PT PMA Annual Report Indonesia 2026: New SABH Filing Requirements Under Permenkum 49/2025
What Changed Under Permenkum 49/2025
Indonesia has introduced one of the most significant corporate compliance changes affecting Limited Liability Companies (Perseroan Terbatas – PT) and Foreign Investment Companies (PT PMA) in recent years.
Minister of Law Regulation No. 49 of 2025 (Permenkum 49/2025), which entered into force in December 2025, replaces earlier procedural regulations and introduces a structured annual reporting process that extends beyond the traditional Annual General Meeting of Shareholders (RUPS).
Under the new framework, approval of the annual report is no longer solely an internal corporate matter. Following approval by the shareholders, the resolution must be formalised in a notarial deed and submitted electronically through the Legal Entity Administration System (SABH) within the prescribed period.
For many Indonesian companies, these steps represent an additional administrative obligation. For foreign-owned PT PMA companies, however, they introduce a compliance requirement that may easily be overlooked because it differs from the annual tax reporting and accounting procedures that many foreign directors are already familiar with.
The regulation forms part of Indonesia's broader effort to strengthen corporate governance, improve the accuracy of legal entity records, and increase transparency within the national corporate registry administered by the Directorate General of General Legal Administration (AHU).
Official SourcesThis article is based on Minister of Law Regulation No. 49 of 2025 (Permenkum 49/2025) together with publicly available implementation guidance and professional commentary published after the regulation entered into force.
Because implementation guidance may continue to evolve, companies should verify whether additional circular letters, technical instructions, or Ministry announcements have been issued after the date of publication.
Useful official references:
Minister of Law Regulation No. 49 of 2025 (Permenkum 49/2025), which entered into force in December 2025, replaces earlier procedural regulations and introduces a structured annual reporting process that extends beyond the traditional Annual General Meeting of Shareholders (RUPS).
Under the new framework, approval of the annual report is no longer solely an internal corporate matter. Following approval by the shareholders, the resolution must be formalised in a notarial deed and submitted electronically through the Legal Entity Administration System (SABH) within the prescribed period.
For many Indonesian companies, these steps represent an additional administrative obligation. For foreign-owned PT PMA companies, however, they introduce a compliance requirement that may easily be overlooked because it differs from the annual tax reporting and accounting procedures that many foreign directors are already familiar with.
The regulation forms part of Indonesia's broader effort to strengthen corporate governance, improve the accuracy of legal entity records, and increase transparency within the national corporate registry administered by the Directorate General of General Legal Administration (AHU).
Official SourcesThis article is based on Minister of Law Regulation No. 49 of 2025 (Permenkum 49/2025) together with publicly available implementation guidance and professional commentary published after the regulation entered into force.
Because implementation guidance may continue to evolve, companies should verify whether additional circular letters, technical instructions, or Ministry announcements have been issued after the date of publication.
Useful official references:
- AHU Document Repository (Permenkum No. 49 Tahun 2025)
- Directorate General of General Legal Administration (AHU)
- AHU Online – PT (Perseroan Terbatas) Services (SABH access)
Before | After |
Annual report approved internally through RUPS | Annual report approved by RUPS and submitted through SABH |
No dedicated electronic annual filing requirement | Mandatory electronic submission through SABH after notarial documentation |
Limited administrative enforcement | Administrative sanctions may apply for non-compliance, including written warnings and possible suspension of SABH access in accordance with the regulation |
Internal governance focus | Internal governance combined with Ministry reporting and corporate registry compliance |
Who Must Prepare and Submit the Annual Report
The new reporting framework established under Permenkum No. 49 of 2025 clearly allocates responsibilities among the company's governing bodies. While the filing itself is ultimately submitted through the SABH system, the annual report is the result of several mandatory corporate actions that must occur in the correct sequence.
For foreign investors, one of the most important points is that the annual report is not simply an accounting document. It is a corporate governance document that passes through internal review, shareholder approval, notarial documentation, and finally electronic submission to the Ministry of Law.
For foreign investors, one of the most important points is that the annual report is not simply an accounting document. It is a corporate governance document that passes through internal review, shareholder approval, notarial documentation, and finally electronic submission to the Ministry of Law.
Role of the Board of Directors (Direksi)
The Board of Directors (Direksi) carries primary responsibility for preparing the company's annual report.
Among other matters, the Directors are responsible for ensuring that the report accurately reflects:
Among other matters, the Directors are responsible for ensuring that the report accurately reflects:
- the company's financial position;
- business activities during the financial year;
- significant operational developments;
- corporate governance information;
- other information required by Indonesian company law and Permenkum 49/2025.
Role of the Board of Commissioners (Dewan Komisaris)
The Board of Commissioners performs an oversight function rather than managing the company directly.
Before the annual report is submitted to shareholders, the Commissioners review the report and prepare their supervisory assessment.
This review forms an important part of Indonesia's corporate governance framework and demonstrates that the company's management has been independently supervised before shareholders approve the report.
Before the annual report is submitted to shareholders, the Commissioners review the report and prepare their supervisory assessment.
This review forms an important part of Indonesia's corporate governance framework and demonstrates that the company's management has been independently supervised before shareholders approve the report.
Role of the Annual General Meeting (RUPS)
The Annual General Meeting of Shareholders (RUPS) is the corporate body responsible for formally approving the annual report.
Under Indonesian company law, the Annual RUPS should normally be held within six months after the end of the company's financial year.
For companies whose financial year ends on 31 December, this generally means the Annual RUPS should be conducted no later than 30 June of the following year.
Approval of the annual report by the shareholders represents a significant corporate milestone because it also forms the basis for granting acquit et de charge (release and discharge) to the Directors and Commissioners, where applicable under Indonesian company law and the resolutions adopted by the shareholders.
Under Indonesian company law, the Annual RUPS should normally be held within six months after the end of the company's financial year.
For companies whose financial year ends on 31 December, this generally means the Annual RUPS should be conducted no later than 30 June of the following year.
Approval of the annual report by the shareholders represents a significant corporate milestone because it also forms the basis for granting acquit et de charge (release and discharge) to the Directors and Commissioners, where applicable under Indonesian company law and the resolutions adopted by the shareholders.
Role of the Notary
One of the most significant procedural changes introduced by Permenkum 49/2025 is the requirement that the shareholder approval of the annual report be documented in a notarial deed.
Meeting minutes prepared internally are no longer sufficient for completing the reporting process.
The notarial deed becomes one of the mandatory documents that must accompany the electronic submission to the Ministry through the SABH system.
Meeting minutes prepared internally are no longer sufficient for completing the reporting process.
The notarial deed becomes one of the mandatory documents that must accompany the electronic submission to the Ministry through the SABH system.
Role of AHU and the SABH System
After the annual report has been approved by the shareholders and recorded in a notarial deed, the required documents must be submitted electronically through the Legal Entity Administration System (SABH) administered by the Directorate General of General Legal Administration (AHU).
Once the submission has been accepted, the Ministry issues an electronic acknowledgment of receipt confirming that the annual reporting obligation has been fulfilled.
Once the submission has been accepted, the Ministry issues an electronic acknowledgment of receipt confirming that the annual reporting obligation has been fulfilled.
Practical Note for Foreign-Owned PT PMA Companies
Many foreign shareholders assume that annual tax reporting or audited financial statements automatically satisfy all Indonesian corporate reporting requirements.
Tax compliance must also be reviewed separately, including whether the company may continue using the 0.5% final tax or must calculate corporate income tax under the ordinary regime following PP 20/2026.
Under the new regulation, this assumption may lead to compliance issues.
The annual corporate reporting process now involves corporate governance, shareholder approval, notarial documentation, and electronic submission through SABH.
These obligations exist alongside tax and accounting requirements rather than replacing them. Companies should therefore coordinate early with their directors, commissioners, accountants, corporate secretary (if applicable), and notary to ensure that each step is completed within the prescribed timeframe.
For companies selling through marketplaces, tax coordination should also cover the marketplace PPh Article 22 withholding framework. DJP confirmed that withholding under PMK 37/2025 began on 1 October 2026 for the four marketplace operators appointed on 24 September 2026. Companies should verify the withholding applied to their transactions, keep their tax information and any required exemption documents up to date, and reconcile marketplace deductions with their accounting records.
Tax compliance must also be reviewed separately, including whether the company may continue using the 0.5% final tax or must calculate corporate income tax under the ordinary regime following PP 20/2026.
Under the new regulation, this assumption may lead to compliance issues.
The annual corporate reporting process now involves corporate governance, shareholder approval, notarial documentation, and electronic submission through SABH.
These obligations exist alongside tax and accounting requirements rather than replacing them. Companies should therefore coordinate early with their directors, commissioners, accountants, corporate secretary (if applicable), and notary to ensure that each step is completed within the prescribed timeframe.
For companies selling through marketplaces, tax coordination should also cover the marketplace PPh Article 22 withholding framework. DJP confirmed that withholding under PMK 37/2025 began on 1 October 2026 for the four marketplace operators appointed on 24 September 2026. Companies should verify the withholding applied to their transactions, keep their tax information and any required exemption documents up to date, and reconcile marketplace deductions with their accounting records.
Key Deadlines for PT and PT PMA Companies
One of the most important aspects of the new annual reporting framework is compliance with the statutory deadlines. Missing a filing deadline may trigger administrative procedures that can delay future corporate actions and create unnecessary complications when companies need to update their corporate records.
Although every company should verify the reporting period applicable to its own financial year, the timeline introduced by Permenkum No. 49 of 2025 follows a logical sequence of corporate governance steps.
Although every company should verify the reporting period applicable to its own financial year, the timeline introduced by Permenkum No. 49 of 2025 follows a logical sequence of corporate governance steps.
Step 1: Financial Year Ends
The annual reporting process begins immediately after the end of the company's financial year.
For most PT and PT PMA companies in Indonesia, the financial year ends on 31 December, although some companies adopt a different accounting period depending on their Articles of Association.
The annual report should be prepared using the financial information relating to that completed financial year.
For most PT and PT PMA companies in Indonesia, the financial year ends on 31 December, although some companies adopt a different accounting period depending on their Articles of Association.
The annual report should be prepared using the financial information relating to that completed financial year.
Step 2: Directors Prepare the Annual Report
Following the close of the financial year, the Board of Directors prepares the company's annual report together with the supporting financial statements and other information required by Indonesian company legislation.
Depending on the company's size and business activities, preparation may involve coordination between management, accountants, auditors, corporate secretaries, and external advisers.
Companies should begin this process well before the statutory deadlines to allow sufficient time for internal review.
Depending on the company's size and business activities, preparation may involve coordination between management, accountants, auditors, corporate secretaries, and external advisers.
Companies should begin this process well before the statutory deadlines to allow sufficient time for internal review.
Step 3: Commissioners Review the Report
Before shareholders approve the annual report, the Board of Commissioners should review the report and perform its supervisory function.
This review provides shareholders with an independent assessment of the company's management during the reporting period and forms part of Indonesia's corporate governance framework.
This review provides shareholders with an independent assessment of the company's management during the reporting period and forms part of Indonesia's corporate governance framework.
Step 4: Annual General Meeting (RUPS)
The Annual General Meeting of Shareholders (RUPS) should generally be held within six months after the end of the financial year.
For companies whose financial year ends on 31 December, this means the Annual RUPS will normally take place no later than 30 June of the following year.
During the meeting, shareholders consider and approve the annual report, adopt the relevant corporate resolutions, and, where appropriate, grant acquit et de charge to the Directors and Commissioners.
For companies whose financial year ends on 31 December, this means the Annual RUPS will normally take place no later than 30 June of the following year.
During the meeting, shareholders consider and approve the annual report, adopt the relevant corporate resolutions, and, where appropriate, grant acquit et de charge to the Directors and Commissioners.
Step 5: Notarial Deed
After the shareholders approve the annual report, the corporate resolutions should be documented in a notarial deed prepared by an Indonesian notary.
This deed becomes one of the supporting documents required for the electronic filing process.
Companies should avoid leaving this step until the last moment, as preparing the deed may require supporting corporate documents and coordination between shareholders and the notary.
This deed becomes one of the supporting documents required for the electronic filing process.
Companies should avoid leaving this step until the last moment, as preparing the deed may require supporting corporate documents and coordination between shareholders and the notary.
Step 6: Submission Through SABH
Following execution of the notarial deed, the annual report must be submitted electronically through the Sistem Administrasi Badan Hukum (SABH).
Under Permenkum No. 49 of 2025, the submission should generally be completed within 30 days after the notarial deed has been signed.
The Ministry then records the submission through the AHU system and issues an electronic acknowledgement confirming receipt.
Under Permenkum No. 49 of 2025, the submission should generally be completed within 30 days after the notarial deed has been signed.
The Ministry then records the submission through the AHU system and issues an electronic acknowledgement confirming receipt.
If a Deadline Is Missed
Where a company fails to submit its annual report within the prescribed period, the regulation provides for a sequence of administrative measures rather than immediate penalties.
Depending on the circumstances, this may include:
Practical Tip for Foreign Directors
Practical Tip for Foreign Directors
Rather than treating the annual report as a single filing, it is advisable to manage it as a corporate compliance project with several interconnected steps.
Planning the process early in the year gives directors sufficient time to prepare financial statements, coordinate the Annual RUPS, obtain the required notarial documentation, and complete the SABH submission before the statutory deadlines.
Depending on the circumstances, this may include:
- a written warning;
- an opportunity to correct the non-compliance within the specified period;
- further administrative measures if the company fails to comply after receiving the warning, including possible suspension of access to certain SABH services as provided under the regulation.
Practical Tip for Foreign Directors
Stage | Typical Deadline |
Financial year ends | 31 December (for most companies) |
Directors prepare annual report | Following year-end |
Commissioners review | Before Annual RUPS |
Annual RUPS | Within 6 months after year-end |
Notarial deed | After RUPS approval |
SABH submission | Within 30 days after signing the notarial deed |
Correction period (if warning issued) | As provided in the warning under the regulation |
Practical Tip for Foreign Directors
Rather than treating the annual report as a single filing, it is advisable to manage it as a corporate compliance project with several interconnected steps.
Planning the process early in the year gives directors sufficient time to prepare financial statements, coordinate the Annual RUPS, obtain the required notarial documentation, and complete the SABH submission before the statutory deadlines.
What Should You Do If the Annual Reporting Process Is Incomplete?
Start by identifying which stage remains incomplete: preparation of the annual report, review by the Board of Commissioners, shareholder approval, notarial documentation, or submission through SABH. The corrective steps will depend on the company’s actual position.
If shareholder approval has already been obtained, ask your notary to confirm whether it has been recorded in the required notarial deed and whether the SABH notification has been submitted. Request the Ministry’s acknowledgment of receipt rather than relying solely on confirmation that the documents were prepared.
Use the actual dates of meetings, approvals and signatures. If a deadline has already passed, ask your notary to assess the available filing or correction procedure; do not backdate documents to make the process appear timely.
Keep the approved annual report, supporting financial statements, shareholder resolutions, notarial deed, SABH acknowledgment and any warnings together in the company’s corporate records.
If shareholder approval has already been obtained, ask your notary to confirm whether it has been recorded in the required notarial deed and whether the SABH notification has been submitted. Request the Ministry’s acknowledgment of receipt rather than relying solely on confirmation that the documents were prepared.
Use the actual dates of meetings, approvals and signatures. If a deadline has already passed, ask your notary to assess the available filing or correction procedure; do not backdate documents to make the process appear timely.
Keep the approved annual report, supporting financial statements, shareholder resolutions, notarial deed, SABH acknowledgment and any warnings together in the company’s corporate records.
What Must Be Included in the Annual Report
Preparing the annual report involves considerably more than compiling the company's financial statements.
Both the Indonesian Company Law and Permenkum No. 49 of 2025 establish the minimum information that must be included before the report can be presented to the Annual General Meeting of Shareholders (RUPS) and subsequently submitted through the SABH system.
Although the level of detail will vary depending on the size and complexity of the business, companies should ensure that every mandatory component has been properly prepared before commencing the approval process.
Both the Indonesian Company Law and Permenkum No. 49 of 2025 establish the minimum information that must be included before the report can be presented to the Annual General Meeting of Shareholders (RUPS) and subsequently submitted through the SABH system.
Although the level of detail will vary depending on the size and complexity of the business, companies should ensure that every mandatory component has been properly prepared before commencing the approval process.
Financial Statements
The financial statements form the foundation of the annual report.
Under the applicable regulations, they generally include:
Under the applicable regulations, they generally include:
- Statement of Financial Position (Balance Sheet);
- Income Statement;
- Cash Flow Statement;
- Statement of Changes in Equity;
- Notes to the Financial Statements.
Report on Business Activities
The annual report should provide a clear overview of the company's principal business activities during the financial year.
Depending on the nature of the business, this section may include:
Depending on the nature of the business, this section may include:
- operational highlights;
- major projects completed;
- significant commercial developments;
- investment activities;
- expansion initiatives;
- material events affecting operations.
Corporate Social and Environmental Responsibility (TJSL / CSR)
Where applicable, the annual report should describe the company's implementation of Corporate Social and Environmental Responsibility (TJSL / CSR).
This section is particularly relevant for companies operating in sectors where Indonesian legislation requires social and environmental responsibility programmes.
Typical disclosures may include:
This section is particularly relevant for companies operating in sectors where Indonesian legislation requires social and environmental responsibility programmes.
Typical disclosures may include:
- community initiatives;
- environmental programmes;
- sustainability activities;
- social investment projects;
- other TJSL activities undertaken during the financial year.
Material Business Issues During the Financial Year
The annual report should identify significant issues that affected the company's operations during the reporting period.
Examples may include:
Examples may include:
- regulatory changes;
- operational disruptions;
- major commercial disputes;
- significant business risks;
- restructuring activities;
- other material events influencing company performance.
Supervisory Report of the Board of Commissioners
The Board of Commissioners should provide its report describing the supervisory activities performed during the financial year.
This section demonstrates that management has been independently supervised and forms an important element of Indonesian corporate governance.
The Commissioners' report is reviewed together with the Directors' annual report before shareholder approval.
This section demonstrates that management has been independently supervised and forms an important element of Indonesian corporate governance.
The Commissioners' report is reviewed together with the Directors' annual report before shareholder approval.
Directors and Commissioners
The annual report should identify the members of:
Accurate identification of corporate officers contributes to maintaining reliable corporate records within the Indonesian legal administration system.
- the Board of Directors (Direksi); and
- the Board of Commissioners (Dewan Komisaris)
Accurate identification of corporate officers contributes to maintaining reliable corporate records within the Indonesian legal administration system.
Remuneration of Directors and Commissioners
One aspect of the new reporting framework that has attracted particular attention within the Indonesian business community is the requirement to disclose the remuneration of members of the Board of Directors and the Board of Commissioners as part of the annual report.
Business associations and professional advisers have discussed the practical implications of this requirement, particularly regarding confidentiality and the extent to which financial information submitted through SABH may be accessed by government authorities.
At the time of publication, companies should continue to follow the regulation while monitoring any additional implementing guidance that may clarify practical reporting requirements.
Business associations and professional advisers have discussed the practical implications of this requirement, particularly regarding confidentiality and the extent to which financial information submitted through SABH may be accessed by government authorities.
At the time of publication, companies should continue to follow the regulation while monitoring any additional implementing guidance that may clarify practical reporting requirements.
Practical Compliance Checklist
Before scheduling the Annual RUPS, companies should confirm that the following items have been prepared:
✓ Financial statements completed
✓ Business activity report prepared
✓ TJSL / CSR information included (where applicable)
✓ Material business issues documented
✓ Commissioners' supervisory report completed
✓ Directors and Commissioners identified
✓ Remuneration information prepared in accordance with applicable requirements
✓ Annual report ready for shareholder approval
Preparing these documents in advance helps reduce delays during the approval process and facilitates timely submission through the SABH system.
✓ Financial statements completed
✓ Business activity report prepared
✓ TJSL / CSR information included (where applicable)
✓ Material business issues documented
✓ Commissioners' supervisory report completed
✓ Directors and Commissioners identified
✓ Remuneration information prepared in accordance with applicable requirements
✓ Annual report ready for shareholder approval
Preparing these documents in advance helps reduce delays during the approval process and facilitates timely submission through the SABH system.
Documents Required for SABH Submission
Submitting the annual report through the Legal Entity Administration System (SABH) is the final step in the new compliance process introduced by Permenkum No. 49 of 2025.
Although companies prepare numerous internal documents throughout the annual reporting cycle, the regulation specifies a concise set of supporting documents that must accompany the electronic submission to the Ministry of Law.
Understanding these requirements helps companies avoid incomplete submissions and unnecessary delays.
Although companies prepare numerous internal documents throughout the annual reporting cycle, the regulation specifies a concise set of supporting documents that must accompany the electronic submission to the Ministry of Law.
Understanding these requirements helps companies avoid incomplete submissions and unnecessary delays.
1. Notarial Deed Confirming Approval of the Annual Report
The first mandatory document is the notarial deed recording the shareholders' approval of the annual report.
Following the Annual General Meeting of Shareholders (RUPS), an Indonesian notary prepares a deed reflecting the shareholders' resolution approving the annual report.
Depending on the circumstances, this may take the form of:
Following the Annual General Meeting of Shareholders (RUPS), an Indonesian notary prepares a deed reflecting the shareholders' resolution approving the annual report.
Depending on the circumstances, this may take the form of:
- Minutes of Meeting executed by the notary; or
- A Notarial Deed of Shareholders' Resolution prepared in accordance with Indonesian legal requirements.
2. The Annual Report
The second mandatory document is the Annual Report (Laporan Tahunan) itself.
As discussed in the previous section, the report should contain the information required under Indonesian company legislation, including financial information, business activities, supervisory reports, and other mandatory disclosures.
Companies should ensure that the report presented to shareholders is identical to the version submitted through SABH to maintain consistency within the corporate records.
As discussed in the previous section, the report should contain the information required under Indonesian company legislation, including financial information, business activities, supervisory reports, and other mandatory disclosures.
Companies should ensure that the report presented to shareholders is identical to the version submitted through SABH to maintain consistency within the corporate records.
Submission Through a Notary
Under the current reporting procedure, the submission to the Ministry is carried out electronically through the SABH system by or through the notary, together with the required supporting documents.
For this reason, companies should coordinate with their notary well before the filing deadline to ensure that:
For this reason, companies should coordinate with their notary well before the filing deadline to ensure that:
- the Annual RUPS has been completed;
- the notarial deed has been signed;
- all supporting documentation is complete; and
- the electronic submission can be made within the statutory timeframe.
Common Misunderstanding Among Foreign-Owned Companies
Many foreign business owners assume that preparing the annual financial statements or holding the Annual RUPS automatically completes their annual corporate obligations.
Under Permenkum No. 49 of 2025, this is not the final step.
The reporting process is only completed after the approved annual report has been properly documented in a notarial deed and submitted through the SABH system in accordance with the applicable procedures.
Under Permenkum No. 49 of 2025, this is not the final step.
The reporting process is only completed after the approved annual report has been properly documented in a notarial deed and submitted through the SABH system in accordance with the applicable procedures.
Practical Submission Checklist
Before asking your notary to submit the annual report through SABH, confirm that the following items are ready:
✓ Annual Report completed
✓ Board of Commissioners' review completed
✓ Annual General Meeting (RUPS) held
✓ Shareholders' approval obtained
✓ Notarial deed signed
✓ Supporting documents verified
✓ Submission deadline confirmed
✓ Electronic filing completed through SABH
Completing this checklist before the filing deadline can significantly reduce the risk of administrative delays or rejected submissions.
✓ Annual Report completed
✓ Board of Commissioners' review completed
✓ Annual General Meeting (RUPS) held
✓ Shareholders' approval obtained
✓ Notarial deed signed
✓ Supporting documents verified
✓ Submission deadline confirmed
✓ Electronic filing completed through SABH
Completing this checklist before the filing deadline can significantly reduce the risk of administrative delays or rejected submissions.
Sanctions for Late or Incomplete Submission
The introduction of mandatory annual report filing through the Sistem Administrasi Badan Hukum (SABH) is accompanied by a structured administrative enforcement process.
Rather than imposing immediate penalties, Permenkum No. 49 of 2025 establishes a sequence of corrective measures designed to encourage companies to fulfil their reporting obligations.
For foreign-owned PT PMA companies, understanding these procedures is particularly important because the practical consequences may not become apparent until the company needs to complete another corporate transaction.
Rather than imposing immediate penalties, Permenkum No. 49 of 2025 establishes a sequence of corrective measures designed to encourage companies to fulfil their reporting obligations.
For foreign-owned PT PMA companies, understanding these procedures is particularly important because the practical consequences may not become apparent until the company needs to complete another corporate transaction.
AHU Announces Administrative Sanctions from November 2026
AHU has announced that administrative sanctions for failure to submit the required annual report through SABH will begin to apply from November 2026. Companies with outstanding filings should coordinate with their notary to complete the submission and retain the Ministry’s acknowledgment of receipt.
The announcement concerns the start of enforcement. It should be read together with the warning and access-blocking procedures under Permenkum 49/2025 described below.
The announcement concerns the start of enforcement. It should be read together with the warning and access-blocking procedures under Permenkum 49/2025 described below.
Written Warning
If the annual report is not submitted within the prescribed period, the Ministry may issue a written warning requesting the company to fulfil its reporting obligation.
The warning serves as the first formal notification that the company has failed to comply with the reporting requirements.
Companies should treat such notices seriously and begin correcting the deficiency without unnecessary delay.
The warning serves as the first formal notification that the company has failed to comply with the reporting requirements.
Companies should treat such notices seriously and begin correcting the deficiency without unnecessary delay.
30-Day Correction Period
Following the written warning, the regulation provides the company with an opportunity to remedy the non-compliance.
During this period, management should coordinate with its directors, commissioners, shareholders, accountants, and notary to complete any outstanding corporate procedures and submit the required documents through SABH.
Resolving the issue promptly may help avoid further administrative consequences.
During this period, management should coordinate with its directors, commissioners, shareholders, accountants, and notary to complete any outstanding corporate procedures and submit the required documents through SABH.
Resolving the issue promptly may help avoid further administrative consequences.
Possible Suspension of SABH Access
If the company does not comply after the warning and correction period, Permenkum No. 49 of 2025 provides for administrative measures that may include suspension of access to certain SABH services, in accordance with the regulation.
Although this is an administrative measure rather than a financial penalty, its practical consequences can be significant because many corporate actions are processed through the AHU/SABH system.
Although this is an administrative measure rather than a financial penalty, its practical consequences can be significant because many corporate actions are processed through the AHU/SABH system.
Practical Consequences for PT PMA Companies
For many foreign investors, the most significant risk is not the warning itself but the operational disruption that may follow if access to SABH services is suspended.
Depending on the company's circumstances, this may affect the ability to process corporate administration such as:
Companies should therefore avoid assuming that annual reporting can be postponed until a later date.
Depending on the company's circumstances, this may affect the ability to process corporate administration such as:
- appointment or resignation of directors;
- appointment or resignation of commissioners;
- changes to shareholders;
- amendments to the Articles of Association;
- capital increases or reductions;
- company restructuring;
- other corporate filings requiring AHU registration.
Companies should therefore avoid assuming that annual reporting can be postponed until a later date.
Why Early Compliance Matters
For most PT PMA companies, preparing the annual report several months before the statutory deadline is considerably easier than attempting to resolve compliance issues after receiving an administrative warning.
Early planning allows sufficient time to:
Early planning allows sufficient time to:
- prepare financial statements;
- obtain the Commissioners' review;
- schedule the Annual RUPS;
- coordinate with the notary;
- verify supporting documents;
- complete the SABH submission within the required timeframe.
Practical Tip
Foreign-owned companies often focus on taxation, accounting, and business licensing while overlooking corporate governance obligations.
The annual report filing introduced under Permenkum No. 49 of 2025 should be treated as a separate corporate compliance requirement.
Establishing an internal compliance calendar and coordinating early with your notary and advisers can help ensure that reporting deadlines are met without disrupting future corporate activities.
The annual report filing introduced under Permenkum No. 49 of 2025 should be treated as a separate corporate compliance requirement.
Establishing an internal compliance calendar and coordinating early with your notary and advisers can help ensure that reporting deadlines are met without disrupting future corporate activities.
New AHU Filing Fees and SABH Unblocking Costs Under PP 30/2026
Government Regulation PP No. 30 of 2026 introduced statutory non-tax state revenue tariffs (PNBP) for services administered by Indonesia’s Ministry of Law. The regulation took effect on 1 August 2026 and applies to corporate services processed through AHU and the Legal Entity Administration System (SABH).
Under PP 30/2026, the statutory tariffs for annual-report notifications are:
Annual-report notification for a company subject to mandatory audit — IDR 500,000
Annual-report notification for a company not subject to mandatory audit — IDR 250,000
Under Articles 2–3 of Permenkum 13/2026, a temporary PNBP tariff of IDR 0 applies to notifications of approval of annual reports submitted from 1 August through 31 December 2026. This applies to companies both subject to and exempt from mandatory audit.
The notification must be submitted through the Ministry of Law’s electronic system. No separate application is required to obtain the zero tariff.
The zero-tariff period concerns the government filing fee. It does not extend annual reporting deadlines or suspend administrative enforcement. Companies should therefore not treat 31 December 2026 as a general deadline for completing overdue annual-report filings.
PP 30/2026 also establishes separate government fees for restoring SABH access when a company has been blocked because it failed to comply with the annual-report notification requirement:
Removal of the block for a company subject to mandatory audit — IDR 2,000,000
Removal of the block for a company not subject to mandatory audit — IDR 1,000,000
The zero tariff under Permenkum 13/2026 applies specifically to annual-report approval notifications. It does not waive the separate SABH unblocking fees or cover notarial fees, accounting or audit costs, professional fees, or the preparation of the annual report and supporting corporate documents.
A company that fails to complete its annual-report notification may still face restricted access to SABH services and a separate government charge before the block can be removed. This may affect the company when it later needs to amend its Articles of Association, update shareholders, replace directors or commissioners, or complete another corporate filing through AHU.
PT and PT PMA owners should distinguish between the temporary zero tariff for annual-report approval notifications submitted through 31 December 2026 and the separate government fee for removing an SABH block resulting from non-compliance.
For a broader breakdown of registration, corporate amendment, annual-report, unblocking and dissolution charges, see our guide to Indonesia’s new AHU company fees under PP 30/2026.
Under PP 30/2026, the statutory tariffs for annual-report notifications are:
Annual-report notification for a company subject to mandatory audit — IDR 500,000
Annual-report notification for a company not subject to mandatory audit — IDR 250,000
Under Articles 2–3 of Permenkum 13/2026, a temporary PNBP tariff of IDR 0 applies to notifications of approval of annual reports submitted from 1 August through 31 December 2026. This applies to companies both subject to and exempt from mandatory audit.
The notification must be submitted through the Ministry of Law’s electronic system. No separate application is required to obtain the zero tariff.
The zero-tariff period concerns the government filing fee. It does not extend annual reporting deadlines or suspend administrative enforcement. Companies should therefore not treat 31 December 2026 as a general deadline for completing overdue annual-report filings.
PP 30/2026 also establishes separate government fees for restoring SABH access when a company has been blocked because it failed to comply with the annual-report notification requirement:
Removal of the block for a company subject to mandatory audit — IDR 2,000,000
Removal of the block for a company not subject to mandatory audit — IDR 1,000,000
The zero tariff under Permenkum 13/2026 applies specifically to annual-report approval notifications. It does not waive the separate SABH unblocking fees or cover notarial fees, accounting or audit costs, professional fees, or the preparation of the annual report and supporting corporate documents.
A company that fails to complete its annual-report notification may still face restricted access to SABH services and a separate government charge before the block can be removed. This may affect the company when it later needs to amend its Articles of Association, update shareholders, replace directors or commissioners, or complete another corporate filing through AHU.
PT and PT PMA owners should distinguish between the temporary zero tariff for annual-report approval notifications submitted through 31 December 2026 and the separate government fee for removing an SABH block resulting from non-compliance.
For a broader breakdown of registration, corporate amendment, annual-report, unblocking and dissolution charges, see our guide to Indonesia’s new AHU company fees under PP 30/2026.
September 2026 Update: Check Your Company’s AHU Status and Corporate Records
In September 2026, AHU’s provisional inactive-corporation register displayed approximately 705,000 entries in its limited liability company section. This is a changing administrative list, so a company’s current position should be checked directly in the register.
Separately, AHU reported in April 2026 that approximately 823,000 of Indonesia’s 3.5 million registered legal entities had not reported their beneficial owners. That figure describes beneficial ownership reporting at an earlier date. It should not be added to the provisional inactive-list total, because the categories may overlap and measure different compliance issues.
For PT PMA owners, these figures reinforce the importance of checking corporate records before planning a change of directors, commissioners, shareholders or Articles of Association.
A practical review should cover:
The provisional inactive list, beneficial ownership compliance and annual-report compliance should be checked separately. Inclusion in the provisional list alone should not be treated as proof that a company has failed to file its annual report.
If a company appears in the register or encounters restricted access, its directors should ask the notary or relevant adviser to confirm the specific reason and the steps required to update the records.
Separately, AHU reported in April 2026 that approximately 823,000 of Indonesia’s 3.5 million registered legal entities had not reported their beneficial owners. That figure describes beneficial ownership reporting at an earlier date. It should not be added to the provisional inactive-list total, because the categories may overlap and measure different compliance issues.
For PT PMA owners, these figures reinforce the importance of checking corporate records before planning a change of directors, commissioners, shareholders or Articles of Association.
A practical review should cover:
- whether the company appears in AHU’s provisional inactive register;
- whether beneficial ownership information has been submitted and remains accurate;
- whether the required annual-report approval and SABH notification have been completed;
- whether registered company data matches the latest deeds and corporate resolutions; and
- whether any warning or restriction requires action before the next corporate filing.
The provisional inactive list, beneficial ownership compliance and annual-report compliance should be checked separately. Inclusion in the provisional list alone should not be treated as proof that a company has failed to file its annual report.
If a company appears in the register or encounters restricted access, its directors should ask the notary or relevant adviser to confirm the specific reason and the steps required to update the records.
Why Foreign-Owned Companies Should Pay Attention
Foreign-owned companies (PT PMA) often maintain a high level of compliance in areas such as taxation, accounting, business licensing, and immigration.
However, many foreign directors and shareholders are less familiar with Indonesia's corporate governance procedures, particularly those involving shareholder meetings, notarial documentation, and filings with the Ministry of Law.
As a result, the new annual reporting requirements introduced under Permenkum No. 49 of 2025 may come as an unexpected obligation, especially for companies that have operated for several years under different administrative practices.
Unlike annual tax reporting, which is typically handled by accountants or tax consultants, the SABH annual report is fundamentally a corporate governance obligation that requires coordination between management, shareholders, commissioners, and an Indonesian notary.
However, many foreign directors and shareholders are less familiar with Indonesia's corporate governance procedures, particularly those involving shareholder meetings, notarial documentation, and filings with the Ministry of Law.
As a result, the new annual reporting requirements introduced under Permenkum No. 49 of 2025 may come as an unexpected obligation, especially for companies that have operated for several years under different administrative practices.
Unlike annual tax reporting, which is typically handled by accountants or tax consultants, the SABH annual report is fundamentally a corporate governance obligation that requires coordination between management, shareholders, commissioners, and an Indonesian notary.
Annual Tax Reporting Is Not the Same as Corporate Reporting
One of the most common misunderstandings among foreign business owners is the assumption that once annual taxes have been filed and financial statements have been prepared, the company's annual compliance obligations have been completed.
Under the current framework, this is not the case.
A PT PMA may fully comply with its tax obligations while still failing to complete its corporate reporting obligations under the Ministry of Law if the annual report is not approved by the shareholders and submitted through the SABH system.
These are separate compliance processes administered by different government authorities.
Under the current framework, this is not the case.
A PT PMA may fully comply with its tax obligations while still failing to complete its corporate reporting obligations under the Ministry of Law if the annual report is not approved by the shareholders and submitted through the SABH system.
These are separate compliance processes administered by different government authorities.
Corporate Administration Often Becomes Relevant at the Worst Possible Time
Many companies only discover an outstanding compliance issue when they need to make an urgent corporate change.
Examples include:
Companies planning to cease operations should resolve outstanding corporate filings before beginning the formal PT PMA closure process.
Examples include:
- appointing a new director;
- adding or removing shareholders;
- increasing investment capital;
- amending the Articles of Association;
- restructuring the company;
- preparing for an acquisition or investment round.
Companies planning to cease operations should resolve outstanding corporate filings before beginning the formal PT PMA closure process.
Foreign Shareholders Often Rely on Local Service Providers
Many PT PMA companies engage accountants, tax consultants, payroll providers, company secretaries, and notaries.
While this approach is entirely normal, responsibility for corporate compliance should not be assumed to rest automatically with any single adviser.
Different advisers typically manage different aspects of the business:
Directors should therefore confirm who is responsible for each stage of the reporting process rather than assuming that another adviser is managing it.
While this approach is entirely normal, responsibility for corporate compliance should not be assumed to rest automatically with any single adviser.
Different advisers typically manage different aspects of the business:
- accountants focus on financial reporting;
- tax consultants manage taxation;
- notaries prepare corporate deeds;
- OSS consultants handle licensing;
- immigration advisers manage visas.
Directors should therefore confirm who is responsible for each stage of the reporting process rather than assuming that another adviser is managing it.
Early Planning Reduces Administrative Risk
Companies that prepare their annual reporting calendar well before the statutory deadlines generally experience a smoother compliance process.
Early planning provides sufficient time to:
Early planning provides sufficient time to:
- prepare financial statements;
- organise the Commissioners' review;
- schedule the Annual RUPS;
- prepare the notarial deed;
- verify supporting documents;
- complete the SABH filing within the required timeframe.
Good Corporate Governance Supports Long-Term Investment
For foreign investors, compliance should be viewed as more than a legal obligation.
Maintaining complete and accurate corporate records demonstrates sound governance, supports transparent decision-making, and strengthens confidence among shareholders, financial institutions, business partners, and prospective investors.
As Indonesia continues to modernise its corporate administration systems, companies that maintain orderly documentation and comply with reporting obligations are generally better positioned to respond efficiently to future regulatory or commercial requirements.
Practical Recommendation
Foreign-owned PT PMA companies should treat the annual report as part of their broader corporate governance framework rather than as a standalone filing.
Establishing an annual compliance calendar, clearly assigning responsibilities among directors and advisers, and reviewing documentation well before the statutory deadlines can significantly reduce administrative risk and help ensure that future corporate actions proceed without interruption.
Maintaining complete and accurate corporate records demonstrates sound governance, supports transparent decision-making, and strengthens confidence among shareholders, financial institutions, business partners, and prospective investors.
As Indonesia continues to modernise its corporate administration systems, companies that maintain orderly documentation and comply with reporting obligations are generally better positioned to respond efficiently to future regulatory or commercial requirements.
Practical Recommendation
Foreign-owned PT PMA companies should treat the annual report as part of their broader corporate governance framework rather than as a standalone filing.
Establishing an annual compliance calendar, clearly assigning responsibilities among directors and advisers, and reviewing documentation well before the statutory deadlines can significantly reduce administrative risk and help ensure that future corporate actions proceed without interruption.
Data Confidentiality and Business Concerns
The introduction of mandatory annual report submission through the SABH system has prompted discussion among Indonesian businesses, professional associations, and legal practitioners regarding the scope of information that companies are required to submit to the Ministry of Law.
While many organisations recognise the government's objective of improving corporate governance and maintaining accurate legal entity records, questions have also been raised regarding data confidentiality, administrative burden, and the practical implementation of the new reporting requirements.
For foreign-owned PT PMA companies, understanding these discussions can help management prepare appropriate internal procedures while continuing to comply with the applicable regulations.
While many organisations recognise the government's objective of improving corporate governance and maintaining accurate legal entity records, questions have also been raised regarding data confidentiality, administrative burden, and the practical implementation of the new reporting requirements.
For foreign-owned PT PMA companies, understanding these discussions can help management prepare appropriate internal procedures while continuing to comply with the applicable regulations.
Disclosure of Directors' and Commissioners' Remuneration
One of the most widely discussed aspects of Permenkum No. 49 of 2025 is the requirement for the annual report to include information relating to the remuneration of members of the Board of Directors and the Board of Commissioners.
Some businesses have expressed concern that this information is commercially sensitive and should be handled with an appropriate level of confidentiality.
At the time of publication, companies should continue to prepare their annual reports in accordance with the regulation while monitoring any future implementing guidance that may further clarify reporting procedures or data handling practices.
Some businesses have expressed concern that this information is commercially sensitive and should be handled with an appropriate level of confidentiality.
At the time of publication, companies should continue to prepare their annual reports in accordance with the regulation while monitoring any future implementing guidance that may further clarify reporting procedures or data handling practices.
Administrative Burden for Smaller Companies
Another topic raised by business organisations is the additional administrative work required to complete the annual reporting process.
For companies with limited internal resources, coordinating financial statements, supervisory reviews, shareholder meetings, notarial documentation, and electronic submission may require careful planning.
Although these requirements may increase administrative effort, establishing a structured annual compliance calendar can help reduce the workload in future reporting cycles.
For companies with limited internal resources, coordinating financial statements, supervisory reviews, shareholder meetings, notarial documentation, and electronic submission may require careful planning.
Although these requirements may increase administrative effort, establishing a structured annual compliance calendar can help reduce the workload in future reporting cycles.
Data Security and Government Systems
Some commentators have also discussed the importance of protecting corporate information submitted through electronic government systems.
As with many digital regulatory platforms, businesses expect that confidential corporate data will be managed in accordance with applicable legal and administrative safeguards.
Companies submitting annual reports through SABH should use the official AHU platform, maintain accurate internal records, and retain copies of all submitted documents together with the Ministry's electronic acknowledgement of receipt.
As with many digital regulatory platforms, businesses expect that confidential corporate data will be managed in accordance with applicable legal and administrative safeguards.
Companies submitting annual reports through SABH should use the official AHU platform, maintain accurate internal records, and retain copies of all submitted documents together with the Ministry's electronic acknowledgement of receipt.
Balancing Transparency and Commercial Confidentiality
Corporate reporting always involves balancing regulatory transparency with the protection of commercially sensitive information.
Indonesia's revised reporting framework reflects a broader trend toward strengthening corporate governance and maintaining more complete legal entity records.
For businesses, the most practical approach is to ensure that reporting is accurate, complete, and submitted through the prescribed procedures while maintaining appropriate internal controls over corporate documentation.
Practical Perspective for PT PMA Owners
Rather than viewing the new reporting requirements solely as an administrative obligation, foreign-owned companies may benefit from using the annual reporting process as an opportunity to review their overall corporate governance.
An annual review can help management confirm that:
A well-maintained corporate record not only supports regulatory compliance but also simplifies future activities such as investment, financing, restructuring, due diligence, and changes to the company's legal structure.
Editorial Note
The implementation of Permenkum No. 49 of 2025 continues to evolve as companies, notaries, and government authorities gain practical experience with the new reporting procedures.
Businesses should therefore monitor official announcements issued by the Ministry of Law and verify whether additional technical guidance or implementing regulations become available after publication of this article.
Indonesia's revised reporting framework reflects a broader trend toward strengthening corporate governance and maintaining more complete legal entity records.
For businesses, the most practical approach is to ensure that reporting is accurate, complete, and submitted through the prescribed procedures while maintaining appropriate internal controls over corporate documentation.
Practical Perspective for PT PMA Owners
Rather than viewing the new reporting requirements solely as an administrative obligation, foreign-owned companies may benefit from using the annual reporting process as an opportunity to review their overall corporate governance.
An annual review can help management confirm that:
- corporate records remain up to date;
- shareholder resolutions have been properly documented;
- directors' and commissioners' appointments are accurately recorded;
- statutory filings have been completed;
- company documentation is organised for future corporate transactions.
A well-maintained corporate record not only supports regulatory compliance but also simplifies future activities such as investment, financing, restructuring, due diligence, and changes to the company's legal structure.
Editorial Note
The implementation of Permenkum No. 49 of 2025 continues to evolve as companies, notaries, and government authorities gain practical experience with the new reporting procedures.
Businesses should therefore monitor official announcements issued by the Ministry of Law and verify whether additional technical guidance or implementing regulations become available after publication of this article.
Common Mistakes Companies Should Avoid
Although the annual reporting framework introduced by Permenkum No. 49 of 2025 is based on a structured sequence of corporate actions, many compliance issues arise not because companies intentionally disregard their obligations, but because they misunderstand the process or assume that other annual filings satisfy the new requirements.
The following are some of the most common mistakes that foreign-owned PT PMA companies should seek to avoid.
The following are some of the most common mistakes that foreign-owned PT PMA companies should seek to avoid.
Assuming Tax Reporting Is Sufficient
One of the most frequent misunderstandings is the belief that submitting the company's annual tax return and financial statements automatically fulfils all annual compliance obligations.
Corporate annual reporting through SABH is separate from taxation and accounting.
Even companies that are fully tax compliant may still have outstanding corporate reporting obligations if the annual report has not been approved through the Annual General Meeting (RUPS) and submitted in accordance with Permenkum No. 49 of 2025.
Corporate annual reporting through SABH is separate from taxation and accounting.
Even companies that are fully tax compliant may still have outstanding corporate reporting obligations if the annual report has not been approved through the Annual General Meeting (RUPS) and submitted in accordance with Permenkum No. 49 of 2025.
Failing to Hold the Annual General Meeting (RUPS)
Some companies prepare financial statements but delay or overlook the Annual General Meeting of Shareholders.
Without formal shareholder approval, the annual reporting process cannot be completed properly.
Companies should schedule the Annual RUPS well before the statutory deadline to allow sufficient time for the remaining compliance steps.
Without formal shareholder approval, the annual reporting process cannot be completed properly.
Companies should schedule the Annual RUPS well before the statutory deadline to allow sufficient time for the remaining compliance steps.
Submitting Incomplete Annual Reports
An annual report should include all information required by Indonesian company legislation and the applicable regulations.
Missing financial information, incomplete business activity reports, omitted supervisory reports, or absent mandatory disclosures may delay the reporting process or require additional corrections before submission.
Preparing the report using a structured checklist helps reduce these risks.
Missing financial information, incomplete business activity reports, omitted supervisory reports, or absent mandatory disclosures may delay the reporting process or require additional corrections before submission.
Preparing the report using a structured checklist helps reduce these risks.
Delaying the Notarial Deed
Some companies complete the Annual RUPS but postpone preparing the notarial deed.
Because the deed forms part of the reporting process, unnecessary delays at this stage may leave insufficient time to complete the SABH submission before the statutory deadline.
Early coordination with the notary is therefore advisable.
Because the deed forms part of the reporting process, unnecessary delays at this stage may leave insufficient time to complete the SABH submission before the statutory deadline.
Early coordination with the notary is therefore advisable.
Ignoring the Board of Commissioners' Review
The supervisory review performed by the Board of Commissioners is an important component of Indonesia's corporate governance framework.
Companies should ensure that this review is completed before the annual report is presented to shareholders.
Treating the Commissioners' review as a formality rather than a required governance step may create unnecessary compliance issues.
Companies should ensure that this review is completed before the annual report is presented to shareholders.
Treating the Commissioners' review as a formality rather than a required governance step may create unnecessary compliance issues.
Waiting Until a Corporate Change Is Needed
Many companies only discover outstanding reporting obligations when they need to register another corporate action through the AHU system.
Examples include:
Addressing annual reporting obligations proactively helps avoid unexpected delays when these transactions become time-sensitive.
If the planned corporate action changes or expands the company’s business scope, its KBLI 2025 classifications should also be reviewed across the Articles of Association, AHU and OSS before proceeding.
Examples include:
- appointing a new director;
- changing shareholders;
- increasing authorised capital;
- amending the Articles of Association;
- restructuring the company.
Addressing annual reporting obligations proactively helps avoid unexpected delays when these transactions become time-sensitive.
If the planned corporate action changes or expands the company’s business scope, its KBLI 2025 classifications should also be reviewed across the Articles of Association, AHU and OSS before proceeding.
Assuming Someone Else Is Responsible
Foreign-owned companies often work with accountants, tax advisers, payroll providers, company secretaries, notaries, and licensing consultants.
Because responsibilities are divided among several advisers, directors should not assume that one professional is automatically managing the entire annual reporting process.
Establishing clear internal responsibility for each stage—from preparing the annual report through to the final SABH submission—helps prevent important compliance steps from being overlooked.
Practical Takeaway
Most reporting problems can be avoided through early planning, clear allocation of responsibilities, and timely coordination between directors, commissioners, shareholders, accountants, and the notary.
The annual report should be viewed as a structured corporate governance process rather than as a single administrative filing.
Because responsibilities are divided among several advisers, directors should not assume that one professional is automatically managing the entire annual reporting process.
Establishing clear internal responsibility for each stage—from preparing the annual report through to the final SABH submission—helps prevent important compliance steps from being overlooked.
Practical Takeaway
Most reporting problems can be avoided through early planning, clear allocation of responsibilities, and timely coordination between directors, commissioners, shareholders, accountants, and the notary.
The annual report should be viewed as a structured corporate governance process rather than as a single administrative filing.
Practical Compliance Checklist for PT PMA Owners
The introduction of mandatory annual report filing under Permenkum No. 49 of 2025 provides companies with an opportunity to establish a structured annual corporate compliance process rather than approaching each reporting cycle on an ad hoc basis.
The following checklist summarises the principal steps that foreign-owned PT PMA companies should consider completing each year. Depending on the company's structure, business activities, and financial year, additional requirements may also apply.
The following checklist summarises the principal steps that foreign-owned PT PMA companies should consider completing each year. Depending on the company's structure, business activities, and financial year, additional requirements may also apply.
1. Confirm the Company's Financial Year
Verify the company's financial year as stated in its Articles of Association and ensure that management, accountants, and shareholders are working towards the correct reporting timetable.
For many PT PMA companies, the financial year ends on 31 December, but this should always be confirmed against the company's corporate documents
For many PT PMA companies, the financial year ends on 31 December, but this should always be confirmed against the company's corporate documents
2. Prepare the Annual Report
Ensure that the Board of Directors prepares a complete annual report containing all information required under Indonesian company legislation and Permenkum No. 49 of 2025.
The report should be internally reviewed before being presented to the Board of Commissioners.
The report should be internally reviewed before being presented to the Board of Commissioners.
3. Obtain the Commissioners' Review
The Board of Commissioners should complete its supervisory review before the annual report is submitted to shareholders.
This step forms part of the company's corporate governance process and should not be overlooked.
This step forms part of the company's corporate governance process and should not be overlooked.
4. Hold the Annual General Meeting (RUPS)
Schedule the Annual General Meeting of Shareholders within the statutory timeframe.
During the meeting, shareholders should formally approve the annual report and adopt the necessary corporate resolutions.
During the meeting, shareholders should formally approve the annual report and adopt the necessary corporate resolutions.
5. Coordinate With Your Notary
Following shareholder approval, arrange for the preparation and execution of the notarial deed documenting the Annual RUPS resolutions.
Providing the notary with complete documentation in advance may help avoid unnecessary delays.
Providing the notary with complete documentation in advance may help avoid unnecessary delays.
6. Verify Supporting Documents
Before the SABH submission is made, confirm that:
- the annual report is complete;
- supporting financial information has been finalised;
- corporate resolutions have been properly documented;
- all required signatures have been obtained.
7. Complete the SABH Submission on Time
Ensure that the annual report is submitted through the SABH system within the applicable statutory deadline after the notarial deed has been executed.
Retain copies of:
Retain copies of:
- the submitted documents;
- the electronic acknowledgement issued through the AHU system;
- the notarial deed; and
- the approved annual report.
8. Establish an Annual Compliance Calendar
Rather than treating annual reporting as an isolated administrative task, companies should establish a recurring compliance calendar covering:
Annual Compliance Checklist
Before considering the reporting process complete, confirm that the following items have been addressed:
✓ Financial year confirmed
✓ Annual report prepared
✓ Financial statements completed
✓ Commissioners' review completed
✓ Annual RUPS held
✓ Shareholder approval obtained
✓ Notarial deed executed
✓ Supporting documents verified
✓ SABH submission completed
✓ Electronic acknowledgement retained
✓ Corporate records updated
Practical Recommendation
For many foreign-owned PT PMA companies, the annual reporting obligation is likely to become part of a broader corporate governance cycle. Assigning clear responsibility, maintaining accurate records throughout the year, and coordinating early with accountants and notaries can substantially reduce compliance risk while making future corporate actions more efficient.
- annual tax reporting;
- corporate annual reporting;
- business licence renewals;
- OSS compliance;
- shareholder meetings;
- corporate record updates.
Annual Compliance Checklist
Before considering the reporting process complete, confirm that the following items have been addressed:
✓ Financial year confirmed
✓ Annual report prepared
✓ Financial statements completed
✓ Commissioners' review completed
✓ Annual RUPS held
✓ Shareholder approval obtained
✓ Notarial deed executed
✓ Supporting documents verified
✓ SABH submission completed
✓ Electronic acknowledgement retained
✓ Corporate records updated
Practical Recommendation
For many foreign-owned PT PMA companies, the annual reporting obligation is likely to become part of a broader corporate governance cycle. Assigning clear responsibility, maintaining accurate records throughout the year, and coordinating early with accountants and notaries can substantially reduce compliance risk while making future corporate actions more efficient.
Frequently Asked Questions
Is the SABH Annual Report Notification Free Until 31 December 2026?
Yes. Under Articles 2–3 of Permenkum 13/2026, a government filing tariff of IDR 0 applies to annual-report approval notifications submitted from 1 August through 31 December 2026. It covers companies both subject to and exempt from mandatory audit, without a separate application for the zero tariff.
This covers only the government notification fee. It does not cover notarial, accounting, audit or professional fees, or separate SABH unblocking charges. It also does not extend reporting deadlines or postpone AHU’s announced start of administrative sanctions in November 2026.
This covers only the government notification fee. It does not cover notarial, accounting, audit or professional fees, or separate SABH unblocking charges. It also does not extend reporting deadlines or postpone AHU’s announced start of administrative sanctions in November 2026.
Does every PT PMA need to submit an annual report through SABH?
In general, PT and PT PMA companies that fall within the scope of Permenkum No. 49 of 2025 should comply with the annual reporting requirements introduced by the regulation.
The precise reporting obligations may depend on the company's legal status, financial year, and other applicable corporate regulations. Companies should therefore verify their individual compliance requirements with their notary or corporate adviser.
The precise reporting obligations may depend on the company's legal status, financial year, and other applicable corporate regulations. Companies should therefore verify their individual compliance requirements with their notary or corporate adviser.
Is tax reporting the same as the SABH annual report?
No.
Annual tax reporting and annual corporate reporting serve different purposes and are administered by different government authorities.
Tax reporting concerns the company's tax obligations, while the SABH annual report relates to corporate governance, shareholder approval, and maintaining accurate legal entity records with the Ministry of Law.
Completing one process does not automatically satisfy the other.
Annual tax reporting and annual corporate reporting serve different purposes and are administered by different government authorities.
Tax reporting concerns the company's tax obligations, while the SABH annual report relates to corporate governance, shareholder approval, and maintaining accurate legal entity records with the Ministry of Law.
Completing one process does not automatically satisfy the other.
What happens if a company misses the reporting deadline?
AHU has announced that administrative sanctions for failure to submit the required annual report through SABH will begin to apply from November 2026.
Under Permenkum 49/2025, the enforcement process includes a written warning and an opportunity to remedy the non-compliance, followed by blocking of SABH access if the company fails to comply within the prescribed correction period. The November announcement should not be interpreted as automatic blocking of every company on the first day of that month.
Companies with outstanding filings should coordinate with their notary, check any SABH notifications or warning emails, and retain the Ministry’s acknowledgment after completing the submission.
Under Permenkum 49/2025, the enforcement process includes a written warning and an opportunity to remedy the non-compliance, followed by blocking of SABH access if the company fails to comply within the prescribed correction period. The November announcement should not be interpreted as automatic blocking of every company on the first day of that month.
Companies with outstanding filings should coordinate with their notary, check any SABH notifications or warning emails, and retain the Ministry’s acknowledgment after completing the submission.
Can SABH access really be suspended?
The regulation provides for administrative measures that may include suspension of access to certain SABH services if a company fails to fulfil its annual reporting obligations after the applicable warning and correction procedures.
Because many corporate filings are processed through SABH, companies should avoid allowing annual reporting obligations to remain outstanding.
Because many corporate filings are processed through SABH, companies should avoid allowing annual reporting obligations to remain outstanding.
Who is responsible for the accuracy of the annual report?
The Board of Directors (Direksi) is primarily responsible for preparing the annual report.
The Board of Commissioners performs its supervisory review, the shareholders approve the report through the Annual General Meeting (RUPS), and the reporting process is subsequently formalised through notarial documentation and submission to SABH.
The Board of Commissioners performs its supervisory review, the shareholders approve the report through the Annual General Meeting (RUPS), and the reporting process is subsequently formalised through notarial documentation and submission to SABH.
Does the annual report need to include directors' remuneration?
Permenkum No. 49 of 2025 introduces disclosure requirements that include information relating to the remuneration of members of the Board of Directors and the Board of Commissioners.
As implementation of the regulation continues to develop, companies should monitor any additional technical guidance issued by the Ministry and ensure that their reporting remains consistent with the applicable requirements.
As implementation of the regulation continues to develop, companies should monitor any additional technical guidance issued by the Ministry and ensure that their reporting remains consistent with the applicable requirements.
Should small companies prepare the same report as large companies?
The annual report should always comply with the applicable legal requirements.
However, the complexity and level of detail may vary depending on the company's activities, governance structure, and whether additional statutory obligations—such as audited financial statements or CSR reporting—apply.
However, the complexity and level of detail may vary depending on the company's activities, governance structure, and whether additional statutory obligations—such as audited financial statements or CSR reporting—apply.
Can a notary prepare the entire annual report?
No.
The annual report is prepared by the company's management.
The notary's role is to document the shareholders' resolutions in a notarial deed and facilitate the subsequent filing process through the SABH system.
Preparing the report itself remains the responsibility of the company.
The annual report is prepared by the company's management.
The notary's role is to document the shareholders' resolutions in a notarial deed and facilitate the subsequent filing process through the SABH system.
Preparing the report itself remains the responsibility of the company.
What should foreign directors do now?
Foreign directors should begin by reviewing whether their company already has an annual corporate compliance process in place.
If not, it is advisable to establish an annual compliance calendar, coordinate early with accountants, commissioners, shareholders, and the company's notary, and ensure that each stage of the reporting process is completed before the statutory deadlines.
A proactive approach can help reduce administrative risk and minimise disruption to future corporate transactions.
If not, it is advisable to establish an annual compliance calendar, coordinate early with accountants, commissioners, shareholders, and the company's notary, and ensure that each stage of the reporting process is completed before the statutory deadlines.
A proactive approach can help reduce administrative risk and minimise disruption to future corporate transactions.
Official References
The regulatory framework governing annual report filing for PT and PT PMA companies continues to evolve. Companies should always rely on official government publications and monitor new implementation guidance issued by the Ministry of Law.
The following sources provide authoritative legal texts and practical commentary that may assist companies in understanding the new reporting requirements.
Official Indonesian Government Sources
Ministry of Law – AHU Document Repository
Official repository containing Minister of Law Regulation No. 49 of 2025 and other legal documents published by the Directorate General of General Legal Administration (AHU).
https://portal.ahu.go.id/unduh
Directorate General of General Legal Administration (AHU)
Official AHU portal providing information on legal entity administration, corporate services, and government announcements.
https://ahu.go.id/
Official Regulation
Minister of Law Regulation No. 49 of 2025
Requirements and Procedures for the Establishment, Amendment, and Dissolution of Limited Liability Companies.
This regulation introduced the mandatory annual report submission procedure through SABH and replaced Permenkumham No. 21 of 2021
Minister of Law Regulation No. 13 of 2026
Articles 2–3 establish a temporary zero PNBP tariff for annual-report approval notifications submitted from 1 August through 31 December 2026, covering companies both subject to and exempt from mandatory audit.
Government Implementation Updates
Directorate General of AHU – Announcement on Administrative Sanctions from November 2026
Official communication announcing that administrative sanctions for failure to submit annual reports through SABH will begin to apply from November 2026. This announcement should be read alongside the enforcement procedures in Permenkum 49/2025.
Professional Regulatory Commentary
The following publications provide practical explanations of the regulation from professional advisers and may be useful for companies seeking a deeper understanding of the implementation process:
Important Note
This article is intended to provide practical guidance for foreign-owned PT PMA companies based on publicly available information at the time of publication.
Because implementation of Permenkum No. 49 of 2025 continues to develop, companies should verify whether additional circular letters, technical guidance, or administrative instructions have been issued after publication and consider obtaining professional assistance where their corporate structure or reporting obligations require individual assessment.
The following sources provide authoritative legal texts and practical commentary that may assist companies in understanding the new reporting requirements.
Official Indonesian Government Sources
Ministry of Law – AHU Document Repository
Official repository containing Minister of Law Regulation No. 49 of 2025 and other legal documents published by the Directorate General of General Legal Administration (AHU).
https://portal.ahu.go.id/unduh
Directorate General of General Legal Administration (AHU)
Official AHU portal providing information on legal entity administration, corporate services, and government announcements.
https://ahu.go.id/
Official Regulation
Minister of Law Regulation No. 49 of 2025
Requirements and Procedures for the Establishment, Amendment, and Dissolution of Limited Liability Companies.
This regulation introduced the mandatory annual report submission procedure through SABH and replaced Permenkumham No. 21 of 2021
Minister of Law Regulation No. 13 of 2026
Articles 2–3 establish a temporary zero PNBP tariff for annual-report approval notifications submitted from 1 August through 31 December 2026, covering companies both subject to and exempt from mandatory audit.
Government Implementation Updates
Directorate General of AHU – Announcement on Administrative Sanctions from November 2026
Official communication announcing that administrative sanctions for failure to submit annual reports through SABH will begin to apply from November 2026. This announcement should be read alongside the enforcement procedures in Permenkum 49/2025.
Professional Regulatory Commentary
The following publications provide practical explanations of the regulation from professional advisers and may be useful for companies seeking a deeper understanding of the implementation process:
- EY Indonesia – New Requirements for Submitting Limited Liability Company Annual Reports to the Ministry of Law.
- Yang & Co. – Introduction to Minister of Law Regulation No. 49 of 2025.
- KSP Law – Annual Report Submission Through SABH Under Permenkum No. 49 of 2025.
Important Note
This article is intended to provide practical guidance for foreign-owned PT PMA companies based on publicly available information at the time of publication.
Because implementation of Permenkum No. 49 of 2025 continues to develop, companies should verify whether additional circular letters, technical guidance, or administrative instructions have been issued after publication and consider obtaining professional assistance where their corporate structure or reporting obligations require individual assessment.
Why Keeping AHU Corporate Data Updated Also Matters
Annual reporting is only one part of ongoing corporate compliance.
PT and PT PMA companies should also ensure that their corporate data in AHU remains current and that Beneficial Ownership information has been properly reported.
Annual-report filing and Beneficial Ownership reporting are separate compliance requirements. Completing one does not replace the other.
Under Articles 22–25 of Minister of Law Regulation No. 2 of 2025, failure to report a beneficial owner or submission of incorrect information may result in administrative sanctions, including warnings, blacklisting and blocking of AHU Online access. Sanctions are generally imposed progressively, although the regulation allows direct administrative sanctions in certain circumstances.
Removal of a BO-related restriction requires the company to fulfil its reporting obligations and/or provide correct information. Payment of an applicable unblocking fee alone should not be treated as a substitute for correcting the underlying compliance issue.
Companies that leave corporate records unchanged for extended periods may face administrative restrictions or inactive status in the AHU system. This does not mean that the company has been legally dissolved, but it can create additional compliance steps before future corporate changes or closure can be completed.
AHU now maintains a public temporary inactive-corporation list that PT and PT PMA owners can search using the company’s exact registered name. The results may show the registered location, the latest corporate transaction recorded as Transaksi Terakhir and the company’s Beneficial Ownership reporting status.
The BO field is a separate compliance indicator. Because the list includes companies marked both SUDAH LAPORAN and BELUM LAPORAN, a company’s appearance in the list should not automatically be attributed only to an outstanding Beneficial Ownership report. Its complete AHU record and the corrective action required should be verified with the company’s notary or corporate adviser.
Companies planning to suspend operations or close a PT PMA should therefore review their AHU and Beneficial Ownership status rather than assuming that inactivity alone ends their corporate obligations.
PT and PT PMA companies should also ensure that their corporate data in AHU remains current and that Beneficial Ownership information has been properly reported.
Annual-report filing and Beneficial Ownership reporting are separate compliance requirements. Completing one does not replace the other.
Under Articles 22–25 of Minister of Law Regulation No. 2 of 2025, failure to report a beneficial owner or submission of incorrect information may result in administrative sanctions, including warnings, blacklisting and blocking of AHU Online access. Sanctions are generally imposed progressively, although the regulation allows direct administrative sanctions in certain circumstances.
Removal of a BO-related restriction requires the company to fulfil its reporting obligations and/or provide correct information. Payment of an applicable unblocking fee alone should not be treated as a substitute for correcting the underlying compliance issue.
Companies that leave corporate records unchanged for extended periods may face administrative restrictions or inactive status in the AHU system. This does not mean that the company has been legally dissolved, but it can create additional compliance steps before future corporate changes or closure can be completed.
AHU now maintains a public temporary inactive-corporation list that PT and PT PMA owners can search using the company’s exact registered name. The results may show the registered location, the latest corporate transaction recorded as Transaksi Terakhir and the company’s Beneficial Ownership reporting status.
The BO field is a separate compliance indicator. Because the list includes companies marked both SUDAH LAPORAN and BELUM LAPORAN, a company’s appearance in the list should not automatically be attributed only to an outstanding Beneficial Ownership report. Its complete AHU record and the corrective action required should be verified with the company’s notary or corporate adviser.
Companies planning to suspend operations or close a PT PMA should therefore review their AHU and Beneficial Ownership status rather than assuming that inactivity alone ends their corporate obligations.
Related Insights
Understanding Indonesia's corporate reporting requirements is only one part of maintaining a compliant and well-structured business. Foreign investors should also review their contracts, property transactions, and broader business operations to reduce legal and operational risks.
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