New Rules for Annual Company Reports Through AHU

The Indonesian Government has issued a new regulation introducing important changes for all limited liability companies (PT), including Foreign Investment Companies (PT PMA). Under the latest provisions, companies are now required to submit an Annual Company Report through the General Legal Administration System (AHU), which includes annual financial statements approved by the shareholders.

This regulation aims to enhance transparency and accountability and ensure that company records maintained by the Ministry of Law remain accurate and up to date.

What Has Changed?

Under Minister of Law Regulation No. 49 of 2025, every company is required to submit an Annual Company Report through the AHU system. The new requirements include submitting beneficial ownership documents, mandating the upload of supporting documents, evaluating corporate amendment applications, and filing annual reports.

As part of this process, the company’s annual report must first be approved through a General Meeting of Shareholders (GMS) and formalised in a notarial deed.

As a result, the preparation of annual company reports is no longer merely an internal corporate matter but has become part of the company’s reporting obligations to the government.

Who Is Required to Submit the Report?

This obligation applies to all companies, including:

• Foreign Investment Companies (PT PMA)
• Domestic Limited Liability Companies (PT)
• Active operating companies
• Non-operational companies
• Companies with no revenue (zero revenue)

This means that even if a company has not yet commenced operations or generated any income, it is still required to comply with the reporting obligation.

What Needs to Be Prepared?

In accordance with Article 16 of the Minister of Law Regulation No. 49/2025, companies must undertake the following steps:

1. Prepare the company’s annual report.
2. Hold a General Meeting of Shareholders (GMS).
3. Record the GMS resolutions in a notarial deed.
4. Submit the Annual Company Report through the Legal Entity Administration System (SABH).

Pursuant to Article 16, paragraph (6), the annual report must contain at least:

• Financial statements;
• Company activity report;
• Report on the implementation of corporate social and environmental responsibility;
• Details of issues affecting business operations;
• Supervisory report of the Board of Commissioners;
• Names of members of the Board of Directors and Board of Commissioners; and
• Information regarding salaries, honorariums, and allowances of Directors and Commissioners.

As this process involves legal and corporate administrative aspects, it is important to ensure that all documents are properly prepared and compliant with the applicable regulations.

When Must the Annual Report Be Submitted?

In addition to fulfilling the documentary requirements, companies must also observe the deadlines stipulated under Minister of Law Regulation No. 49/2025.

According to Article 16 paragraph (1), the annual report must be submitted by the Board of Directors to the General Meeting of Shareholders no later than six (6) months after the end of the company’s financial year.

Furthermore, once the annual report approval has been formalised in a notarial deed, the notary must submit it to the Minister through SABH within thirty (30) days of signing the deed, as stipulated in Article 16, paragraph (3).

Therefore, companies should prepare their annual reports and conduct their GMS on time to avoid delays in fulfilling these obligations.

Why Is This Important?

Annual reporting is an essential component of good corporate governance. In addition to ensuring regulatory compliance, orderly reporting helps companies maintain their legal status and avoid potential administrative issues in the future.

For PT PMA owners and foreign investors, compliance with this obligation is an important aspect of maintaining business continuity and a good relationship with government authorities.

What Are the Risks of Non-Compliance?

Companies should pay close attention to reporting deadlines because, under Article 17 paragraph (1) of the Minister of Law Regulation No. 49/2025, companies that fail to submit, or submit late, approval of their annual reports may be subject to administrative sanctions.

According to Article 17, paragraph (2), these sanctions may include:

• Written warning; and/or
• Suspension of access to the SABH system.

Furthermore, Article 18 paragraph (1) stipulates that written warnings will be delivered through SABH notifications and/or email. If the company still fails to fulfil its obligation within thirty (30) days after receiving the warning, it may be subject to SABH access suspension as provided under Article 18, paragraphs (2) and (3).

Therefore, compliance with annual reporting obligations is important not only from a corporate governance perspective but also to ensure the smooth administration and legal standing of the company in the future.

What Should Companies Do Now?

Companies are advised to immediately review their administrative compliance status and ensure that their annual financial statements have been prepared in accordance with the current financial year.

If the financial statements have not yet been prepared or the General Meeting of Shareholders has not yet been conducted, companies should begin preparing these processes as early as possible.

Given that this regulation applies to all companies, including inactive companies, shareholders and directors should understand these new obligations and take the necessary steps to ensure compliance.

Conclusion

Minister of Law Regulation No. 49 of 2025 marks a significant step forward in enhancing corporate transparency and governance in Indonesia. With the introduction of mandatory annual financial reporting through the AHU system, companies must pay greater attention to their administrative and legal compliance obligations.

Ensuring that all required processes are carried out correctly from the outset will help companies avoid future complications while maintaining their business reputation and legal standing on an ongoing basis.

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