Frequently Asked Questions: #annual-report-sabh-deadline-sanctions

There are two deadlines, one leading into the other:

• AGMS approval: within six months of the end of the financial year. For the December year-end that almost every Indonesian company uses, that is 30 June of the following year.
• SABH filing: within 30 days of the date the notarial deed recording that approval is signed.

So a company with a December year-end that holds its AGMS on 30 June and has the deed drawn the same day must have the filing in SABH by 30 July.

The first year is unusual. The obligation took effect on 1 June 2026, and the first report due is the one for financial year 2025 — whose AGMS deadline was 30 June 2026. Any company that approved its 2025 report but has not yet had the deed lodged is already outside the 30-day window. The Ministry has said administrative sanctions will begin to be applied from November 2026.

Sanctions under Articles 17–18 of Permenkum 49/2025 are administrative and come in sequence:

• A written warning, delivered by SABH notification and/or email to the company’s registered contact.
• If the filing is still not made within 30 days of that warning, the company’s access to SABH is blocked.

Blocking is the sanction that hurts. While it stands the Ministry will not process any change to the company: appointment or resignation of directors and commissioners, transfers of shares, capital changes, amendments to the articles of association, change of address. In practice that stalls bank mandate changes, licence renewals that require current company data, investment approvals and tender pre-qualification.

Government fees. Under Government Regulation No. 30 of 2026 the state fee (PNBP) for the annual report notification is Rp 250,000 per filing for a company not subject to statutory audit and Rp 500,000 for one that is. Lifting a block costs a further Rp 1,000,000 or Rp 2,000,000 on the same distinction, and is granted only once the overdue report has been filed.

Fees for the notary and for any professional assistance are separate from the government charges above.

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