29 October 2026 | Remidian and Partners
Identifying a company’s registered shareholders is only part of understanding who ultimately controls or benefits from the business.
Under Minister of Law Regulation No. 2 of 2025 on Verification and Supervision of Corporate Beneficial Ownership, corporations must identify their beneficial owners and verify the accuracy of the information against supporting documents. Verification applies when submitting incorporation, amendment, and information-update filings.
Who qualifies as a beneficial owner?
A beneficial owner must be an individual. For an Indonesian limited liability company, the assessment includes shareholding, voting rights, entitlement to profits, authority to appoint or dismiss directors and commissioners, and actual control over the company.
Ownership below 25% does not automatically exclude an individual. Other control or benefit criteria may apply, and a beneficial owner may be someone outside the company’s registered shareholders or management.
An existing filing may still require further action
AHU’s 2026 circular reinforces the requirement to report beneficial ownership information and complete the verification questionnaire. Corporations that have already reported must also complete the questionnaire when making relevant corporate amendments or changing or updating beneficial ownership information. Failure to report, or reporting incorrect information, may result in administrative sanctions, including warnings, blacklisting, and/or blocking access to AHU systems.
What should companies review?
- Identify the individuals who ultimately own, control, or benefit from the business.
- Check that reported information matches supporting corporate and identity documents.
- Review whether the required verification questionnaire has been completed.
- Keep beneficial ownership information current. AHU’s reporting guidance requires updates at least annually.
Treat beneficial ownership reporting as an ongoing compliance responsibility, particularly when ownership or control changes.
Need assistance reviewing your company’s beneficial ownership reporting?
Contact Remidian and Partners to discuss your corporate compliance requirements.
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.