Part of the series: The Reporting Year
- PT PMA Reporting Obligations: The Indonesian Company Reporting Year Mapped
- Why a PT PMA Carries the Large Enterprise Classification
- Why a PT PMA Pays the Same Corporate Income Tax as a Local Company
- The Investment Activity Report, and Why it Exists
- A Financial Reporting System that Survives Deadline Season
The Reporting Year · TraceWorthy Financial Services
When a foreign investor sets up a foreign investment limited liability company (Perseroan Terbatas Penanaman Modal Asing, or PT PMA), it makes a commitment to invest a set amount. The investment activity report is the quarterly filing through which Indonesia checks that the commitment is being carried out.
A PT PMA’s investment plan is a multi-year commitment recorded in the licensing system at incorporation. For a foreign-owned company, the plan begins at above IDR 10,000,000,000 (ten billion Indonesian Rupiah) per Indonesian Standard Industrial Classification (Klasifikasi Baku Lapangan Usaha Indonesia, or KBLI) at the five-digit level per project location, excluding land and buildings. The Investment Activity Report (Laporan Kegiatan Penanaman Modal, or LKPM) is the document through which the company shows the regulator how that commitment is being deployed. It is submitted each quarter through the Online Single Submission (OSS) system, the same one that issued the company its Business Identification Number (Nomor Induk Berusaha, or NIB). The duty starts in the quarter the NIB is issued and continues for the life of the company, so the run of filings becomes a multi-year ledger of realisation against the original plan.
What the investment activity report is for
The obligation to report comes from the investment law itself. Law No. 25 of 2007 places a direct duty on every investor to submit periodic reports on the realisation of its investment, and Regulation of the Minister of Investment and Downstreaming, also Head of the Investment Coordinating Board (Badan Koordinasi Penanaman Modal, or BKPM), No. 5 of 2025 on Risk-Based Business Licensing and Investment Facilities sets out how the duty is carried out. The report lets the government see, each quarter, whether the capital an investor committed is being deployed on the licensed project.
The licence sets out what an investor plans to invest and what activity it will carry on. The investment activity report shows the regulator how far that plan has been carried out, quarter by quarter, so the realisation figures in the report can be measured against the commitment recorded at licensing. BKPM Regulation No. 5 of 2025 reinforces this in two ways. Article 27 requires paid-up capital to remain in the company’s bank account for at least 12 (twelve) months, with limited exceptions for asset acquisition, construction or operational expenditure, so the regulator sees funds committed before the first realisation figures appear. Appendix II to the regulation sets the framework BKPM uses to assess progress against the full plan, defining reference windows that range from approximately 4.5 (four and a half) years to approximately 15.5 (fifteen and a half) years for full project realisation, varying by sector. Within that frame, an investor is expected to begin realising its investment within one year of receiving the NIB, and a company that secures a licence and then leaves the project dormant becomes visible to the regulator through its own quarterly filings.
Who must file, and how often
The duty reaches every business actor that has a Business Identification Number. The exemptions are limited to micro-scale businesses and to activities financed through the State Budget or the Regional Budget. Banking, non-bank finance, insurance and upstream oil and gas, which were exempt under the predecessor regulation, are now subject to the regime under BKPM Regulation No. 5 of 2025 and file on the same schedule as everyone else. A PT PMA is not among the exemptions. It files the investment activity report from the quarter in which its NIB is issued, and it continues to file for as long as the company exists.
| Business scale | Investment size | Filing frequency |
|---|---|---|
| Micro enterprise | Up to IDR 1 billion | Exempt |
| Small enterprise | Above IDR 1 billion | Every six months |
| Medium enterprise | Above IDR 5 billion | Every quarter |
| Large enterprise, including a PT PMA | IDR 10 billion plan or above | Every quarter |
A PT PMA reports every quarter because its investment plan places it in the large band. The frequency does not depend on whether the company is trading. A company still in its construction stage, and a company that has paused operations, each file a report for the period, recording nil realisation where there is nothing new to record. A separate report is required for each business activity and each location the company runs, so a company with two lines of business under different classifications files for each.
The quarterly LKPM filing calendar
Each quarter has a fixed deadline, set at the fifteenth day of the month after the quarter closes. The fourth-quarter filing falls on 15 January, which makes the first weeks of the year the heaviest reporting period for most foreign-owned companies, because the annual financial statements and the corporate income tax return fall in the same opening months. Where a deadline coincides with a public holiday, an adjusted date is announced through the OSS system under Article 286 paragraph (7) of BKPM Regulation No. 5 of 2025.
| Reporting quarter | Period covered | Filing deadline |
|---|---|---|
| First quarter | January to March | 15 April |
| Second quarter | April to June | 15 July |
| Third quarter | July to September | 15 October |
| Fourth quarter | October to December | 15 January, the following year |
The first filing a new company submits depends on when its NIB was issued. A company licensed inside a quarter reports from the next full period, so a NIB issued in May produces a first filing for the third quarter, due on 15 October. The detailed filing mechanics, including how the OSS form treats a company that registers part-way through a quarter, are set out in our Governance series article on LKPM obligations and deadlines.
What each LKPM report contains
A report covers the company’s investment and activity for the quarter, with figures the regulator can compare against the original plan and against earlier reports. The OSS form asks for the realised investment, separated into fixed capital, such as land, buildings, machinery and equipment, and working capital. It asks for the workforce the company employs, the value of any production and exports, the funding sources behind the investment, and the stage the project has reached, whether construction or commercial operation. Where the company has met an obstacle, the form provides for that to be recorded, which gives the regulator a route to the reasons a plan has slipped.
A licence with no realisation behind it now draws sanctions on its own. The investment activity report is where that gap appears, quarter by quarter.
What happens when a report is missed
Non-submission carries administrative sanctions, applied in stages under BKPM Regulation No. 5 of 2025, and each stage is heavier than the one before. A revoked NIB, the final stage, removes the company’s access to the OSS system, which stops it operating lawfully and unwinds the licensing the investor built at the outset. The table below sets out the sequence.
| Stage | When it applies |
|---|---|
| Written warning | Issued in a progressive sequence after a missed or non-compliant filing, for example where a company fails to submit for two consecutive periods |
| Temporary suspension | Applied where the warnings produce no correction, and it may carry an administrative fine |
| Revocation of the business licence | Applied where non-compliance continues after suspension, cancelling the NIB |
| Loss of OSS access | Follows revocation of the NIB, removing the company’s ability to file or operate through the system |
The OSS system now flags inactivity directly. Where a company reports nil investment realisation for four consecutive quarters, the system can apply an administrative sanction without waiting for a separate review, a change introduced with the 2025 regulation to discourage dormant licences. The detailed escalation, including the warning intervals and the routes to lift a suspension, is covered in our Governance series article on the consequences of non-submission.
Where the report sits in the reporting year
The investment activity report is one of several filings a PT PMA submits each year, and each goes to a different authority. The table below places the LKPM next to the financial and corporate filings that share its calendar.
| Return | Authority | What it reports |
|---|---|---|
| Annual financial statements | Tax authority, with an audit where required | The company’s financial position for the year |
| Corporate income tax return | Tax authority | Taxable profit and the tax due, settled annually |
| Annual company report | Ministry of Law | Confirmation of the company’s corporate data for the year |
| Investment activity report (LKPM) | BKPM, through OSS | Realisation of the licensed investment, each quarter |
The LKPM is the filing a foreign owner most often overlooks, because it runs on a quarterly cycle while the financial statements and tax returns run annually, and because it sits with the investment licence at BKPM, away from the accountant who prepares the tax filings. Reading the four filings together, against one calendar, is how a company avoids a missed quarter. The financial services team at TraceWorthy maintains that combined calendar for foreign-owned companies, alongside the realisation figures each LKPM requires, so the quarterly report is prepared from the company’s own records ahead of each deadline.
Each quarterly report measures realisation against the same investment plan that places a PT PMA in the large enterprise band, examined in the second article of this series. Because that plan is realised over years, the obligation continues for the life of the company, and the run of quarterly reports becomes the record the regulator reads when it assesses whether a licensed investment was carried out.
The advisory work behind each report
The investment activity report is the quarterly surface of a multi-year realisation programme that begins at NIB issuance and continues for the life of the company. A foreign-owned company that treats the LKPM as a quarterly form, completed in the days before the deadline, leaves that programme largely unmanaged. Four areas of work sit underneath the report, each at a different point in the cycle.
| Stage in the cycle | The work that sits underneath the quarterly report |
|---|---|
| Investment plan structuring at NIB issuance | Translation of the licensed investment value above IDR 10,000,000,000 (ten billion Indonesian Rupiah) per KBLI per project location into a year-by-year realisation schedule the company can sustain, allocation across fixed capital and working capital, alignment with the 12 (twelve) month paid-up capital retention requirement under Article 27 of BKPM Regulation No. 5 of 2025, and the construction of the milestones each quarterly report will record. |
| Quarterly preparation and cross-system reconciliation | Extraction of realisation figures from the general ledger and the accounting records, reconciliation against the annual financial statements where audited, the corporate income tax return and the monthly Article 25 instalment file, the Value Added Tax (Pajak Pertambahan Nilai, or PPN) returns where the company is a Taxable Enterprise (Pengusaha Kena Pajak, or PKP), the employment social security records maintained under BPJS Ketenagakerjaan (Badan Penyelenggara Jaminan Sosial Ketenagakerjaan), and the Mandatory Manpower Report (Wajib Lapor Ketenagakerjaan Perusahaan, or WLKP), since BKPM treats inconsistency across these sources as a trigger for review. |
| Substantive-activity evidencing for parent-company structures | Documentation that a parent company classified under KBLI 64200 carries on substantive operations in its own right, since BKPM measures the investment commitment against the parent entity’s own balance sheet, and ownership of subsidiaries on its own is no longer accepted as realisation. |
| Sanctions response and the restoration pathway | Drafting of the company’s response at each stage of the progressive warning sequence and at temporary suspension, preparation of the missed quarterly reports with the explanatory narrative the OSS form requires, restoration of NIB access where a suspension is in place, and negotiation with BKPM on the compliance timeline required to lift the sanction. |
This is the work TraceWorthy’s financial services team performs for foreign-owned companies on Indonesian licenses:
- structuring the investment plan at NIB issuance,
- preparing and submitting each quarterly report,
- reconciling realisation figures across the company’s own financial systems, and
- responding to BKPM where a filing slips or realisation lags.
The combined calendar referenced earlier is the operational instrument behind this work.
Frequently asked questions
What is the investment activity report?
The investment activity report, known by the initials LKPM, is a periodic report on the realisation of a company’s investment. It is required under Law No. 25 of 2007 on Investment and specified by BKPM Regulation No. 5 of 2025, and it is filed through the OSS system that issued the company its NIB.
Does a PT PMA have to file the investment activity report every quarter?
Yes. A PT PMA sits in the large band, which files every quarter. The duty does not depend on trading, so a company in construction or paused operation still files a report for the period, recording nil realisation where there is nothing new to report.
When are the LKPM deadlines?
Each quarter is due on the fifteenth day of the following month. The first quarter is due 15 April, the second 15 July, the third 15 October, and the fourth 15 January of the next year. Where a deadline coincides with a public holiday, the OSS system announces an adjusted date.
What does the investment activity report contain?
It records realised fixed capital, such as land, buildings, machinery and equipment, and working capital. It also records the workforce employed, the value of any production and exports, the funding sources, the stage of the project, whether construction or commercial operation, and any obstacles met during the period.
What are the sanctions for missing an LKPM?
Sanctions are administrative and escalate in stages under BKPM Regulation No. 5 of 2025: a written warning first, then temporary suspension of business activities, then revocation of the business licence, with a revoked NIB removing the company’s access to OSS. The system can also apply a sanction where a company reports nil realisation for four consecutive quarters.
Is the investment activity report the same as the tax return?
No. The investment activity report goes to BKPM through OSS and records how the licensed investment is being realised, every quarter. The corporate income tax return is an annual filing to the tax authority on taxable profit. The two run on separate calendars and answer to separate authorities, so a company prepares each one independently.
This article provides general information on the investment activity report (LKPM) in Indonesia as at May 2026 and does not constitute legal, tax or accounting advice. Reporting thresholds, deadlines and sanctions are set by regulation and can change, and the position for any individual company depends on its scale, sector and licensing. Obtain advice specific to your circumstances before acting on any point set out above.
Acronyms and Indonesian-language terms
| Term | Full form | Meaning in this series |
|---|---|---|
| BKPM | Badan Koordinasi Penanaman Modal | The Investment Coordinating Board, now within the Ministry of Investment and Downstreaming, which receives the investment activity report and sets the licensing and capital rules. |
| BPJS | Badan Penyelenggara Jaminan Sosial | The social security administering bodies for health and for employment, to which an employer pays monthly contributions. |
| HPP | Harmonisasi Peraturan Perpajakan | The Harmonisation of Tax Regulations Law, Law No. 7 of 2021, which fixed the corporate income tax rate and the value added tax rate. |
| IDX | Indonesia Stock Exchange (Bursa Efek Indonesia) | The exchange on which a company lists to reach the 19 per cent public-company rate. |
| LKPM | Laporan Kegiatan Penanaman Modal | The investment activity report, the quarterly report on the realisation of a company’s investment. |
| NIB | Nomor Induk Berusaha | The Business Identification Number, the foundational licence issued through OSS. |
| OSS | Online Single Submission | The risk-based electronic licensing system that issues the NIB and receives the LKPM. |
| PKP | Pengusaha Kena Pajak | A Taxable Enterprise, the status a company takes for value added tax once its turnover reaches the registration threshold. |
| PPN | Pajak Pertambahan Nilai | Value added tax. |
| PPnBM | Pajak Penjualan atas Barang Mewah | The Sales Tax on Luxury Goods, charged on designated luxury items alongside value added tax. |
| PT PMA | Perseroan Terbatas Penanaman Modal Asing | A foreign-investment limited liability company, the entity through which a foreign investor operates in Indonesia. |
| RPTKA | Rencana Penggunaan Tenaga Kerja Asing | The Foreign Worker Utilisation Plan, the approval an employer secures before engaging a foreign worker. |
| SABH | Sistem Administrasi Badan Hukum | The Legal Entity Administration System of the Ministry of Law, through which corporate changes and the annual report deed are lodged. |
| WLKP | Wajib Lapor Ketenagakerjaan Perusahaan | The mandatory company manpower report filed with the Ministry of Manpower. |
Legal instruments cited in the series
| Instrument | Full title | What it governs in the series | Article |
|---|---|---|---|
| Entity, capital and governance | |||
| Law No. 40 of 2007 | Law on Limited Liability Companies | The requirement that at least 25 per cent of authorised capital is issued and fully paid. | 2 |
| Law No. 6 of 2023 | Job Creation Law, enacting the Government Regulation in Lieu of Law on Job Creation | The removal of the fixed minimum authorised capital for a company. | 2 |
| Govt Regulation No. 7 of 2021 | Ease, Protection and Empowerment of Cooperatives and Micro, Small and Medium Enterprises | The enterprise size bands that classify a PT PMA as a large enterprise. | 2 |
| Minister of Law Regulation No. 49 of 2025 | Requirements and Procedures for the Establishment, Amendment and Dissolution of Limited Liability Company Legal Entities | The annual report, approved by deed and lodged through SABH. | 1 |
| Licensing and investment reporting | |||
| Law No. 25 of 2007 | Law on Investment | The duty on every investor to report investment realisation, the basis of the LKPM. | 1, 4 |
| BKPM Regulation No. 5 of 2025 | Regulation of the Minister of Investment and Downstreaming, also Head of BKPM, on Risk-Based Business Licensing and Investment Facilities | The minimum paid-up capital, the investment plan, and the LKPM frequency and sanctions. | 2, 4 |
| Minister of Law and Human Rights Regulation No. 22 of 2023 | On the investor stay permit, as amended in 2024 and 2025 | The personal shareholding figure of IDR 10,000,000,000 (ten billion Indonesian Rupiah) for the investor permit. | 2 |
| Corporate and indirect tax | |||
| Income Tax Law | Law No. 7 of 1983 on Income Tax, as amended | The corporate income tax base, the Article 25 instalments, the Article 26 withholding on payments abroad, and the Article 31E turnover relief. | 3 |
| Law No. 7 of 2021 | Law on the Harmonisation of Tax Regulations | The 22 per cent corporate income tax rate and the value added tax rate. | 1, 3 |
| Govt Regulation No. 30 of 2020 | Reduction of the Income Tax Rate for Domestic Corporate Taxpayers in the Form of Public Companies | The 19 per cent rate for a qualifying listed company. | 3 |
| Govt Regulation No. 55 of 2022 | Adjustment of Income Tax Regulations | The 0.5 per cent final tax on turnover up to the small-business ceiling. | 3 |
| MoF Regulation No. 131 of 2024 | On Value Added Tax on Goods and Services | The value added tax base and the 12 per cent rate on goods carrying the Sales Tax on Luxury Goods. | 1 |
| MoF Regulation No. 136 of 2024 | On the Global Minimum Tax | The 15 per cent minimum effective rate for groups with consolidated revenue of EUR 750,000,000 (seven hundred and fifty million Euros) and above. | 3 |
| Employment, social security and records | |||
| Law No. 7 of 1981 | Law on Mandatory Manpower Reporting in Companies | The basis of the WLKP. | 1 |
| Govt Regulation No. 34 of 2021 | On the Utilisation of Foreign Workers | The RPTKA, and the WLKP as a precondition for a foreign-worker permit. | 1 |
| Law No. 24 of 2011 | Law on the Social Security Administering Bodies | The basis of the monthly BPJS contributions. | 1 |
| Law No. 8 of 1997 | Law on Company Documents | The ten (10)-year retention period for company records. | 1 |
| Regional comparators | |||
| Foreign Investments Act of 1991 | Philippine Foreign Investments Act | The minimum paid-in capital for a foreign-owned domestic-market enterprise, set beside the Indonesian figure. | 2 |
| Foreign Business Act of 1999 | Thai Foreign Business Act | The minimum capital for a foreign business, set beside the Indonesian figure. | 2 |
Where to read these instruments
The text of every Indonesian law, government regulation and ministerial regulation listed above sits in the national legal database maintained by the Audit Board, at peraturan.bpk.go.id, and on the government portal peraturan.go.id. As an example, Law No. 25 of 2007 on Investment is at peraturan.bpk.go.id/Details/39903.
For the operational side, the tax authority at pajak.go.id carries guidance on the income tax and value added tax points, while the licensing system at oss.go.id and the investment ministry at bkpm.go.id carry the licensing and capital procedures, together with the forms for the investment activity report. The two regional comparators sit with their own authorities, the Philippine Securities and Exchange Commission and the Thai Department of Business Development.
Each instrument in the reference table above links to its authoritative source. Most resolve to the Audit Board database, with the two Minister of Finance regulations housed in the Ministry of Finance database and the two foreign comparators housed by the Philippine Official Gazette and the Thai Department of Business Development. A direct document link can move when a database is reorganised, so the database root and portals above remain the reliable point of re-entry should any link change.
This reference summarises instruments as cited in the Reporting Year series, current at May 2026, and does not constitute legal, tax or accounting advice. Regulations are amended and replaced, and the position for any individual company depends on its own facts. Confirm the current text of any instrument at the source before relying on it.