NOTICE REGARDING THE OBLIGATION TO SUBMIT THE COMPANY’S ANNUAL REPORT
News |
05 Sep 2026
Written by
Omnilegal Team
The Ministry of Law, Directorate General of General Legal Administration, has announced the obligation of the company to submit Annual Report to the Minister of Law regarding the implementation of the Minister of Law Regulation No.49 of 2025 concerning Procedures for the Establishment, Amendment, and Dissolution of Limited Liability Company.
A. Submission of the Annual Report
The Company is required to submit the Company’s Annual Report, which has been approved by the Company’s Annual General Meeting of Shareholders (AGMS) and recorded in a notarial deed, to the Minister of Law (“MOL”) through the Legal Entity Administration System (Sistem Administrasi Badan Hukum/SABH) within 30 days from the date of the notarial deed.
The obligation to submit the Annual Report takes effect on 1 June 2026.
The documents that must be submitted to the SABH are as follows:
The notarial deed regarding the approval of the company’s annual report; and
The Annual Report.
The MOL will issue a Letter of Receipt of Annual Report Submission for the Annual Report that has been submitted.
B. Parameters for Audit Obligations by Public Accountants
The company’s financial statements must be audited by a public accountant if the company’s meets any of the following criteria:
The company engages in business activities involving the collection and/or management of public funds;
The company issues debt instruments to the public;
Publicly Listed Company (Tbk);
State-Owned Enterprise;
Assets and/or total business turnover exceeding 50 billion Rupiah; or
Required by law.
C. Non-Tax State Revenue (PNBP)
The service for submitting Annual Reports is not subject to PNBP fees until the new Government Regulation on PNBP is enacted.
D. Administrative Sanctions
The company that fails to submit or has missed the deadline for the General Meeting of Shareholders to approve the Annual Report may be imposed to administrative sanctions in the form of a Written Warning and Access Block of SABH.
IMPORTANT NOTES
The Annual Report must be signed by all members of the Board of Directors and all members of the Board of Commissioners. If any member of the Board of Directors or the Board of Commissioners does not sign the Annual Report, they must provide a written explanation;
Regarding the AGMS recorded in a notarial deed, notwithstanding that the deed has surpassed its 30-day statutory period, in the meantime the notarial deed is still valid for the submission of the company's Annual Report;
Administrative sanctions will be imposed starting November 2026 if the company fails to submit the Annual Report or missed the deadline for submitting the Annual Report.
