Does a foreign-owned company (PT PMA) have to file an annual report in Indonesia?

Short answer: yes. A PT PMA — a foreign-owned limited liability company — is legally a Perseroan Terbatas (PT), the same as any local company. So the annual-reporting rule that took effect on 1 June 2026 under Permenkum 49/2025 applies to it identically. Foreign ownership does not exempt you, and neither does being a small or dormant company. If your company’s legal status is active in the Ministry of Law’s database, you have to file.

This catches a lot of foreign owners off guard, because the obligation used to be invisible. Below is what actually changed and what you now have to do.

What used to happen vs what happens now

Every PT is supposed to hold an Annual General Meeting of Shareholders — the RUPS (Rapat Umum Pemegang Saham) — to approve its Annual Report. For years, private companies treated that as an internal formality: a meeting on paper, an approval kept as a private minute, nothing filed anywhere.

Under Permenkum 49/2025 that approval is no longer private. The RUPS resolution approving the Annual Report must now be drawn up as a notary deed (akta notaris) and filed electronically through SABH — Sistem Administrasi Badan Hukum, the same Legal Entity Administration System (Ditjen AHU, Ministry of Law) used to incorporate and amend your company. The substance of what the report must contain still comes from Law 40/2007 on Limited Liability Companies.

The deadlines

• The Annual RUPS must be held no later than six months after the financial year ends. For a 31 December year-end, that means by 30 June.
• The RUPS resolution must be put into a notary deed.
• That deed must be filed to SABH within 30 days of being signed.

What the annual report has to include

Under Article 16(6) of Permenkum 49/2025: full financial statements (year-end balance sheet, income statement, cash-flow statement, statement of changes in equity, and notes), a report on the company’s activities, the CSR/TJSL report, the business problems and risks faced during the year, the Board of Commissioners’ supervisory report, the names of the serving Directors and Commissioners, and details of their remuneration. We break this down on the PT PMA Annual Reporting & SABH service page.

What if you don’t file?

You get a written warning through SABH first. Ignore it for 30 days and your legal-entity access is blocked — you can no longer change directors, capital or your articles. Because AHU is integrated with other systems, a block also disrupts your OSS-RBA licensing validation and your Coretax tax-data sync. Formal administrative-sanction enforcement applies from November 2026. Unblocking means filing the overdue report and paying a recovery fine (roughly Rp1 million for a non-audit company, Rp2 million for an audit-required one).

Does a dormant company still file?

Yes. A villa-holding or project company that is paused between developments is still an active legal entity, so the duty stays. The only way the obligation ends is to formally dissolve the company.

The practical takeaway

If you own a PT PMA in Bali or anywhere in Indonesia, put your financial year-end on a compliance calendar now and work backwards: financial statements, then the RUPS, then the notary deed, then the SABH filing within 30 days. If you’d rather not track it, that’s exactly what we do — see PT PMA Annual Reporting & SABH, and for the quarterly side, LKPM Reporting & Capital Lock-Up.