Annual Report Approval Filing: A Recurring Obligation for Indonesian Limited Liability Companies

On 2 November 2026, the Minister of Law issued Regulation No. 24 of 2026 on Services in the Field of Business Entities (“MOL Regulation 24/2026”), which was promulgated and came into force on 3 November 2026. This update addresses one obligation under MOL Regulation 24/2026 that applies to every limited liability company in the form of a capital partnership (Perseroan Persekutuan modal) (each a “Company”): the filing of the general meeting of shareholders’ (“GMS”) approval of the annual report with the Minister of Law through the Legal Entity Administration System (“AHU System”).

The filing obligation is not new. It was introduced under Minister of Law Regulation No. 49 of 2025 on the Requirements and Procedures for the Establishment, Amendment, and Dissolution of Limited Liability Companies (“MOL Regulation 49/2025”). MOL Regulation 24/2026 revokes MOL Regulation 49/2025 (Article 153 letter h) but retains the annual report filing regime in substantially the same form, as part of a broader consolidation of regulations on business entity services.

Filing timeline

The board of directors (“BOD”) must submit the annual report to the GMS, after review by the board of commissioners (“BOC”), no later than 6 months after the end of the Company’s financial year (Article 16(1)).

The GMS approval of the annual report must be set out in a notarial deed (Article 16(2)). Article 16(2) refers specifically to approval by the GMS and does not expressly address shareholder resolutions adopted outside a meeting. Companies that approve their annual report by circular resolution should nonetheless ensure that the approval is set out in a notarial deed.

The BOD, through a notary, must submit the GMS approval to the Minister within 30 days of the date on which the notarial deed is signed (Article 16(3)). “Days” under MOL Regulation 24/2026 refers to calendar days (Article 1 point 19).

The filing is made electronically through the AHU System and must be accompanied by the notarial deed on the approval of the annual report and the annual report itself (Article 16(4) and (5)). Upon receipt, the Minister, through the Director General, issues a notification receipt (surat penerimaan pemberitahuan) (Article 16(7)).

Minimum contents of the annual report

Under Article 16(6), the annual report must contain at least:

• financial statements, comprising at least the year-end balance sheet compared with the previous financial year, the profit and loss statement, the cash flow statement, the statement of changes in equity, and the notes to the financial statements;
• a report on the Company’s activities;
• a report on the implementation of social and environmental responsibility;
• details of problems arising during the financial year that affected the Company’s business activities;
• a report on the supervisory duties performed by the BOC during the past financial year;
• the names of the members of the BOD and BOC; and
• the salaries and allowances of the members of the BOD, and the salaries or honoraria and allowances of the members of the BOC, for the past year.

Sanctions and blocked access

A Company that fails to fulfil the obligation, or that exceeds the filing deadline, may be subject to administrative sanctions in the form of a written warning and the blocking of access to the AHU System (Article 17).

The written warning is delivered through a notification on the AHU System and/or by email once the filing deadline has passed (Article 18(1)). If the Company does not comply within 30 days of the notification date, its access to the AHU System is blocked (Article 18(2) and (3)).

Blocked access prevents the Company from using the AHU and OSS System, through which amendments to the articles of association and changes to company data, including changes in shareholders and in the composition of the BOD and BOC, are filed (Articles 1 point 10 and 10(2)). Such applications are generally subject to a 30-day filing period, after which they “tidak dapat diajukan kepada Menteri” (Article 9(6) and (7)). A Company whose access is blocked at the time of a transaction may therefore be unable to file within that period.

Lifting the block

A Company subject to blocking may apply for the lifting of the block through the AHU System by completing the relevant form and uploading the notarial deed on the approval of the annual report and the annual report (Article 19). The Director General lifts the block once a complete application has been received (Article 20).

Individual companies

Individual companies (Perseroan perorangan) are subject to a separate regime. An individual company must report its financial statements by completing an electronic form on the AHU System no later than 6 months after the end of the current accounting period (Article 27(1)). Non-compliance may result in a written warning, termination of access to AHU System services, and, ultimately, revocation of legal entity status (Article 28).

Concluding remarks

The annual report filing is a recurring obligation that should be incorporated into each Company’s annual corporate compliance calendar, alongside its annual tax reporting. Companies that have not yet filed the GMS approval of their most recent annual report are advised to review their status on the AHU System and coordinate with their notary.

JJP & Partners can assist Companies in reviewing their filing status on the AHU System, preparing the GMS resolutions on the approval of the annual report, coordinating with the notary on the notarial deed and its submission within the 30-day period, and applying for the lifting of blocked access where a Company has already been sanctioned. We can also assist in structuring an annual corporate compliance calendar covering this obligation together with other recurring corporate filings.