Legal News Update
Contributors: Almaida Askandar, S.H., MBA, Nita Damayanti, S.H., and Rania Adhara Safira, S.H.
Published on 9 October 2026 by IABF Law Firm, Jakarta, Indonesia.
Reminder to Business Entities to File Annual Reports with
the Minister of Law by 31 October 2026
Further to our 7 March 2026 client update entitled “New Compliance Requirement in Indonesia: Mandatory Annual Report Filing for All Limited Liability Companies”, this update serves as a reminder to business entities established as limited liability companies to complete the notification of their annual report approval to the Minister of Law no later than 31 October 2026. This update also outlines the implementation of the annual report filing requirement under Minister of Law Regulation No. 49 of 2025, including the applicable administrative sanctions, blocking of SABH access, reopening procedures, and relevant PNBP tariffs.
Minister of Law Regulation No. 49 of 2025 on Requirements and Procedures for the Establishment, Amendment, and Dissolution of Limited Liability Company Legal Entities (“Regulation 49/2025”) requires limited liability companies established as a capital partnership to submit the approval of their annual reports to the Minister of Law through the Legal Entity Administration System (Sistem Administrasi Badan Hukum or “SABH”).
This requirement does not apply to individual limited liability companies (perseroan perorangan) for micro and small enterprises. These companies are subject to a separate obligation to submit financial statements to the Minister of Law through SABH, under Government Regulation No. 8 of 2021 on Authorised Capital of Companies and the Registration of Establishment, Amendment, and Dissolution of Companies that Satisfy the Criteria for Micro and Small Enterprises.
Pursuant to Articles 66 and 67 of Law No. 40 of 2007 on Limited Liability Companies, as amended by Law No. 6 of 2023 on the Stipulation of Government Regulation in Lieu of Law No. 2 of 2022 on Job Creation into Law (“Company Law”), and Regulation 49/2025, the board of directors must submit the annual report, signed by all members of the board of directors and the board of commissioners, to the General Meeting of Shareholders (“GMS”) after review by the board of commissioners, no later than 6 (six) months after the end of the relevant financial year. For companies with a financial year ending on 31 December, the GMS approving the 2025 annual report should therefore have been held by 30 June 2026. The GMS approval must be recorded in a notarial deed and notified to the Minister by the board of directors through the appointed notary, electronically through SABH, within 30 (thirty) days from the signing date of the relevant notarial deed.
The Directorate General of General Legal Administration (“DG AHU”) has made the SABH reporting service available. Based on the applicable implementation provisions, companies are given until 31 October 2026 to complete the notification of the GMS approval of their annual report for the 2025 financial year, and administrative sanctions are expected to be operationalised from 1 November 2026. As 31 October 2026 falls on a Saturday and SABH services may be temporarily unavailable on weekends, public holidays, or outside working hours, companies are advised to complete their filing no later than Friday, 30 October 2026. Companies that have not completed their annual report filing for the 2025 financial year should therefore use the remaining transition period to regularise their position.
Key Deadline and Recommended Actions
To avoid a written warning and the subsequent blocking of SABH access, companies that have not completed the notification of their 2025 annual report approval are advised to take the following steps before 31 October 2026:
- ensure that the 2025 annual report has been prepared, reviewed by the board of commissioners, and signed by all members of the board of directors and the board of commissioners (Articles 66 and 67 of the Company Law);
- convene a GMS or adopt a circular shareholders’ resolution in lieu of a GMS (Article 91 of the Company Law) to approve the annual report, if this has not been done;
- have the GMS resolution set out in a notarial deed and instruct the notary to submit the notification through SABH no later than 30 (thirty) days from the signing date of the deed and, in any event, before 31 October 2026;
- make use of the zero tariff for notifications of annual report approvals available until 31 December 2026; and
- retain the SABH proof of submission and monitor SABH notifications and the company’s registered e-mail address for any written warning from the DG AHU.
Administrative Sanctions
Articles 17 to 20 of Regulation 49/2025 establish a staged sanction mechanism for companies that fail to fulfil the annual report notification requirement or exceed the applicable submission deadline, which, for the 2025 financial year, is expected to apply to companies that have not completed their filing by 31 October 2026. First, the company may receive a written warning. The warning may be delivered through a notification in SABH and/or by electronic mail. If the company does not fulfil its obligation within 30 (thirty) days after the warning notification, the Minister, through the DG AHU, may impose an administrative sanction in the form of blocking the company’s SABH access.
The blocking sanction is particularly significant because SABH is the principal electronic system used to process a range of corporate legal entity administration matters. Consequently, a blocked company may encounter difficulties in carrying out corporate actions requiring SABH access, including amendments to its articles of association and notifications of changes to corporate data, such as changes to directors, commissioners, shareholders, or share ownership composition. Importantly, the blocking of SABH access is not imposed immediately upon the first instance of late filing. Regulation 49/2025 requires a written warning to be issued first, followed by a 30-day period for the company to fulfil its outstanding obligation.
Reopening of SABH Access
A company whose SABH access has been blocked may apply for the reopening of access through SABH. The application must be submitted to the DG AHU by completing the prescribed reopening form and uploading the relevant supporting documents, namely:
- the notarial deed containing the GMS approval of the annual report; and
- the annual report of the company.
The DG AHU will reopen SABH access after the application has been received and declared complete. Accordingly, payment of the applicable tariff alone does not cure the non-compliance; the company must also complete the outstanding annual report notification.
PNBP Tariffs
Government Regulation No. 30 of 2026 on Types and Tariffs of Non-Tax State Revenue Applicable to the Ministry of Law (“GR 30/2026”), which has been effective since 1 August 2026, introduces tariffs for the relevant SABH services.
The normal tariff for reopening blocked SABH access is:
- IDR2,000,000 per application for a company required to be audited by a public accountant; and
- IDR1,000,000 per application for a company that is not required to be audited by a public accountant.
In addition, Minister of Law Regulation No. 13 of 2026 currently grants a zero tariff for notifications of annual report approvals submitted from 1 August 2026 until 31 December 2026. This temporary relief applies to both companies required to be audited and companies that are not required to be audited. The zero tariff does not include notarial fees or other professional fees that may be charged in connection with the preparation of the annual report, GMS documentation, and notarial deed.
***
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.
