Major Changes in Indonesia's Regulation 2026: Know the Mandatory Annual Reporting Requirements for Your Company
- Jun 14
- 3 min read
Indonesia has taken a significant step in tightening corporate compliance. Through the Ministry of Law, the Government has issued Minister of Law Regulation (Permenkum) No. 49 of 2025, which came into effect on 17 December 2025. This regulation replaces Minister of Law Regulation No. 21 of 2021 and introduces fundamental changes to the annual reporting obligations of all Limited Liability Companies (PT) and Foreign Investment Limited Liability Companies (PT PMA) operating in Indonesia.
For business operators and foreign investors, this represents a systemic change with a direct impact on the continuity of company operations.
1. What Is an Annual Report?
An Annual Report is an official document that must be prepared by the Board of Directors of every limited liability company, containing a summary of performance, financial condition, and management’s accountability for the company’s operations during one financial year.
Key Components of the Annual Report:
• Audited Financial Statements (Balance Sheet, Profit and Loss Statement, Cash Flow Statement)
• Report by the Board of Directors on the running of the company
• Report by the Board of Commissioners on the oversight of management
• Disclosure of Beneficial Owner information
• Business plans and future projections
2. Latest Update from the Indonesian Government
The Government of Indonesia officially enacted Permenkum No. 49 of 2025 on 17 December 2025. This regulation revokes and replaces Permenkum 21/2021
Annual Reporting Is Now Mandatory in Digital Form
The most crucial change is that the Annual Report is no longer sufficient to be kept internally. Every PT and PT PMA must now upload their annual report to the Government’s SABH (Legal Entity Administration System) or AHU Online system. This applies without exception, including for companies that have not made any changes during the financial year.
3. Comparison of Old Rules vs New Rules
Aspect | Before (Permenkum 21/2021) | After (Permenkum 49/2025) |
Annual Report | Not required to be reported to the system | MUST be uploaded to SABH/AHU Online |
Annual General Meeting of Shareholders (RUPS) | Internal record sufficient | Must be notarised and reported |
Beneficial Owner | Voluntary | Mandatory disclosure, with a dedicated document |
Sanctions | No automatic block | Automatic SABH access block |
Corporate changes | Single registration pathway | Two pathways: Approval & Notification |
4. Timeline and Milestones
Peterson Solutions Indonesia, as an experienced consultant in analysis and report preparation, is ready to support your company end-to-end in completing the analysis and report in line with the agreed timeline.
With the combination of Peterson Solutions Indonesia’s technical expertise and active collaboration with the client’s team, this process is designed to be efficient, transparent, and to produce a high-quality, timely report ensuring your company receives accurate analysis that can be implemented immediately.
5. Consequences of Late or Non-Reporting
Sanctions for non-compliance under Permenkum 49/2025 are immediate, automatic, and have a significant operational impact. This is not merely an administrative fine — it is a freeze on the company’s ability to operate legally.
SABH/AHU Online Access Block
The most critical consequence is the automatic blocking of access to the SABH system. When SABH access is blocked, the company will be unable to carry out:
• Amendments to the Articles of Association (name, domicile, capital, etc.)
• Changes to or additions of Directors and Commissioners
• Changes to the shareholder structure
• Company restructuring processes
• Filing for company dissolution
• All other corporate changes
In other words, your company becomes legally frozen. You cannot make any corporate decisions until compliance is restored.
Ready to start a timely, accurate, and professional analysis and annual report for your company? Peterson Solutions Indonesia is ready to be your partner please schedule a consultation session with our team of experts!
📞 Telp: +62 21 2270 8913
Let’s make this a high-quality annual report before the 30 June deadline.
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Legal References
Minister of Law Regulation No. 49 of 2025 | Law No. 40 of 2007 on Limited Liability Companies | BKPM Regulation No. 5 of 2025 | Government Regulation No. 5 of 2021 (OSS-RBA)