Surveyor Reports may be issued after the expiration of the relevant import licence.

In addition, Articles 55 and 57 refine the procedures for issuing and amending Certificates (Surat Keterangan). These adjustments highlight the importance of maintaining consistency across import-related documents and ensuring that verification and technical inspection procedures comply with the applicable regulatory requirements.

Import Reporting Obligations and Administrative Sanctions

MOT Regulation 18/2026 reinforces the importance of complying with import reporting obligations, including the submission of import realisation reports and, where applicable, goods distribution realisation reports.

Importers are required to submit the relevant reports in accordance with the applicable requirements and reporting schedules. Companies should therefore maintain accurate records and regularly monitor their import and distribution activities to minimise regulatory and operational risks.

The Regulation also amends the provisions governing administrative sanctions for importers who fail to fulfil their reporting obligations. Under Articles 69 to 71, non-compliance may initially result in an electronic warning.

If the outstanding reporting obligations remain unfulfilled within 30 days following the warning, further administrative measures may apply, including the freezing of import licences or Certificates, suspension of licensing services, and recommendations to suspend verification or technical inspection services.

Frozen licences or Certificates may be reactivated once the relevant reporting obligations have been fulfilled.

Exemptions from Import Policies and Regulations

Another notable development is the introduction of Article 91A, which provides a mechanism for granting exemptions from import policies and regulations where disruptions affect the smooth flow of imported goods.

Such exemptions may be considered based on national interests, matters affecting public welfare, the implementation of government programmes, or Presidential directives.

The granting of exemptions is subject to the relevant coordination or decision-making mechanisms. The Director General, acting on behalf of the Minister of Trade, subsequently issues the exemptions through the INATRADE System, which are then transmitted to the Indonesia National Single Window System (SINSW).

Effective Date and Implications for Businesses

MOT Regulation 18/2026 was stipulated on 3 June 2026 and promulgated on 4 June 2026. Pursuant to Article II, the Regulation entered into force on the date of its promulgation, although certain provisions were subject to a deferred implementation period of 30 days.

These amendments highlight the importance of maintaining regulatory compliance throughout the import process, from licensing applications and shipment documentation to post-import reporting obligations.