PT PMA Annual Reporting & SABH Compliance in Bali & Indonesia

Annual reporting via SABH, and why it now catches every PT PMA

An Annual Report (Laporan Tahunan) sets out a company’s financial position and what it did during the financial year, approved by the shareholders at an Annual General Meeting — the RUPS (Rapat Umum Pemegang Saham). For years, most private companies treated this as housekeeping: the meeting happened on paper, the approval was kept as an internal private minute, and nobody outside the company ever saw it.

That has changed. Under Permenkum 49/2025 — the Minister of Law’s regulation on the establishment, amendment and dissolution of limited liability companies — the Annual Report has become an administrative compliance obligation owed to the state. The Directorate General of Legal Administrative Affairs (Ditjen AHU) now requires the RUPS approval and the Annual Report to be filed electronically through SABH (Sistem Administrasi Badan Hukum), the same Legal Entity Administration System used to incorporate and amend your company.

The point foreign owners miss is that a PT PMA is a PT. Perseroan Terbatas Penanaman Modal Asing is simply a foreign-owned limited liability company — legally the same animal as a local PT, just with foreign shareholders. So the rule applies to it identically. A villa-management company in Seminyak, an F&B group in Canggu, a consultancy in Ubud or a trading company in Jakarta are all caught the moment their legal status is active in the SABH database.

Legal basis: Permenkum 49/2025 and Law 40/2007

Two instruments work together. Permenkum 49/2025 is the procedure — it makes the annual RUPS approval and Annual Report a mandatory SABH filing and tightens how it must be done. The substance of what goes into the Annual Report comes from Law 40/2007 on Limited Liability Companies (Undang-Undang Perseroan Terbatas), the foundational statute that has always defined what a company must report to its shareholders.

Together they turn the Annual Report from an internal document into a duty that attaches to every PT with an active legal-entity status at Ditjen AHU — foreign-owned or not.

What changed on 1 June 2026

From 1 June 2026 the reporting flow changed in ways that directly affect how a foreign owner has to operate:

• The RUPS approval must be a notary deed. The shareholders’ resolution approving the Annual Report can no longer be a private internal minute (risalah di bawah tangan) — it must be drawn up as a formal notary deed (akta notaris) before it is filed.
• A 30-day filing window. Once the notary deed is signed, the directors — through the notary — must report the approval electronically to SABH within 30 days.
• The RUPS itself within six months. The Annual RUPS must be held no later than six months after the financial year ends, so scheduling has to be disciplined.
• Two clusters. Ditjen AHU splits reporting into companies that must be audited (Tbk, state-owned enterprises, managers of public funds) and companies that are not required to be audited.
• Sole-shareholder companies (PT Perorangan) self-file a financial-statement form directly through SABH.

Who must file — including the dormant villa company

The obligation attaches to every company whose legal status is active in the Ministry of Law’s database, with the mechanism varying by category:

• Audit-required companies — public companies (Tbk), state-owned enterprises and managers of public funds must attach financial statements audited by a public accountant.
• Non-audit companies — the typical private PT PMA files the Annual Report through the RUPS notary deed and SABH e-filing, without a public-accountant audit.
• PT Perorangan — fill in a financial-statement form directly in SABH.
• Dormant / non-operating companies — still must file. This is the trap for foreign owners: a villa-holding or project company that is “resting” between developments is still an active legal entity, so the duty remains. Pausing operations does not pause the obligation.

What the Annual Report must contain

The contents follow Article 16(6) of Permenkum 49/2025, read with the standard in Law 40/2007. At a minimum, the Annual Report must include:

• Financial statements — a year-end balance sheet, income statement, cash-flow statement, statement of changes in equity, and notes to the financial statements.
• Company activities — a report on the company’s operations during the financial year.
• CSR / TJSL report — the implementation of corporate social and environmental responsibility.
• Business problems and risks — the issues and risks that affected the company’s operations during the year.
• Supervisory report — the Board of Commissioners’ report on its supervision during the preceding year.
• Management roster — the names of the serving Directors and Commissioners.
• Remuneration details — the salaries, honorariums, facilities and allowances of the Directors and Commissioners.

Penalties: the SABH-block domino

The government has set a grace period, with formal administrative-sanction enforcement applying from November 2026. If a company ignores the obligation, it first receives a written warning through the SABH system or by email. If the warning is ignored for 30 days, the company’s legal-entity access in SABH is blocked or marked inactive.

A block triggers a chain reaction across the company’s operations:

• Corporate actions freeze. You cannot change the Directors or Commissioners, change the capital, or amend the articles of association in the system.
• OSS and tax knock-on. Because AHU is integrated with other systems, a block obstructs OSS-RBA licensing validation and the sync of tax data into Coretax (Ditjen Pajak) — exactly the systems a working PT PMA relies on day to day.
• Director liability risk. Administrative negligence that harms the company can become a breach of fiduciary duty, exposing directors to personal claims from shareholders.

Prepare financial statements & reports Jan–Mar

Hold Annual RUPS by 30 Jun (≤6 months)

RUPS resolution → notary deed after the RUPS

E-file approval to SABH ≤30 days after the deed

Indicative cycle for a company with a 31 December financial year-end. Shift the dates if your financial year differs; deadlines are set by Permenkum 49/2025, not by the calendar.

What CLAN does for foreign owners

We run the whole annual cycle so it never becomes the thing that blocks your company:

• Document review & drafting — we check that your comparative financial statements, activity report, CSR/TJSL report and Commissioners’ supervisory report meet the Permenkum 49/2025 standard before anything is filed.
• RUPS notary deed — we put your Annual RUPS resolution into a proper notary deed through our partner notaries, the mandatory form under the new rule.
• SABH e-filing — we upload the deed and supporting documents to Ditjen AHU’s SABH within the 30-day window, through to the official acknowledgement letter (Surat Penerimaan Pemberitahuan).
• Unblocking — if your access is already blocked, we clear the outstanding filing and restore it.
• Handled in English — every document and obligation explained clearly, so nothing is lost between Indonesian regulation and a foreign board.

Documents you’ll need to start

To begin, you only need the basics:

• The Deed of Establishment (Akta Pendirian) and the latest amendment deed, if any.
• The most recent Ministry of Law approval (SK Pengesahan Kemenkum).
• Year-end financial statements (comparative balance sheet and income statement).
• Director, Commissioner and shareholder data (passports / KITAS, NPWP).
• A summary of the year’s activities and the CSR report, where required.

If you set up your company recently, this slots straight onto your existing structure — see our PT PMA Company Setup and, for the quarterly side of compliance, LKPM Reporting & Capital Lock-Up.