Effective 1 June 2026, Indonesia’s Directorate General of Legal Administration (AHU) opened annual report submissions through the SABH system, marking the practical start of the annual reporting regime introduced under Minister of Law Regulation No. 49 of 2025.

At a glance

• Limited liability companies (Perseroan Terbatas) can now submit annual reports (Laporan Tahunan) through the Legal Entity Administration System (SABH), effective 1 June 2026.
• No sanctions apply yet, but AHU is already checking annual report compliance before processing certain corporate filings, so gaps can cause delays now.
• Sanctions for non-compliance are expected from November 2026, though their scope hasn’t been disclosed.

The announcement adds no new legal obligation, but it starts enforcement of a rule many companies have previously treated as a paperwork formality.

Background

Indonesian Company Law has long required the Board of Directors to prepare an annual report each year and have it approved at the General Meeting of Shareholders. In practice, though, these reports rarely reached government authorities and were treated as internal records. MOL 49/2025 took effect in December 2025, but the filing system and implementation guidelines weren’t available until this announcement, which is the first to confirm how and when submissions actually begin.

Key Points of the Announcement

• Compliance now affects other filings: AHU will check annual report compliance when processing changes to the Board of Directors or Board of Commissioners, share transfers, and shareholder record updates. This is the point with the most immediate bite: companies with unfiled reports may hit delays on routine corporate actions well before any sanctions regime starts.
• Filing is open: Companies can submit through SABH since 1 June 2026.
• No fees yet: No PNBP fees currently apply, though a future government regulation could introduce them.
• Notarial deeds get transitional flexibility: Deeds may still be used for submission even after their normal 30-day validity has lapsed.
• Sanctions land later: Administrative sanctions are expected from November 2026, but AHU hasn’t disclosed their nature or scope.

Impact and Action Required

Annual reports can no longer be treated as internal records; they constitute now a statutory filing tied to AHU. Any company planning a director or commissioner change, a share transfer, or another registration should check early that its annual reports are prepared and submission-ready. No exemption applies to foreign investment companies (PMA), so foreign-owned Indonesian subsidiaries are fully in scope.

Timeline

SABH filing opened 1 June 2026; sanctions are expected from November 2026, with scope still to be confirmed.