Every PT and PMA company in Indonesia must now file its annual report electronically with the Ministry of Law through the Legal Entity Administration System (Sistem Administrasi Badan Hukum, SABH). The obligation was introduced by Minister of Law Regulation No. 49 of 2025 and has applied since 1 June 2026. Administrative sanctions begin in November 2026.
Holding the Annual General Meeting of Shareholders (AGMS) alone does not discharge it. The Board of Directors must present the annual report, reviewed by the Board of Commissioners, to the AGMS for approval within six months of the end of the financial year — 30 June for a December year-end. That approval must then be recorded in a notarial deed and the deed, together with the annual report, filed with the Minister through SABH within 30 days of the deed being signed.
The first report due is for financial year 2025. For a December year-end the AGMS deadline was 30 June 2026, so a company whose approval deed has not yet been lodged is already outside the 30-day window. The Ministry’s filing fee (PNBP) is Rp 250,000 per filing, or Rp 500,000 for a company subject to statutory audit, and is included in our fee below.
What non-compliance costs: a written warning, and if the filing is still not made within 30 days of it, the company’s SABH access is blocked. While blocked, no change to directors, commissioners, shareholding or articles can be processed — which in practice stalls bank mandates, licence renewals, investment approvals and tender participation. Unblocking costs a further Rp 1–2 million and starts only after the overdue report is filed.
Our annual report filing service includes:
- Review of the annual report against the contents the regulation requires
- Preparation and execution of the notarial deed recording AGMS approval of the annual report
- Electronic submission of the deed and the annual report to the Ministry of Law through SABH
- Confirmation once SABH has accepted the filing
You supply the year’s financial statements, the AGMS minutes or circular resolution approving the report, and current details of the directors, commissioners and shareholders. A company subject to statutory audit also supplies the audited statements and the public accountant’s name, licence number and date of licence, which the SABH filing records. Where Okusi Associates already handles your bookkeeping and tax reporting, most of this is prepared already.
The annual report must contain at least the company’s financial statements, a report on its activities, a report on social and environmental responsibility (TJSL, mandatory where the company operates in the natural-resources sector), any problems arising during the year, the Board of Commissioners’ supervisory report, the names of the directors and commissioners, and their remuneration for the year.
Companies that collect public funds, have issued debt instruments to the public, are listed, are state-owned, or whose total assets or annual turnover reach IDR 50 billion must have their financial statements audited by a registered public accountant before the AGMS can ratify them — see Financial Statement Audit.
The fee shown is all-inclusive: Okusi’s work, the notarial deed, the SABH lodgement, VAT and the Ministry’s filing fee. If your FY2025 approval has not yet been filed, we can have the deed executed and lodged within 14 working days — contact us today.
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