Indonesian companies must file their approved annual reports with the Ministry of Law
Indonesia's Minister of Law Regulation No. 49 of 2025 requires limited liability companies (PT) to file their annual report, and the notarial deed of the shareholders' approval, with the Ministry of Law through its online legal entity system (SABH). The annual report goes to shareholders within six months of the financial year end, and the notary must file the deed within 30 days. The Ministry says sanctions, including blocking access, apply from November 2026.
Regulation No. 49 of 2025 covers the establishment, amendment and dissolution of limited liability companies. It replaces Regulation No. 21 of 2021 and adds a duty to file annual reports with the Ministry.
What changed
- Directors present the annual report to the general meeting of shareholders within six months of the financial year end (30 June for calendar-year companies), after the board of commissioners reviews it.
- The shareholders' approval is recorded in a notarial deed, which the notary files with the Ministry within 30 days through the SABH system, with the annual report attached.
- Sanctions: a written reprimand, then blocking of the company's access to SABH. The Directorate General of General Legal Administration (AHU) says sanctions apply from November 2026.
- The Ministry checks filing status when a company changes directors or commissioners, transfers shares or changes shareholder names.
What to do
Make sure the annual report approval is notarised and filed for each Indonesian PT before planned board or share changes.