Current as at 10 November 2026.
Since 17 December 2025, every Indonesian Perseroan Terbatas (PT, limited liability company) formed by two or more founders, a Perseroan persekutuan modal, has had to file the approval of its annual report with the Ministry of Law. This group includes every foreign-owned company (Perseroan Terbatas Penanaman Modal Asing, PT PMA). Minister of Law Regulation Number 49 of 2025 (Permenkum 49/2025) requires the Rapat Umum Pemegang Saham Tahunan (RUPS Tahunan, annual general meeting of shareholders, referred to here as the AGMS) to approve the annual report. The approval is then recorded in a notarial deed, and the deed is filed through the Sistem Administrasi Badan Hukum (SABH, Legal Entity Administration System) within 30 calendar days of signature.1 The Directorate General applies that 30-day period to deeds from 1 November 2026.4 The obligation applies to a domestic PT and to a PT PMA on the same terms.
The Direktorat Jenderal Administrasi Hukum Umum (AHU, Directorate General of General Legal Administration) at the Ministry of Law announced on 27 October 2026 that companies which have not filed their 2025 annual report will receive a written warning between 1 and 31 December 2026. SABH access will be blocked from 2 January 2027 for any company that has still not filed.4
In the Business Health Checks we facilitate for our clients, we check each financial year for an AGMS approval and each director and commissioner for a current term. We find PT PMAs with no AGMS for several years, and directors and commissioners whose terms ended without a reappointment. Each of these companies has a 2025 filing to make before the block begins, and a company whose officers’ terms have lapsed also needs SABH access to record their reappointment.
What must a PT do each year?
For a company whose financial year ends on 31 December, the AGMS for the 2026 financial year must be convened by 30 June 2027.12
| Step | Who acts | Deadline | Legal basis |
|---|---|---|---|
| Financial statements prepared under Indonesian financial accounting standards, and audited by a public accountant where the audit criteria apply | Directors | Before the AGMS | Company Law, Articles 66(3) and 68 |
| Annual report reviewed | Board of commissioners | Before the report goes to the AGMS | Company Law, Article 66(1); Permenkum 49/2025, Article 16(1) |
| Annual report submitted to the AGMS | Directors | Within six months after the financial year ends, which is 30 June for a company whose year ends on 31 December | Company Law, Articles 66(1) and 78(2); Permenkum 49/2025, Article 16(1) |
| Annual report approved and financial statements ratified | Shareholders in the AGMS | At the AGMS | Company Law, Article 69(1) |
| Approval recorded in a notarial deed | Notary | After the AGMS | Permenkum 49/2025, Article 16(2) |
| Deed and annual report uploaded through SABH | Directors, through the notary | Within 30 calendar days of signature of the deed | Permenkum 49/2025, Articles 1(10) and 16(3) to (5) |
| Notice of receipt issued | Minister of Law, through the Director General of AHU | When the filing is received | Permenkum 49/2025, Article 16(7) |
Permenkum 49/2025 defines a day as a calendar day, so weekends and public holidays count towards the 30 days between the signature of the deed and the filing in SABH.1
What must the annual report contain?
Article 16(6) of Permenkum 49/2025 repeats the minimum contents set by Article 66(2) of the Company Law.12
The annual report must contain at least the following:
- financial statements consisting of at least a balance sheet compared with the previous financial year, a profit and loss statement, a cash flow statement, a statement of changes in equity and the notes to those statements;
- a report on the activities of the company;
- a report on the implementation of social and environmental responsibility;
- details of any problems arising during the financial year that affected the company’s business;
- a report on the supervision performed by the board of commissioners during the previous financial year;
- the names of the members of the board of directors and of the board of commissioners;
- the salaries and benefits of the directors, and the salaries or honoraria and benefits of the commissioners, for the previous year.
Article 74 of the Company Law makes social and environmental responsibility a legal obligation for a company whose business is in natural resources or affects them. Article 66(2)(c) of the Company Law and Article 16(6)(c) of Permenkum 49/2025 list the report on social and environmental responsibility without exception, so we include the section for every company and record the programmes undertaken, or that none were undertaken.12
Under Article 68(1) of the Company Law, the directors must submit the financial statements to a public accountant for audit where any of the following applies to the company:2
- its business is collecting or managing public funds;
- it issues debt instruments to the public;
- it is a public company, or it is a state-owned limited liability company (persero);
- its assets or turnover amount to at least IDR 50,000,000,000, approximately USD 2,758,000 at IDR 18,128 to USD 1 on 6 November 2026;6
- another law or regulation requires the audit.
Where an audit is required and has not been performed, Article 68(2) of the Company Law prevents the AGMS from ratifying the financial statements, so the audit is completed before the AGMS is convened.2
What are the dates for the 2025 annual report?
| Date | Event | Source |
|---|---|---|
| 17 December 2025 | Permenkum 49/2025 takes effect and revokes Minister of Law and Human Rights Regulation Number 21 of 2021 | Permenkum 49/2025, Articles 33 and 34 |
| 30 June 2026 | Six-month deadline for the 2025 AGMS of a company whose financial year ends on 31 December | Company Law, Article 78(2) |
| 1 August to 31 December 2026 | Government fee for an annual report filing set at zero | AHU announcement of 27 October 2026, point 24; Minister of Law Regulation Number 13 of 2026, as reported7 |
| 1 to 31 December 2026 | Written warnings sent by SABH notification or email | AHU announcement of 27 October 2026, point 34; Permenkum 49/2025, Article 18(1) |
| 2 January 2027 | SABH access blocked for companies that have not filed | AHU announcement of 27 October 2026, point 34 |
| 2 January to 30 June 2027 | Period announced for filing the 2026 annual report; each filing remains due within 30 calendar days of signature of the deed | AHU announcement of 27 October 2026, point 44 |
Article 18(2) of Permenkum 49/2025 allows a block where a company has not filed within 30 calendar days of the date of its own SABH warning notification, so the date on which a particular company is blocked depends on when its warning was sent.1
A company that has not filed its 2025 annual report can still approve it at an AGMS or by an Article 91 written resolution. Once the notary has signed the deed, the filing can be made through SABH before the written warnings begin on 1 December 2026, and the notice fee remains zero until 31 December 2026. A company planning a capital increase, a share sale, a change of directors or an amendment to its articles in early 2027 needs the filing complete before 2 January 2027, because a block prevents those changes from being registered.
Outside the zero-fee period, which runs from 1 August to 31 December 2026,7 Government Regulation Number 30 of 2026 (PP 30/2026) sets the fee for each annual report filing at IDR 500,000 (approximately USD 28) for a company required to be audited and IDR 250,000 (approximately USD 14) for any other company, at IDR 18,128 to USD 1 on 6 November 2026.3 Notary fees are charged separately.
What does a blocked SABH account stop?
SABH is the Ministry of Law system through which a notary registers each change to a company’s legal record. While access is blocked, the company cannot register changes to that record.15 The changes affected include the following:
- a change of directors or commissioners, including the reappointment of an officer whose term has ended;
- a transfer of shares to a new shareholder;
- a change in the name of a shareholder;
- an amendment to the articles of association, including a change of capital.
For a PT PMA, these items include the appointment of a foreign director and the registration of a new foreign investor as a shareholder.
Under the Elucidation to Article 94(3) of the Company Law, a director whose term has ended leaves office until a decision of the general meeting of shareholders reappoints the director.2 A block on SABH access prevents a reappointment from being registered until the annual report filing is complete. Article 16(3) of Permenkum 49/2025 requires the directors to make the filing, so where every director’s term has ended, the shareholders first reappoint the directors by an AGMS or an Article 91 written resolution, and the notary registers that change in SABH before 2 January 2027.1
To lift a block, the company applies through SABH on the unblocking form, and uploads the notarial deed of the AGMS approval and the annual report (Article 19(3)). The Director General lifts the block once the application is received and complete (Articles 19 and 20).1 PP 30/2026 sets an unblocking fee of IDR 2,000,000 (approximately USD 110) per approval for a company required to be audited and IDR 1,000,000 (approximately USD 55) for any other company.3
Who is accountable for the annual report?
The directors prepare the annual report and submit it to the AGMS, and the board of commissioners reviews it first. Where the financial statements prove to be incorrect or misleading, Article 69(3) of the Company Law makes the directors and the commissioners jointly liable to any party who suffers loss as a result. Article 69(4) releases a member who proves that the situation was not caused by their fault.2
Shareholders who together own one tenth or more of the voting shares may ask the directors to convene a general meeting. Where neither the directors nor the commissioners issue the summons within the required period, Article 80(1) of the Company Law allows the requesting shareholder to apply to the chair of the district court for permission to convene the meeting.2
How can shareholders overseas approve the annual report?
Article 77 of the Company Law allows a general meeting to be convened by electronic media, such as a video conference, provided every participant can see and hear the others directly and take part in the meeting. The minutes of a meeting convened this way must be approved and signed by every participant.2 Article 91 allows the shareholders to decide without a meeting where every shareholder with voting rights approves the proposal in writing and signs it.2 A PT PMA whose shareholders live outside Indonesia can use these provisions for the AGMS approval, and the notary then records the approval in a deed for filing through SABH under Article 16(2) of Permenkum 49/2025.1
How do we bring a company’s annual reporting up to date?
In a Business Health Check, our team reads the company’s deeds registered in AHU against its financial statements, its tax returns, its officer appointments and its beneficial ownership record. We then record each financial year that has no AGMS approval, and each director or commissioner whose term has ended. Where the review shows an open year, we remediate it with the company.
Our work includes the following:
- preparing or reconciling the financial statements for each open year, and arranging an audit by a public accountant where Article 68 applies;
- drafting the annual report with each of the required items, and arranging the review by the board of commissioners;
- preparing the AGMS resolutions, including the reappointment of any officer whose term has ended, for a meeting by video conference or a written resolution where the shareholders of a PT PMA are overseas;
- instructing the notary, and tracking the 30 calendar days from signature of the deed until the SABH notice of receipt is issued;
- scheduling the 2026 AGMS by 30 June 2027, and the filing within 30 calendar days of signature of the deed.
Our team includes qualified and experienced lawyers, accountants, tax specialists, compliance experts and immigration specialists, alongside the community, business and people development skills and qualifications that Tracy Wilkinson brings herself. We perform this work for clients in Indonesia and overseas, for domestic companies and for PT PMAs.
To have your company’s annual reporting and officer terms reviewed before the written warnings begin on 1 December 2026, book a Business Health Check with our team.
This article is general information and is current as at 10 November 2026. The dates for the 2025 filing come from an announcement by the Ministry of Law, which can change them, and the obligations of any company depend on its own financial year, audit status, articles of association and officer terms. This article is no substitute for advice on a company’s own position, and it creates no advisory relationship.
Frequently asked questions
Article 16 of Permenkum 49/2025 applies to every PT formed by two or more founders (Perseroan persekutuan modal) and contains no exemption for a company without revenue. A single-founder micro company (Perseroan perorangan) files financial statements under Article 27 instead. The AHU announcement of 27 October 2026 directs a company established in 2026, or whose financial year has not ended in 2026, to file in the following reporting period.4
The six-month deadline in Article 78(2) of the Company Law has passed, and the company can still convene the AGMS and file the approval. The AHU announcement schedules written warnings from 1 December 2026 for any company without a filing, and blocking of SABH access from 2 January 2027.
The annual report goes to the AGMS and, once approved, to the Ministry of Law through SABH. The annual corporate income tax return goes to the Directorate General of Taxes. We reconcile the financial statements filed with each, because the two authorities each receive a set.
The company completes the unblocking form in SABH and uploads the two supporting documents in Article 16(5): the notarial deed of the AGMS approval and the annual report. The Director General lifts the block once the application is received and complete, under Articles 19 and 20 of Permenkum 49/2025.
Legal References
1. Minister of Law Regulation Number 49 of 2025 on the Requirements and Procedures for the Establishment, Amendment and Dissolution of Limited Liability Company Legal Entities (Peraturan Menteri Hukum Nomor 49 Tahun 2025 tentang Syarat dan Tata Cara Pendirian, Perubahan, dan Pembubaran Badan Hukum Perseroan Terbatas), enacted 11 December 2025 and promulgated 17 December 2025. Articles 1(10), 16 to 20, 27, 33 and 34.
2. Law Number 40 of 2007 on Limited Liability Companies (Undang-Undang Nomor 40 Tahun 2007 tentang Perseroan Terbatas), as amended by Law Number 6 of 2023 on the Stipulation of Government Regulation in Lieu of Law Number 2 of 2022 on Job Creation. Articles 66, 68(1) and (2), 69, 74, 77, 78, 79, 80, 91, 94(3) and its Elucidation, and 111(3).
3. Government Regulation Number 30 of 2026 on the Types and Tariffs of Non-Tax State Revenue at the Ministry of Law (Peraturan Pemerintah Nomor 30 Tahun 2026), enacted and promulgated 2 July 2026, State Gazette 2026 Number 72, in force 30 days after promulgation (Article 10). Lampiran, section I.A, items 11 and 12.
Research and Data Sources
4. Directorate General of General Legal Administration, Announcement on the implementation of administrative sanctions for limited liability companies that have not filed an annual report (Pengumuman Pemberlakuan sanksi administratif bagi perseroan terbatas yang belum menyampaikan laporan tahunan), official Instagram account @djahu_kemenkum, 27 October 2026. Points 1 to 5.
5. DDTC News, Ditjen AHU prepares sanctions for PTs that have not filed annual reports, 29 October 2026, reporting the Directorate General’s announcement.
6. Metro TV, Rupiah exchange rate on 6 November 2026, IDR 18,128 to USD 1, used for every USD equivalent in this article.
7. DDTC, Ministry of Law waives annual report fee for LLCs until December, 12 August 2026, reporting Minister of Law Regulation Number 13 of 2026.
Glossary
| Indonesian term | Abbreviation | English meaning |
|---|---|---|
| Perseroan Terbatas | PT | Limited liability company |
| Perseroan persekutuan modal | None | A PT formed by two or more founders under an agreement, with capital divided into shares; the companies bound by Article 16 of Permenkum 49/2025 |
| Perseroan perorangan | None | A single-founder PT for micro and small businesses, which files financial statements under Article 27 of Permenkum 49/2025 |
| Perseroan Terbatas Penanaman Modal Asing | PT PMA | Foreign-owned limited liability company |
| Rapat Umum Pemegang Saham Tahunan | RUPS Tahunan; AGMS | Annual general meeting of shareholders |
| Sistem Administrasi Badan Hukum | SABH | Legal Entity Administration System of the Ministry of Law |
| Direktorat Jenderal Administrasi Hukum Umum | AHU | Directorate General of General Legal Administration, Ministry of Law |
| Peraturan Menteri Hukum | Permenkum | Minister of Law Regulation |
| Laporan tahunan | None | Annual report |
| Akta notaris | None | Notarial deed |
| Persero | None | State-owned limited liability company |
| Hari | None | Day; a calendar day under Permenkum 49/2025, Article 1(10) |