29 October 2026 | Remidian and Partners
Indonesian limited liability companies should review their 2025 annual report filing status following AHU’s latest announcement on the implementation of administrative sanctions.
Key dates for companies
- 1 November 2026: AHU will apply the requirement to submit the notarial deed approving the annual report through the Legal Entity Administration System (SABH) within 30 days of signing.
- 1–31 December 2026: Written warnings will begin for companies that have not fulfilled their 2025 annual report submission obligations.
- 31 December 2026: The announced Rp0 government filing fee period ends.
- 2 January 2027: AHU will begin implementing SABH access blocking for noncompliant companies, subject to the applicable sanction procedures.
These implementation dates were reported by Hukumonline on 28 October 2026, citing AHU’s announcement.
Holding an annual shareholders’ meeting is only part of the process
Under Minister of Law Regulation No. 49 of 2025, the annual report must first be reviewed by the board of commissioners and presented to the General Meeting of Shareholders (RUPS) within six months after the financial year ends. Shareholder approval must be recorded in a notarial deed and submitted to the Minister through a notary via SABH, together with the required supporting documents.
The announced implementation schedule should therefore not be treated as a blanket extension of the normal RUPS deadline or the 30-day deed submission requirement.
What should your company do now?
Check whether your 2025 annual report has been approved, documented in a notarial deed, and successfully submitted through SABH. Coordinate with your notary, retain the filing acknowledgment, and monitor any notices issued to your company.
The Rp0 concession applies to the relevant government filing fee; notarial and professional service fees may still apply.
Need assistance reviewing your corporate compliance obligations?
Contact Remidian and Partners to discuss your company’s reporting requirements and next steps.
Email: info@remidian-bahureksa.com
Website: www.remidian-bahureksa.com
This update provides general information and does not constitute legal advice for any particular company or circumstances.