Minister of Finance Regulation Number 89 of 2025 Tightening Compliance and Administrative Risks in Excise Goods Administration

Introduction

On December 24, 2025, the Ministry of Finance issued Minister of Finance Regulation Number 89 of 2025 on Storage, Entry, Release, and Transportation of Excise Goods (“MoF Regulation 89/2025”), which will take effect on January 1, 2026. MoF Regulation 89/2025 regulates all businesses in the excise sector, including Factory Entrepreneurs, Storage Place Entrepreneurs, Importers, Distributors, and Retail Place [Tempat Penjualan Eceran (“TPE”)] Entrepreneurs, by establishing digital standards in excise administrative governance framework.

MoF Regulation 89/2025 was established to simplify administrative procedures and adjust technical provisions on the storage and movement of excise goods in line with evolving business practices. These provisions replace the regulations in Minister of Finance Regulation Number 226/MoF Regulation.04/2014 on Storage, Entry, Release, and Transportation of Excise Goods (“MoF Regulation 226/2014”), which were deemed no longer adequate. As stated in the Considerations, the government is adjusting supervision and service mechanisms to align with Law Number 7 of 2021 on Harmonization of Tax Regulations and the utilization of information technology.

Comparison

MoF Regulation 89/2025 revokes and replaces MoF Regulation 226/2014. The following is a comparison between MoF Regulation 89/2025 and MoF Regulation 226/2014:

Key Provisions

Storage and Raw Material Record-Keeping Obligations

Factory Entrepreneurs are required to administer the storage of excise goods with unpaid excise status. Article 3 stipulates that excise goods used as raw materials or auxiliary materials must be stored in the Factory or in a place granted an excise exemption facility. For Small-Scale Factory Entrepreneurs, MoF Regulation 89/2025 grants a simple record-keeping facility for goods inventory using the standard format CSCK-7 as listed in Annex Letter A.

Digitization of Goods Movement (CK-5) and Data Correction Limits

Every entry and release of excise goods to or from a Factory or Storage Place must use an Excise Document (CK-5) submitted electronically. Article 13 and Article 14 regulate specific limits on data correction for Excise Documents (CK-5) based on their function. For CK-5 serving as a movement notification, corrections cannot be submitted for data elements including the Office name and code, registration number and date, type of excise goods, origin of excise goods, settlement method, excise status, notification type, excise facility decision, and description of goods in the event of settlement by payment. Meanwhile, for CK-5 functioning only as a transport protection document, correction limits are looser and are prohibited only for the Office name and code, registration number and date, as well as the type, origin, and status of the excise goods.

Document Integration for Export and Import Efficiency

MoF Regulation 89/2025 regulates document integration for Importers and Exporters. Article 11 states that the transportation of excise goods for export, import, and inter-Bonded Storage [Tempat Penimbunan Berikat (“TPB”)] activities uses customs declarations in accordance with customs regulations. Such customs declarations serve as Excise Documents, so entrepreneurs are not required to submit CK-5 or CK-6 documents separately, unless the transportation is carried out directly by the Factory or Storage Place.

Transport Protection Documents (CK-6) and Retail Exemptions

MoF Regulation 89/2025 further regulates the use of transport protection documents in the distribution of excise goods. Article 8 mandates Excise Documents for the transportation of excise goods with unpaid excise status, whether in bulk or packaged form. For goods on which excise has been paid, Article 9 establishes that the obligation for a transport protection document (CK-6) applies only to Ethyl Alcohol and Beverages Containing Ethyl Alcohol (MMEA). MoF Regulation 89/2025 also regulates exemptions from the CK-6 obligation for transportation from Retail Place (TPE) consisting of beverages containing ethyl alcohol with a content of up to 5% (five percent) or beverages containing ethyl alcohol with a content of more than 5% (five percent) in a maximum quantity of 6 (six) liters. Furthermore, for the sake of business logistics efficiency, MoF Regulation 89/2025 also provides exemptions from Excise Document obligations (CK-5 and CK-6) for the transportation of excise goods carried out inter-Factory or inter-Storage Place holding the same NPPBKC.

Emergency and Logistics Obstacle Management

MoF Regulation 89/2025 regulates the handling of force majeure conditions in the storage and transportation of excise goods. Article 7 permits the release or transfer of excise goods in disaster emergencies, whether natural disasters, non-natural disasters, or social disasters, without a prior transport protection document, with an obligation to report to the Head of Office no later than 6 working days after evacuation. In addition, Article 12 regulates the mechanism for requesting an extension of the transportation period electronically in the event of logistical obstacles, such as damage to means of transport or weather conditions, before the document validity period expires.

Inventory Record Format (Annex Letter A)

Format CSCK-7 must be used by Small-Scale Factory Entrepreneurs utilizing the simple record-keeping facility. This format is a single table containing company identity data, including NPPBKC and Taxpayer Identification Number (NPWP), as well as daily transaction details covering activity date, document number and date, entry quantity, release quantity, ending balance, and type of excise goods produced.

Movement Notification Format (Annex Letter B)

Excise Document CK-5 is used for entry and release notifications, as well as a transport protection document for excise goods with unpaid excise status. Entrepreneurs fill in the required data elements, including excise settlement status and method, notification type (such as export, inter-TPB, or destruction), and information on the transported goods.

Transport Protection Format (Annex Letter C)

Excise Document CK-6 is used as a transport document for Ethyl Alcohol and Beverages Containing Ethyl Alcohol (MMEA) on which excise has been paid. Compared to CK-5, this format contains more limited data elements, covering the identity of the Distributor or originating Retail Place, transport destination identity, invoice or delivery order number, and estimated transportation period.

Transitional Provisions

Article 15 stipulates that Excise Documents for storage, entry, release, and transportation activities of excise goods issued before January 1, 2026, remain valid until the completion of said activities. The completion of such storage, entry, release, and transportation activities shall be carried out based on the provisions of MoF Regulation 226/2014.

Closing

MoF Regulation 89/2025 mandates the use of an application-based system for reporting all CK-5 and CK-6 Excise Documents and imposes limitations on permissible data corrections. Businesses need to adjust to the fulfillment of administrative obligations for Beverages Containing Ethyl Alcohol (MMEA) transport protection documents, with exemption provisions for specific transportation from Retail Place, the use of customs document integration for export and import activities, and the implementation of simple record-keeping for Small-Scale Factory Entrepreneurs. This regulation also regulates the mechanism for extending the transportation period in the event of logistical obstacles and emergency handling procedures, as well as establishing the validity of documents issued before the effective date of this regulation until the completion of the related activities.