🇮🇩 Registry4 Feb 2025
Indonesia tightens beneficial owner reporting, with annual updates and access blocks
Indonesia's Minister of Law Regulation No. 2 of 2025, in force from 4 February 2025, replaces the 2019 rules on corporate beneficial owners. Every corporation, including small businesses and civil partnerships, must update its beneficial owner information at least once a year even if nothing has changed, and notaries must complete a beneficial owner questionnaire on incorporations and amendments. Sanctions include blacklisting and blocking access to the AHU online system.
Minister of Law Regulation No. 2 of 2025 on the verification and supervision of corporate beneficial owners replaces Regulation No. 21 of 2019.
What changed
- Scope: all corporate forms, including limited liability companies (both standard and individual companies), foundations, associations, cooperatives, partnerships and, now, civil partnerships. There is no exemption for small businesses.
- Annual update: beneficial owner information must be updated at least once a year, even if unchanged, and whenever it changes.
- Notaries: must complete the beneficial owner questionnaire when establishing a corporation, amending its articles, changing its data or reporting beneficial owners.
- Verification: the Ministry, notaries and other authorities verify information on a risk basis.
- Sanctions: a reprimand, listing on a public blacklist and blocking of access to AHU Online, lifted once complete, verified information is filed. Small businesses are not blocked, but must report beneficial owners before changing their data.
What to do
Set an annual reminder to update beneficial owner information for each Indonesian entity.