Legal Alert No. 66/2026

Updated technical requirements for warehouses under Bappebti Regulations No. 1 and 2 of 2026

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  • Newsletter
  • 10 minute read
  • August 2026

Introduction

On 15 July 2026, the Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi or Bappebti) issued Bappebti Regulation No. 1 of 2026 on Technical Requirements for Warehouses within the Warehouse Receipt System (Bappebti Reg. 1/2026). The regulation sets out detailed requirements regarding the permitted use, specifications, and construction of warehouses operating within the Warehouse Receipt System. One of the provisions in Bappebti Regulation 1/2026 referring to the implementation of the Indonesian National Standard (Standar Nasional Indonesia or SNI) on warehouses is elaborated through Bappebti Regulation No. 2 of 2026 on the Determination of Warehouse Requirements for Goods Stored in the Warehouse Receipt System (Bappebti Reg. 2/2026).
 

Key points

Based on Bappebti Reg. 1/2026, Warehouse Managers must comply with the following technical requirements under Article 2, which form the basis for the approval of warehouses by the Supervisory Agency (Badan Pengawas Sistem Resi Gudang) in approving warehouses within the Warehouse Receipt System:

Requirements

Remarks

 

Purpose of use

  • The ability of the warehouse to maintain the safety, security, and quality of stored goods.
  • The mechanism for the management of the warehouse within the Warehouse Receipt System.

 

Location

  • Free from flooding, landslides, or other potential natural disasters.
  • Adequate transport access that can be passed by motor vehicles or other means of transportation.

 

 

 

 

 

Type and size

  • The conformity of the type and classification of warehouses with the goods that may be stored within the Warehouse Receipt System.
  • ·The types of warehouses include silos, cold storage, enclosed warehouses, open warehouses, and tanks.
  • ·The size of the warehouse takes into account the height, area, and capacity details of the warehouse.

 

 

 

 

Construction, humidity, and air temperature

  • The building structure, roof, walls, floor, and doors must be sturdy, must not leak, and must be capable of withstanding structural loads, stored-goods loads, and external loads arising from human activity, wind, rain, and earthquakes.
  • Good air circulation and/or stable air temperature, and a level of air humidity appropriate to the type and characteristics of the goods.

 

 

 

 

Equipment

The following equipment must be available in the warehouse:

  • Loading and unloading equipment
  • Storage equipment
  • Measuring, gauging, and/or weighing equipment
  • Environmental control equipment
  • Warehouse security equipment
  • Cleaning equipment
  • Communication, technology, and information equipment

 

 

Warehouse Tenure

Warehouse owned by the Warehouse Manager:

Bappebti Reg. 1/2026 does not prescribe a minimum period.

Warehouse not owned by the Warehouse Manager:

The warehouse tenure shall refer to the substance of the cooperation agreement or lease agreement.

 

 

 

 

 

 

 

Reference to SNI Implementation under Bappebti Reg. 2/2026

Pursuant to Article 4 of Bappebti Reg. 1/2026, Bappebti may require that all or part of the technical requirements refer to the applicable SNI on warehouses; in the absence of an applicable SNI, Bappebti may itself establish the relevant technical requirements. This authority is implemented through Bappebti Reg. 2/2026, which specifies the applicable SNI standards for warehouse certification:

a.     SNI 7331:2021 – Agricultural commodity warehouses

b.     SNI 8278:2021 – Agricultural commodity silos

c.     SNI 19‑1674‑1989 – Rubber warehouses

d.     SNI 8446:2022 – Salt commodity warehouses

e.     SNI 9174:2023 – Controlled atmosphere storage (CAS) warehouses

f.      SNI 8661:2023 – Cold storage warehouses for fish commodities

Under Article 3 of Bappebti Reg. 2/2026, the Conformity Assessment Institution (Lembaga Penilai Kesesuaian or LPK) must refer to both the general technical requirements under Bappebti Reg. 1/2026 and these SNI-based requirements (as detailed in the Appendix to Reg. 2/2026) when conducting conformity assessments and issuing warehouse certificates.

Transitional provision

Bappebti Reg. 2/2026 provides that warehouses that have obtained approval from Bappebti prior to the entry into force of the regulation will remain valid. However, such warehouses must be adjusted to comply with the new requirements no later than one year after the regulation becomes effective.

Applications for warehouse approval that are currently under review may continue to be processed, provided that they are first adjusted to comply with the applicable technical requirements and SNI standards.

Conclusion

In light of these requirements, Warehouse Managers should review whether their warehouses satisfy both the technical requirements under Bappebti Reg. 1/2026 and the applicable SNI standards under Bappebti Reg. 2/2026, taking into account the type of goods stored.. Warehouse Managers with existing Bappebti approvals must bring their warehouses into compliance within one year, while those with pending applications must first conform with the technical and SNI requirements before processing can continue.

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