Indonesia’s Directorate General of General Legal Administration (AHU) under the Ministry of Law is preparing to impose administrative sanctions on limited liability companies (PTs) that fail to submit the notarial deed approving their annual report through the Legal Entity Administration System/SABH.
The move is part of the government’s effort to strengthen corporate compliance and ensure that annual report approvals are formally reported through the proper legal channels.
Companies are being given a transition period until December 31, 2026 to fulfil the reporting requirement.
According to AHU, companies that have not yet met their reporting obligations will first receive written warnings through notifications in the Legal Entity Administration System/SABH system between December 1 and December 31, 2026.
Following the warning period, companies that remain non-compliant may face stricter measures. Access to the Legal Entity Administration System/SABH system is scheduled to be blocked starting January 2, 2027 for companies that fail to submit their annual report approval.
“Administrative sanctions in the form of written warnings will be imposed from December 1 to December 31, 2026, while access to the Legal Entity Administration System will be blocked starting January 2, 2027, for limited liability companies that have not fulfilled their obligation to submit their 2025 Annual Report,” AHU said in a statement on Wednesday (October 28).
Holding an AGMS Alone Is No Longer Enough
Under Indonesia’s Company Law (Law No. 40 of 2007), every limited liability company is required to hold an Annual General Meeting of Shareholders/AGMS (or in Bahasa it’s Rapat Umum Pemegang Saham/RUPS) no later than 6 months after the end of its financial year.
However, AHU emphasized that holding the meeting alone is not sufficient to satisfy the reporting requirement.
In addition to conducting an AGMS, companies must ensure that approval of the annual report is formally documented in a notarial deed and submitted to the Ministry of Law through SABH in accordance with the applicable regulations.
Simply holding the meeting and keeping the minutes as an internal company document does not fulfil the obligation.
Under Minister of Law Regulation No. 49 of 2025, companies that fail to submit approval of their annual report may face administrative sanctions ranging from written warnings to restrictions on access to the Legal Entity Administration System/SABH.
To avoid penalties, companies should ensure that their directors have prepared an annual report containing information on business activities, financial performance, and other disclosures required by law.
The report must then be approved by shareholders through an AGMS, documented in a notarial deed, and submitted through SABH together with all required supporting documents and information before the applicable deadline.
Source: HukumOnline, IKPI
