Indonesia Delays Sanctions for Missing Company Annual Reports, With System Blocking From January 2027

Indonesian companies that have not yet filed their 2025 annual report with the Ministry of Law have until the end of November 2026 before sanctions begin. The ministry's Directorate General of General Legal Administration (AHU) announced on 28 October 2026 that companies still missing the filing will receive written warnings from 1 to 31 December 2026, and that their access to the Legal Entity Administration System (SABH) will be blocked from 2 January 2027.

The schedule applies to every limited liability company, including foreign-owned PT PMA companies, under Ministry of Law Regulation (Permenkum) No. 49 of 2025. Companies had expected sanctions to start after the transition period closed at the end of October.

Minister of Law Supratman Andi Agtas had signaled the delay a day earlier at a Kompas forum in Jakarta. "Although it was supposed to end on 30 October, I have asked for it to be extended. We are aiming for the end of November, an extension of one month," he said, as reported by Kompas.

Annual report sanctions timeline

From 1 November 2026, the notarial deed recording shareholder approval of an annual report must be submitted through SABH within 30 days of the date the deed is signed.

From 1 to 31 December 2026, companies that have not submitted their 2025 annual report receive a written warning through SABH.

From 2 January 2027, companies that still have not filed have their SABH access blocked. While access is blocked, a company cannot register changes such as new directors or commissioners, share transfers, or changes to shareholder names, because AHU checks annual report status whenever those changes are filed.

From 2 January to 30 June 2027, companies file their 2026 annual report through SABH. Companies established in 2026, or whose financial year has not ended in 2026, file in the following reporting period.

How the annual report filing works

Permenkum 49/2025 took effect on 17 December 2025 and turned the annual report from an internal company document into a filing with the ministry. The board of directors presents the annual report to the annual general meeting of shareholders, after review by the board of commissioners, within six months after the end of the financial year. The shareholders' approval is then recorded in a notarial deed, and the directors, through the notary, submit it to the ministry.

The 2025 annual report is the first that companies have had to file this way, which is why AHU has run a transition period through 2026.

Government fee waived until the end of 2026

Under Permenkum 13 of 2026, the government fee for submitting an annual report approval is zero for submissions made from 1 August to 31 December 2026. The standard fee is Rp500,000 for companies that are required to be audited and Rp250,000 for those that are not. Notary fees are charged separately.

Beneficial owner reporting

The minister's remarks on 27 October also referred to beneficial owner reporting, but AHU's announcement covers annual reports only and does not set a new date for beneficial owner filings. The minister said the ministry has blocked 1.8 million inactive companies since it began cleaning up its corporate data, and that 700,000 of them remain blocked because they have not uploaded beneficial owner information.

At the same forum, Supratman said he will ask AHU to revise the verification rules for digital shareholder meetings, after business groups complained that minority shareholders were using them to block the registration of new management or share transactions.

The requirements introduced by Permenkum 49/2025, including the beneficial owner documents needed for company changes, are covered in our earlier report on annual reporting and stricter beneficial owner checks.

Emerhub handles annual shareholder approvals, annual report filings and beneficial owner updates for PT and PT PMA companies in Indonesia. Talk to our Indonesia team about corporate secretarial services.