Investment Coordinating Board or Badan Koordinasi Penanaman Modal (“BKPM”) issued Head of BKPM Regulation Number 5 of 2025 on Guidelines and Procedures for Processing Risk-Based Business Licensing and Investment Facilities through the Online Single Submission System (“BKPM Regulation 5/2025”) on 1 October 2025. In general, BKPM Regulation 5/2025 stipulates the regular monitoring activity, including to check the report that is submitted by the business actor. According to Article 284 (1) and (4) of BKPM Regulation 5/2025, the respective monitoring activity consists of, inter alia, the realization development and compliance of investment obligation that is submitted by the business actor in the investment activity report or laporan kegiatan penanaman modal (“LKPM”) through the Online Single Submission system.
I. Obligation to Submit LKPM
All business actors are required to submit the LKPM. Notably, BKPM Regulation 5/2025 introduces a key change to the categories of business actors that are exempt from this obligation. Under the previous regime, namely Article 32 paragraph (5) of BKPM Regulation No. 5 of 2021, the obligation to submit LKPM did not apply to:
- micro-scale business actors; and
- those operating in certain sectors, including upstream oil and gas, banking, non-bank financial institutions, and insurance.
This position has now shifted. Pursuant to Article 286 paragraph (2) of BKPM Regulation 5/2025, the exemption is significantly narrowed, such that it now applies only to:
- micro-scale business actors; and/or
- business activities funded by the state budget (Anggaran Pendapatan dan Belanja Negara/APBN) or regional budget (Anggaran Pendapatan dan Belanja Negara/APBD).
As a result, business actors that were previously exempt, particularly those in sectors such as upstream oil and gas, banking, non-bank financial institutions, and insurance, are now required to submit LKPM in accordance with the applicable reporting deadlines set out in Section III below.
II. Data Listed in the LKPM
Article 285 and (1) and (2) of BKPM Regulation 5/2025 states that the obligation to comply with the LKPM provision is applicable to each location and business activity either the main business activity and/or the supporting business activity. Article 285 (3) and (4) of BKPM Regulation 5/2025 specifies the following data that shall be listed in the LKPM:
- the investment realization;
- workforce realization;
- goods and/or services production realization;
- fulfilment of basic requirements, business licensing, and/or supporting business licenses;
- obstacles faced by business actor; and
- fulfilment of the obligations and responsibilities of investment business actor, which shall cover the fulfilment of the following activities:
- the training for Indonesian worker and/or training and transfer of technology to the colleague of Indonesian worker;
- partnership;
- environmental management;
- implementation of good corporate governance principles;
- employment;
- implementation of worker safety, health, comfort, and welfare;
- and/or corporate social responsibility.
III. The Period of LKPM Submission
| No. | Period of LKPM Submission |
| 1. | The period LKPM submission for small scale business activity:
a) 1st semester report: at the latest on 15 July of respective year, and b) 2nd semester report: at the latest on 15 January of the following year. |
| 2. | The period LKPM submission for medium and large scale business activities:
a) 1st quarter report: at the latest on 15 April of respective year, b) 2nd quarter report: at the latest on 15 July of respective year, c) 3rd quarter report: at the latest on 15 October of respective year, and d) 4th quarter report: at the latest on 15 January of the following year. |
| 3. | The LKPM submission for medium and large scale business activities consist of:
a) the report on the preparation stage → for business which has no active operational activity and/or conducts commercial transaction; and b) the report on the operation and/or commercial stage(s) → for business which actively conducts operational activity and/or conducts commercial transaction. |
IV. Sanctions
Failure to comply with the LKPM submission obligation may result in the imposition of administrative sanctions, which may include:
- written warnings;
- temporary suspension of business activities;
- administrative fines;
- government enforcement measures;
- revocation of licenses, certifications, and/or approvals; and/or
- revocation of basic requirements, business licenses, and/or supporting business licenses.
In light of the upcoming reporting deadlines, business actors are advised to ensure timely and accurate submission of LKPM to maintain compliance with the prevailing regulations.
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Disclaimer:
This news update is prepared for general informational purposes only. The content does not constitute legal advice, a legal opinion, or counsel from IABF Law Firm. The information contained herein may not reflect the most current developments. Any quotation, distribution, or use of this information for any purpose is solely at the user’s own risk.
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Published by: IABF Law Firm
Published on: 3 April 2026
