Frequently Asked Questions: #annual-report-ministry-of-law-sabh-filing

Since 1 June 2026 every Indonesian limited liability company — local PT and foreign-owned PMA alike — must file its annual report electronically with the Ministry of Law (Kementerian Hukum) through the Legal Entity Administration System (Sistem Administrasi Badan Hukum, SABH). The obligation comes from Minister of Law Regulation No. 49 of 2025 (Permenkum 49/2025), which gives effect to the long-standing annual-report provisions of the Company Law (Law No. 40 of 2007, Articles 66–69).

The filing is a two-step process:

• Approval. The Board of Directors prepares the annual report, the Board of Commissioners reviews it, and the Annual General Meeting of Shareholders (AGMS) approves it. Under Article 91 of the Company Law the shareholders may instead approve it by a circular resolution signed by all of them, without holding a physical meeting.
• Filing. The approval is recorded in a notarial deed. Within 30 days of that deed being signed, the directors — acting through the notary, who holds the SABH access — upload two documents: the notarial deed of approval and the annual report itself.

Points that are often misunderstood:

• Holding the AGMS is not enough. The obligation is discharged only when the deed and report have been lodged in SABH.
• The notary is the channel. Companies do not file directly; the deed must be made and uploaded by an Indonesian notary.
• It applies to companies with capital divided into shares (perseroan persekutuan modal). A PT Perorangan (single-shareholder micro or small company) files a simpler financial statement under separate rules.
• It is not a replacement for existing filings. Corporate tax returns to the tax office and the Investment Activity Report (LKPM) to BKPM continue as before; this is a third, separate obligation to a third ministry.

The first report due under the new rule is the one for financial year 2025.

Okusi Associates prepares the notarial deed and lodges the filing — see Annual Report Deed & SABH Filing.

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