Frequently Asked Questions: #sabh-annual-report-vs-tax-return-lkpm

Yes. Indonesian companies now report annually to three different ministries, and none of the filings substitutes for another:

• Tax office (Ministry of Finance). The annual corporate income tax return (SPT Tahunan PPh Badan) with the financial statements attached, due four months after year-end (30 April for a December year-end). Filed through the tax office’s own systems.
• BKPM (Ministry of Investment). The Investment Activity Report (LKPM), filed through OSS — quarterly for medium and large businesses, half-yearly for small ones. Applies to PMA companies and to any company holding investment licensing.
• Ministry of Law. The annual report approved by the AGMS, filed through SABH by a notary within 30 days of the notarial deed of approval, under Permenkum 49/2025.

They draw on the same underlying accounts, but they are different documents, go to different systems, have different deadlines and carry different sanctions. Being fully up to date with the tax office and OSS does nothing for the Ministry of Law obligation, and vice versa.

The practical sequence for a December year-end company is:

• Close the books and finalise the financial statements
• File the tax return by 30 April
• Hold the AGMS (or pass a circular resolution) approving the annual report by 30 June
• Have the notary draw the deed and lodge it with the report in SABH within 30 days
• Keep LKPM filings running to their own quarterly or half-yearly calendar throughout

Does a circular resolution count? Yes. Article 91 of the Company Law allows shareholders to take decisions outside a meeting by a resolution signed by all of them, and approval of the annual report is routinely done this way by companies with one or two shareholders. The notary records the circular resolution in the deed exactly as they would the minutes of a meeting.

Can the company file without a notary? No. SABH access for this filing sits with the notary, and the deed itself must be a notarial instrument.

Dormant or zero-activity companies are not exempt. A company with no transactions still has financial statements (nil ones), still needs an AGMS or circular resolution to approve them, and still needs the deed lodged.

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