Compliance Isn’t Enough: Small Gaps That Can Lead to Big Findings in Indonesia’s New Import Oversight Era

Recent findings by Finance Minister Purbaya Yudhi Sadewa during inspections at Tanjung Priok and Tanjung Perak reveal that Indonesia’s import monitoring has entered a much stricter phase.
Audits now target not only those who intentionally manipulate data but also minor discrepancies often overlooked by importers who actually intend to comply.

Many importers believe that as long as documents are complete and there’s no intent to violate, the process will go smoothly.
However, the new oversight pattern shows that administrative compliance alone is no longer enough.
What’s being tested now is data consistency, document accuracy, and the importer’s ability to substantiate declared transaction values.

1. Small Price Differences Can Become Big Findings

The Customs and Excise (DJBC) price comparison system has become more aggressive.
In addition to its internal database, it now compares declared values against market prices, online marketplaces, and historical import data.

A recent Tanjung Perak case — goods worth nearly IDR 50 million declared as only US$7 — is an extreme example.
But the key point is: even small anomalies are now easy to detect.

Even compliant importers may face scrutiny when:

supplier prices appear unusually low without explanation,
cost components (packing, handling, tooling) are missing,
or transaction evidence doesn’t match the declared value.

2. Vendor Documents Don’t Always Meet Indonesian Standards

This is the most common area where importers feel compliant but are actually not audit-ready.

Generic invoices, incomplete packing lists, or vague product descriptions can be deemed non-transparent — even if no wrongdoing was intended.

In Indonesia’s context, DJBC requires:

highly detailed product descriptions,
justifiable transaction values,
consistent documentation from PO to proof of payment,
and logical cost structures.

A compliant importer must ensure that overseas vendors follow Indonesian standards, not just their home-country norms.

3. Internal Inconsistencies Are Now a Red Flag

Auditors no longer review documents in isolation — they analyze inter-document consistency.

Errors once considered minor are now major issues:

PO value ≠ invoice value,
payment dates far from invoice dates,
BL not matching the packing list,
unexplained changes in freight cost,
or internal SKUs not linked to HS codes.

Such inconsistencies may be interpreted as potential misdeclaration.

4. How Compliant Importers Can Stay Comfortable Amid Tightened Oversight

Compliance today means:

being able to justify pricing logic,
having complete supporting documents,
maintaining a clean digital trail,
and closing any gaps that could appear suspicious.

Many companies are now strengthening internal processes and choosing logistics partners with robust documentation systems and audit-ready dashboards.

The Subtle Role of TCI in Minimizing Importer Risk

Without changing the importer’s business flow, TCI’s real-time digital system, full document traceability, and transparent transaction control help companies:

synchronize vendor and internal documents,
store all records within a unified platform,
reduce data discrepancies that may trigger audits,
and easily substantiate declared values during clarifications.

As import supervision tightens, demonstrating consistency, traceability, and clarity becomes key.
Importers with well-documented processes will continue to enjoy smooth operations even under heightened scrutiny.