Taxes Aren't Everything: The Annual Report That Can Get Your PT Blocked
Picture this: you filed your tax return on time, paid everything due, and carried on with business as usual. A couple of months later you find out that your company's access to the government system is blocked. You can't replace a director, amend the articles of association, or register a single change. The reason is an unfiled annual corporate report you may never have heard about.
As of 2026, this is a realistic scenario. Below we explain what this report is, the deadlines and penalties attached to it, and how to avoid ending up in this situation.
The report isn't new, but the enforcement is
The annual report (Laporan Tahunan) has existed in Indonesian law for a long time. It comes from Article 66 of the Company Law (UU 40/2007, as amended by UU 6/2023). It used to be essentially an internal document: the directors prepared it, the Board of Commissioners reviewed it, and the general meeting of shareholders (RUPS) approved it. That was the end of it.
One thing changed, and it matters. A regulation from the Minister of Law (Permenkum 49/2025) made filing the report into the government system, SABH, mandatory. The RUPS approval of the report is now recorded in a separate notarial deed, and the notary submits the information to SABH electronically. What used to be paperwork for your own files has become formal reporting with oversight and penalties.
How much time you have
Keep these deadlines in mind ahead of time:
SABH filing goes live on June 1, 2026.
The annual report must be put to the RUPS for approval within six months of the end of the financial year. For the 2025 report, that means a deadline of June 30, 2026.
The notarial deed approving the report is submitted through the notary within 30 days of the date it is signed.
Penalties start being applied from November 2026.
As of this writing, there has been no official decision to extend the deadlines, so it is not wise to count on a delay. One more point people often miss: this is not a one-time exercise. The report has to be filed every year.
What happens if you simply don't file
This is where the real risk sits. When a company misses the deadline, a written warning appears in the SABH system and is also sent by email. If the report is still not filed within 30 days of that notification, the company's access to SABH is blocked. This is set out directly in Articles 17 and 18 of Permenkum 49/2025.
A blocked account means corporate actions grind to a halt. You won't be able to replace a director. The system also won't let you amend the articles of association or register changes to the founding documents. The company keeps existing, but any formal step through the government registry is closed off until you clear the outstanding report.
Does this apply to your company
Most likely, yes. The obligation covers all PT companies with share capital: both PT PMA with foreign ownership and local PT PMDN.
A common question: what if the company earned nothing this year? The report is still required. The obligation is tied to the company itself, not to its turnover or profit.
The only exception in terms of content concerns the report on social and environmental responsibility (CSR/TJSL). It is mandatory only for companies in the natural resources sector; everyone else can skip that section.
What the report contains
The law requires seven parts:
Annual financial statements: the balance sheet compared with the prior year, the profit and loss statement, cash flow, changes in equity, and notes.
A report on the company's activities for the year.
A CSR report, for the natural resources sector only.
A report on problems in operations during the year, if there were any.
A report on the supervisory work of the Board of Commissioners.
A list of directors and commissioners.
Details of the salaries and remuneration of directors and commissioners.
The seventh item sometimes surprises owners, but it is a direct requirement of the law, not extra red tape on our part.
Is an audit mandatory?
For most companies, no. A mandatory audit under Article 68 of the Company Law applies only to certain categories:
companies that collect or manage public funds;
bond issuers;
public (Tbk) and state-owned (Persero) companies;
companies with assets or annual turnover of Rp 50 billion or more;
those required to undergo an audit under other provisions of the law.
And one more thing people often mix up. An external audit has nothing to do with a tax inspection. It is an independent review of your financial statements by an audit firm that the company hires and pays itself. The tax office deals with something else, checking that taxes are paid. Different procedures, different people.
Why this is not the report you file with the tax office
The most common confusion sounds like this: "I filed my taxes, so I've reported." In reality these are two separate obligations.
The annual report (Laporan Tahunan) goes to the Ministry of Law through SABH and covers the company's governance and activities. The corporate tax return (SPT Tahunan Badan) goes to the tax office and concerns income tax.
One does not replace the other. Filing your taxes but not submitting the annual report means staying exposed to the risk of being blocked.
How we take this off your plate
We prepare and file the annual report end to end. On your side, you fill out a short questionnaire and hand over the documents. We handle the rest.
How it works:
We send you the questionnaire and a list of the data we need.
You fill it out and pass us the documents.
We prepare the report, arrange the shareholders' meeting (RUPS), and confirm everything with you.
We coordinate with the notary, who files the report in SABH.
The cost is Rp 9,000,000 for companies without a mandatory audit and Rp 11,000,000 for those that need one. The audit itself is carried out by an independent firm and is paid for separately. Preparation takes about two to three weeks, so it is best to start well before the June 30 deadline.
Not sure whether the audit requirement applies to you, or which documents your company specifically needs? Get in touch. We'll look at your situation and take the report filing off your hands.
