Indonesia has introduced clear procedures and enforceable sanctions for late annual report submissions.
Minister of Law Regulation No. 49 of 2025 (“Regulation 49/2025”) formalises how companies must submit their annual reports and introduces real operational consequences for non-compliance.
For directors and shareholders, this regulation changes annual reporting from a formality into a mandatory compliance obligation.
Regulation 49/2025 implements and enforces annual report obligations under Indonesian Companies Law (Law No. 40 of 2007, as amended).
Previously, companies were required to submit annual reports, but:
Regulation 49/2025 closes these gaps.
Deadline: Annual reports must be approved by the General Meeting of Shareholders (GMS) within six months after the end of the financial year.
This deadline has not changed.
What has changed is what must happen after GMS approval.
Under Regulation 49/2025, companies must now follow a strict post-GMS procedure:
The GMS resolution approving the annual report must be restated in a notarial deed.
Within 30 calendar days after the notarial deed is signed, the board of directors must submit an electronic notification via the Legal Entity Administration System (SABH).
The submission must include:
The Ministry of Law will issue an electronic acknowledgement of receipt once the submission is complete.
Without this acknowledgement, the annual report is not considered properly filed.
Regulation 49/2025 introduces enforceable sanctions for non-compliance.
Companies that miss the deadline may face:
To restore access, the company must:
SABH access is required for many corporate actions, including:
A suspension can delay or halt business operations.
Annual reports must now fully comply with Article 16 of Regulation 49/2025, including:
This may increase preparation time and compliance costs.
To remain compliant, companies should:
Annual reporting should be treated as a compliance process, not a year-end task.
Our legal team assists companies with:
If you are unsure whether your annual reporting process aligns with Regulation 49/2025, our legal team can assist.
Contact SAS to ensure your annual compliance remains timely, accurate, and risk-free.
Regulation 49/2025 introduces mandatory procedures and administrative sanctions for late annual report submissions through the SABH system.
Annual reports must be approved within six months after the financial year-end and submitted via SABH within 30 days after notarisation. In practical terms, this means the report must be approved before the end of June and submitted before the end of July.
Companies may receive warnings and face suspension of SABH access, preventing corporate legal actions.
SABH is required for director changes, shareholder updates, capital amendments, and other corporate filings.
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