BKPM Strengthened Control over LKPM: 'Zero' Reporting Now a Risk Zone for Businesses
At the end of 2025, the Indonesian Ministry of Investment (BKPM) once again clearly stated: LKPM reporting is not a formality, but a corporate obligation. Failure to submit reports or regular 'zero' results may result in administrative measures—from warnings to suspension of activities and even revocation of permits. The issue is particularly relevant in anticipation of the reporting window for the fourth quarter of 2025.
What is LKPM and why it is important for the state
LKPM (Laporan Kegiatan Penanaman Modal) is a report on the company's investment activities. It is submitted through the OSS-RBA system.
For BKPM, this report is the main control tool. It shows that the company is actually operating, implementing investments, and fulfilling declared plans, and not existing only 'on paper'.
When sanctions are possible
In practice, the risk of sanctions arises in several typical situations:
the company does not submit LKPM for two consecutive reporting periods;
after the first submission of LKPM, the company shows zero investment realization for four consecutive periods;
the company is in the construction stage, but shows zero investment realization for four consecutive reporting periods.
Specific clarifications directly emphasize: a systematic '0' at the construction stage is considered by BKPM as an alarming signal.
What sanctions are applied
A phased approach is applied.
First, the company receives written warnings. Usually, several in sequence.
After that, supervision may be intensified. Possible work restrictions through OSS, suspension of part of the activities or operations.
In some cases, measures reach the cancellation or revocation of permits and licenses.
It is important to note: sanctions do not always mean a fine. Often, marks of violation, notifications, and restrictions in OSS first appear. They complicate any changes to licenses and increase the likelihood of inspections.
Why 'zero realization' is dangerous even for actually operating companies
Such a situation is often encountered: the company conducts activities, incurs expenses, builds or prepares for operation, but reflects '0' in LKPM.
This happens when:
it is not entirely clear what should be considered as investment realization;
there are no explanations in the comments to LKPM;
the stage is incorrectly indicated (construction instead of production/operation or vice versa);
progress is not described and no supporting data is attached.
Regional explanations note: if the project is in the construction stage, it is not advisable to leave '0' for four consecutive periods. It is better to accurately reflect the project's progress and provide explanations.
Reporting times: what to focus on
The next reporting window is for the fourth quarter of 2025.
In practice, OSS often sets the submission deadline between January 1 and 10, 2026. However, it is necessary to focus on notifications in your OSS account and the requirements set for the specific business category.
What companies should do right now
Check whether the company is required to submit LKPM and how often.
Check if there are any skips for two consecutive reporting periods.
If the report shows 'zero' investment realization:
clarify whether all expenses and capital investments are reflected correctly,
check the correctness of the project stage,
add explanations to the data.
Reconcile internal data: accounting, payments, contracts, acts.
It is important that the figures in the report can be confirmed.
If changes to licenses or data in OSS are planned, LKPM should be made a priority. Noted violations may slow down these processes.
Conclusion
Control over LKPM is being strengthened. The report in the Indonesian Ministry of Investment is no longer considered a formality. Timely and accurate submission of LKPM reduces the risk of sanctions and restrictions.
Checking your report now is easier than restoring it under regulatory pressure.
