Imagine this: you submit your tax reports on time, pay your taxes, and run your business as usual. Then, some time later, you find out that your company’s access to the government system has been blocked. You cannot change the director, amend the articles of association, or register corporate decisions.
The reason is the failure to submit an annual corporate report, a requirement many business owners are not even aware of.
From 2026, this scenario becomes entirely possible. We explain what has changed, who the new requirements apply to, and what consequences companies may face if they ignore this obligation.
The Report Already Existed. What Has Changed Is the Control Mechanism
The company annual report (Laporan Tahunan) has been required under Article 66 of the Company Law (UU 40/2007 as amended by UU 6/2023) for many years. Traditionally, this document was an internal corporate document: it was prepared by the directors, reviewed by the Board of Commissioners, and then approved by the shareholders at the annual general meeting (RUPS).
However, with the adoption of Permenkum 49/2025, the procedure has changed. Information on the approved annual report must now be submitted to the government SABH system through a notary. In practice, an internal corporate document has become a mandatory filing subject to government control, with penalties for missing the deadline.
Key Deadlines to Keep in Mind
The following deadlines currently apply:
- submissions through the SABH system start on 1 June 2026;
- the annual report must be approved by the shareholders within six months after the end of the financial year;
- for the 2025 report, the deadline for holding the RUPS is 30 June 2026;
- the notarial deed must be submitted to the SABH system within 30 days after signing;
- penalties will start to apply from November 2026.
At the time of publication, no official extension of the deadlines has been provided. It is also important to remember that this is not a one-off obligation: the report must be prepared and submitted every year.
What Happens If the Report Is Not Submitted
This is where the main risk for businesses arises.
If the deadline is missed, the company receives an official warning through the SABH system and by email. If the report is still not submitted within 30 days of the notification, the company’s access to SABH is blocked.
In practice, this means the company will be unable to:
- register a change of director or commissioner;
- amend the company’s articles of association;
- register changes in the shareholder structure;
- register other corporate decisions through the state register.
The company continues to exist and operate, but most legally significant corporate actions become unavailable until the breach is remedied.
Who This Obligation Applies To
Almost all companies established as PT are required to submit an annual report.
The requirement applies both to PT PMA companies with foreign investment and to PT PMDN local companies.
Revenue, profit, or actual business activity do not matter. Even if the company did not operate or generate income during the year, the obligation to prepare and approve the report remains.
The only exception concerns the section on social and environmental responsibility (CSR/TJSL). This section must be included by companies operating in the natural resources sector.
What the Annual Report Must Include
Under the law, the annual report includes:
- annual financial statements;
- a report on the company’s activities;
- a report on social and environmental responsibility, if applicable;
- information on significant issues and risks that arose during the year;
- the Board of Commissioners’ report on supervisory activities;
- information on the directors and commissioners;
- information on the remuneration of the directors and commissioners.
The last point often raises questions from business owners, but it is a direct legal requirement.
Is an Audit Mandatory?
For most companies, a mandatory audit is not required.
Under Article 68 of the Company Law, an audit is mandatory only for certain categories of businesses, including:
- companies that collect or manage public funds;
- bond issuers;
- public companies (Tbk);
- state-owned enterprises (Persero);
- companies with assets or annual turnover of at least IDR 50 billion;
- companies for which an audit is required under specific laws or regulations.
It is important to understand that an audit is not the same as a tax inspection. It is an independent review of financial statements carried out by an external audit firm. Tax control is conducted separately and is governed by different procedures.
Why This Is Not the Same as a Tax Return
One of the most common mistakes is to assume that submitting tax reports automatically fulfils all of the company’s obligations.
In practice, these are two different requirements.
The annual report (Laporan Tahunan) is submitted through the SABH system to the Ministry of Law and reflects the company’s corporate activities.
The tax return (SPT Tahunan Badan) is submitted to the tax authority and relates solely to tax obligations.
Submitting one document does not replace submitting the other. Therefore, even a company that has submitted all tax reports on time may still face penalties for failing to submit the annual corporate report.
What Businesses Should Do Now
If your company has not yet prepared its annual report for 2025, it is worth checking in advance which documents will be required to hold the RUPS and subsequently submit the information to SABH. Taking into account corporate procedures, notarial formalities, and the possible need for an audit, preparation may take several weeks.
Legal Indonesia supports clients at every stage of preparing and submitting the annual report: from reviewing the requirements and preparing documents to liaising with the notary and registering the report in the SABH system.
If you are not sure whether the new requirement applies to your company, whether an audit is needed, or which documents must be prepared, contact Legal Indonesia. We will help assess the situation, meet the deadlines, and avoid restrictions related to blocked access to SABH.
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