A New Annual Reporting Obligation PT PMA Owners Should Know in 2026
If your company’s financial year ended on 31 December 2025, you may already be preparing your financial statements, tax filings, and annual corporate documents.
But there is another important corporate compliance matter that PT owners should not overlook:
THE ANNUAL REPORT OF THE COMPANY
Under Indonesian company law, the Board of Directors is required to prepare an annual report and present it to the Annual General Meeting of Shareholders (RUPS) within a maximum of six months after the company’s financial year ends. The annual report includes the company’s financial statements and other corporate information.
And from 2026, the reporting process has become more significant.
WHAT HAS CHANGED?
The Ministry of Law issued Minister of Law Regulation No. 49 of 2025 (Permenkum 49/2025) concerning the requirements and procedures for the establishment, amendment, and dissolution of limited liability companies.
The regulation took effect in December 2025 and introduced a more formal mechanism for reporting the approval of the company’s annual report to the Minister through the Legal Entity Administration System (SABH).
This is particularly important for PT PMA owners who may have previously treated the annual report and RUPS as purely internal corporate documents.
They should no longer be treated that way.
WHAT DOES THIS MEAN FOR YOUR PT PMA?
For a PT PMA operating with a financial year ending on 31 December 2025, the company should generally prepare its 2025 annual report, have it reviewed by the Board of Commissioners, and submit it to the Annual RUPS within six months after the end of the financial year.
That means the normal statutory deadline falls on:
30 JUNE 2026
if the company’s financial year ends on 31 December 2025.
But there is another step.
Following RUPS approval, the approval must be documented in a notarial deed and submitted to the Minister through a notary via SABH within 30 days from the date the notarial deed is signed. The filing includes the notarial deed and the annual report.
WHAT IS INCLUDED IN THE ANNUAL REPORT?
The annual report is more than a simple profit-and-loss statement.
Under the applicable company-law framework, it includes financial statements consisting at least of:
- Balance sheet / statement of financial position
- Income statement
- Cash flow statement
- Statement of changes in equity
- Notes to the financial statements
The annual report also contains information concerning the company’s activities, corporate social and environmental responsibility where applicable, significant problems affecting the business, the supervisory activities of the Board of Commissioners, and information concerning the Directors and Commissioners.
YOUR FINANCIAL STATEMENTS SHOULD BE READY
A professional annual financial statement should normally provide a clear picture of the company’s financial position.
At minimum, the core financial statements include:
01 — BALANCE SHEET
Shows the company’s assets, liabilities, and equity.
02 — PROFIT & LOSS STATEMENT
Shows revenue, expenses, and the resulting profit or loss.
03 — CASH FLOW STATEMENT
Shows how cash moved into and out of the company.
04 — STATEMENT OF CHANGES IN EQUITY
Shows changes in shareholders’ equity during the financial year.
05 — NOTES TO THE FINANCIAL STATEMENTS
Provides important explanations and supporting information.
These are not simply documents for an accountant.
They form part of the company’s annual corporate reporting.
RUPS IS PART OF THE PROCESS
A common misconception is:
“We already prepared our financial statements, so we are finished.”
Not necessarily.
The annual report should be presented to the Annual General Meeting of Shareholders (RUPS) for approval.
The RUPS is therefore an important part of the annual corporate governance cycle.
The process can be understood as:
FINANCIAL YEAR ENDS
↓
FINANCIAL STATEMENTS PREPARED
↓
ANNUAL REPORT PREPARED
↓
REVIEW BY COMMISSIONERS
↓
ANNUAL RUPS
↓
SHAREHOLDERS APPROVE ANNUAL REPORT
↓
NOTARIAL DEED
↓
SUBMISSION THROUGH SABH
This is the corporate compliance chain.
IS THIS THE SAME AS YOUR TAX RETURN?
No.
This is extremely important.
A company may have already submitted its Corporate Income Tax Return (SPT Tahunan Badan) and still have separate corporate reporting obligations.
The following should not automatically be treated as the same thing:
| Obligation | Main Purpose |
|---|---|
| Financial Statements | Report the company’s financial position and performance |
| Annual Corporate Report | Corporate accountability and governance |
| Annual RUPS | Shareholder approval and corporate accountability |
| SPT Tahunan Badan | Tax reporting |
| LKPM | Investment activity and realization reporting |
| SABH Annual Report Submission | Corporate legal administration |
One filing does not automatically replace another.
WHAT ABOUT LKPM?
For PT PMA, there is another important distinction.
LKPM is not the same as the company’s financial statements.
LKPM is an investment activity report submitted through the investment licensing system.
BKPM has specifically reminded businesses that LKPM is a mandatory obligation and that late or inaccurate reporting can lead to warnings and potentially administrative sanctions, including NIB revocation.
Therefore, PT PMA compliance should be viewed as a system of connected obligations rather than a single annual filing.
DOES EVERY COMPANY NEED AN AUDIT?
Not necessarily.
The requirement for an independent audit depends on the company and the applicable legal criteria.
Under the Company Law framework, certain companies are required to submit their financial statements for audit, including specified categories such as publicly held companies and companies meeting certain asset or revenue thresholds, among others.
Therefore:
Financial statements ≠ automatically audited financial statements.
The company should first determine whether an audit is legally required based on its circumstances.
WHAT HAPPENS IF YOUR COMPANY DOES NOTHING?
The new reporting mechanism makes this issue more important.
Permenkum 49/2025 provides administrative consequences for failure to fulfill the annual-report submission requirements, including written warnings and blocking of access to SABH.
Why does SABH access matter?
Because the system is used for important corporate legal administration.
If access is restricted, the company may face difficulties when it needs to process future corporate actions.
For example, a company may later need to:
- Change its shareholders
- Change Directors or Commissioners
- Amend its Articles of Association
- Change company data
- Carry out other corporate actions
A compliance issue that began with an annual reporting obligation can therefore become an operational inconvenience later.
“MY COMPANY HAS NO PROFIT. DO I STILL NEED TO REPORT?”
A company should not assume that having no profit means it has no annual corporate reporting obligation.
A company can have:
ZERO PROFIT
LOW REVENUE
or even
NO SIGNIFICANT BUSINESS ACTIVITY
and still have corporate obligations arising from its status as a PT.
The important question is not simply:
“Did the company make money?”
The question is:
“What corporate and regulatory obligations apply to this company?”
“MY PT PMA IS DORMANT. DOES THAT MEAN NOTHING NEEDS TO BE DONE?”
This is another common misconception.
A dormant or minimally active company may still have:
- Corporate administration
- Tax obligations
- Annual corporate reporting
- RUPS obligations
- Investment reporting obligations where applicable
- Licensing obligations
- Immigration considerations where applicable
Dormant does not automatically mean exempt.
The specific obligations depend on the company’s legal and operational circumstances.
WHY FOREIGN INVESTORS SHOULD PAY ATTENTION
For a foreign shareholder, corporate compliance is particularly important because the company is often part of a larger investment structure.
The investor may need the company for:
Investment
Business Operations
Employment
Property or Lease Arrangements
Licensing
Banking
Future Expansion
Business Sale
Dividend Distribution
Exit Planning
A company with incomplete corporate records can create additional work when the investor wants to make a significant corporate transaction.
THE 2025 FINANCIAL YEAR CHECKLIST
If your PT PMA’s financial year ended on 31 December 2025, consider reviewing the following:
FINANCIAL STATEMENTS
☐ Balance sheet
☐ Profit & loss statement
☐ Cash flow statement
☐ Statement of changes in equity
☐ Notes to financial statements
CORPORATE REPORTING
☐ Annual report prepared
☐ Directors’ report
☐ Commissioners’ review
☐ Annual RUPS
☐ Shareholders’ approval
LEGAL DOCUMENTATION
☐ RUPS documentation
☐ Notarial deed where required
☐ SABH submission
☐ Corporate records updated
TAX
☐ Corporate tax return
☐ Tax reconciliation
☐ Tax payment obligations
☐ Supporting tax documentation
INVESTMENT COMPLIANCE
☐ LKPM
☐ Investment realization records
☐ Business activity consistency
☐ Licensing consistency
DON’T WAIT UNTIL YOU NEED A CORPORATE CHANGE
One of the worst times to discover incomplete corporate compliance is when you urgently need to make a corporate change.
For example:
You want to bring in a new investor.
You want to sell shares.
You want to change your Director.
You want to expand the business.
You want to add a new KBLI.
You want to open a new location.
You want to restructure the company.
And then you discover:
Your annual reporting is incomplete.
This is why annual compliance should be maintained before the company needs it.
PMADOCTOR CORPORATE HEALTH CHECK
Is Your PT PMA’s 2025 Reporting Complete?
PmaDoctor can help review your company’s annual corporate compliance position, including:
Financial Statements
Annual Report
RUPS
Corporate Documents
SABH Filing
Tax Compliance
LKPM
Business Licensing
KBLI
The objective is simple:
KNOW WHAT IS COMPLETE.
KNOW WHAT IS MISSING.
KNOW WHAT NEEDS TO BE FIXED.
2026 IS THE YEAR TO CLEAN UP YOUR CORPORATE FILES
If your company has been operating for several years, this is a good time to review the company’s complete corporate history.
Do not only ask:
“Do we have an NIB?”
Also ask:
“Are our corporate records, financial statements, annual reports, RUPS, licensing, tax, and investment reporting properly maintained?”
A healthy company is not simply a company that exists.
It is a company whose legal, financial, licensing, and compliance records are properly maintained.
THE PMADOCTOR PRINCIPLE
YOUR FINANCIAL STATEMENTS ARE MORE THAN NUMBERS.
They are part of your company’s corporate record.
Your annual report is part of your corporate accountability.
Your RUPS documents your shareholders’ approval.
And your SABH filing forms part of the company’s legal administration.
KEEP THEM ALIGNED.
IS YOUR PT PMA READY FOR 2026?
If your company has not yet reviewed its 2025 financial statements, annual report, RUPS, and corporate reporting, now is the time to check the status.
Don’t wait until you need to make a corporate change.
CHECK YOUR COMPANY BEFORE THE SYSTEM CHECKS YOU.
[ CHECK MY PMA NOW ]
[ BOOK A PMA HEALTH CHECK ]
PMADOCTOR
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