PT PMA Audit Requirements Indonesia 2026

Zantara AI

Loading Zantara...

When Is an Audit Mandatory?

Not every PT PMA in Indonesia needs a financial audit. The requirement depends on the company's size, sector, and specific characteristics. Understanding when an audit is mandatory helps you plan and budget accordingly.

Mandatory Audit Criteria Under UU 40/2007

Article 68 of the Company Law (UU 40/2007) requires an audit by a public accountant for companies that meet any of the following criteria:

Criterion	Threshold
Manage public funds	Any amount (banks, pension funds)
Issue debt instruments	Any amount (bonds, sukuk)
Annual revenue	Exceeds IDR 50 billion
Total assets	Exceeds IDR 100 billion
Publicly listed (IDX)	All listed companies
Required by law/regulation	Sector-specific requirements

Sector-Specific Mandatory Audit

Sector	Regulator	Audit Requirement
Banking	OJK	Annual audit mandatory for all banks
Insurance	OJK	Annual audit mandatory
Securities companies	OJK	Annual audit mandatory
Pension funds	OJK	Annual audit mandatory
Finance companies	OJK	Annual audit mandatory
Mining (IUP holders)	ESDM	Annual audit for production-stage companies
Public companies (Tbk)	OJK/IDX	Annual and semi-annual audit
Companies receiving government grants	Various	Per grant agreement
NGOs/foundations	Kemenkumham	If managing public donations

Practical Assessment for PT PMA in Bali

For most small to medium PT PMA companies in Bali (hospitality, F&B, consulting, tech, tourism), the honest assessment is:

Probably not required if:

Annual revenue is below IDR 50 billion (approximately USD 3 million)
Total assets are below IDR 100 billion
Not in a regulated sector
Not publicly listed

Definitely required if:

Revenue exceeds IDR 50 billion
In banking, insurance, or financial services
Preparing for IPO
Court-ordered (e.g., shareholder disputes)

Types of Audit

Statutory Audit (Audit Wajib)

The mandatory annual audit required by law. This is a full-scope audit resulting in an opinion on the financial statements.

Voluntary Audit (Audit Sukarela)

An audit conducted by choice, not legal requirement. Reasons include:

Bank loan requirements
Investor due diligence
Internal governance
Business partner credibility
Preparation for future regulatory requirements

Tax Audit (Pemeriksaan Pajak)

Conducted by DJP, not by external auditors. This is a government tax investigation, not a financial statement audit. However, having audited financial statements significantly helps during tax audits.

Special Purpose Audit

Audits for specific purposes such as:

Due diligence for M&A transactions
Compliance audits for specific regulations
Forensic audits for fraud investigation
Agreed-upon procedures for specific areas

The Audit Process

Phase 1: Planning and Engagement (2-4 weeks)

Step	Detail
Engagement letter	Auditor and company agree on scope, timeline, fees
Risk assessment	Auditor identifies areas of highest risk
Materiality	Sets the threshold for significant errors
Audit plan	Detailed testing procedures for each financial statement area

Phase 2: Fieldwork (4-8 weeks)

The auditor's team visits your office and performs:

Substantive testing:

Sample testing of sales transactions and revenue recognition
Verification of bank balances (bank confirmations)
Accounts receivable confirmations (directly with clients)
Physical inventory count (if applicable)
Fixed asset verification
Review of expense documentation
Tax compliance testing
Related party transaction review
Review of contracts and commitments

Controls testing:

Evaluate internal controls over financial reporting
Test authorization and approval procedures
Review segregation of duties
Assess IT system controls

Phase 3: Review and Reporting (2-4 weeks)

Step	Detail
Draft findings	Auditor presents preliminary findings to management
Management responses	Company responds to findings and adjustments
Adjusting entries	Agree on adjustments to financial statements
Final financial statements	Prepare revised statements incorporating adjustments
Audit opinion	Auditor issues formal opinion
Management letter	Separate letter with recommendations for improvements

Phase 4: Delivery

The final deliverables include:

Audited financial statements with auditor's report
Management letter with findings and recommendations
List of adjusting journal entries
Summary of unadjusted differences (if any)

Audit Opinions

The auditor's opinion indicates the level of confidence in the financial statements:

Opinion	Meaning	Implication
Unqualified (Wajar Tanpa Pengecualian / WTP)	Financial statements are fairly presented	Best possible outcome
Qualified (Wajar Dengan Pengecualian / WDP)	Generally fair, except for specific issues	Acceptable but issues should be addressed
Adverse (Tidak Wajar)	Financial statements are materially misstated	Serious problem; statements unreliable
Disclaimer (Tidak Memberikan Pendapat)	Auditor cannot form an opinion	Usually due to scope limitations

Goal: Every PT PMA should aim for an unqualified (WTP) opinion. A qualified or adverse opinion can affect bank financing, investor confidence, and regulatory standing.

Choosing an Auditor

Types of Audit Firms in Indonesia

Big 4 Firms

Global Firm	Indonesian Partner	Typical Client
Deloitte	Imelda & Rekan	Large multinationals, listed companies
EY (Ernst & Young)	Purwantono, Sungkoro & Surja	Large companies, IPO candidates
KPMG	Siddharta Widjaja & Rekan	Large companies, financial sector
PwC (PricewaterhouseCoopers)	Tanudiredja, Wibisana, Rintis & Rekan	Large companies, government contracts

Mid-Tier International Affiliates

Network	Strengths
BDO	Strong SME practice
Grant Thornton	International PT PMA specialist
RSM	Mid-market focus
Baker Tilly	Cost-effective international standard
Crowe	Tax-integrated audit approach

Local KAP Firms

Hundreds of local Kantor Akuntan Publik (KAP) operate throughout Indonesia. They range from solo practitioners to mid-size firms with 50+ staff.

Selection Criteria

Criterion	Why It Matters
OJK/PPPK registration	Required for mandatory audits
Industry experience	Understanding of your sector's specific issues
PT PMA experience	Familiarity with foreign ownership, transfer pricing
English capability	Essential for foreign directors and shareholders
Location	Bali-based or willing to travel for fieldwork
Fee structure	Fixed fee vs. hourly; what is included
Partner availability	Who will actually oversee your audit
References	Track record with similar clients

Cost Comparison

Firm Type	Annual Audit Fee Range	Best For
Local KAP (small)	IDR 30-50M	Small PT PMA, simple operations
Local KAP (medium)	IDR 50-100M	Medium PT PMA, moderate complexity
Mid-tier international	IDR 80-200M	PT PMA needing international standards
Big 4	IDR 200-500M+	Large PT PMA, regulated sectors, IPO

Fee factors:

Company revenue and asset size
Number and complexity of transactions
Number of employees
Multiple locations or entities
Related party transaction volume
Industry-specific requirements
First-year vs. recurring engagement (first year is usually higher)

Preparing for an Audit

3 Months Before: Planning

Select and engage the auditor (or confirm continuing engagement)
Agree on timeline and key dates
Identify potential issues (accounting policy changes, unusual transactions, provisions)
Assign internal team (who will work with auditors)

1 Month Before: Documentation

Prepare the following documentation for auditors:

Document	Purpose
Trial balance (final)	Starting point for audit
General ledger detail	Transaction-level detail
Bank statements (all months)	Cash verification
Bank reconciliations (all months)	Completeness check
Sales invoices (sample)	Revenue testing
Purchase invoices (sample)	Expense testing
Payroll records	Employee cost verification
Fixed asset register	Asset existence and depreciation
Tax filing receipts (all SPT)	Tax compliance
BPJS payment receipts	Social security compliance
Contracts and agreements	Obligation identification
Board/RUPS minutes	Authorization verification
Company deed and amendments	Legal verification

During Fieldwork: Cooperation

Provide auditors with a dedicated workspace
Designate a primary contact person
Respond to information requests within 24-48 hours
Be transparent about issues and uncertainties
Do not alter records after providing them to auditors

Common Audit Findings for PT PMA

Finding 1: Inadequate Transfer Pricing Documentation

Issue: Transactions with related parties (parent company, affiliates) without proper arm's length documentation. Fix: Prepare transfer pricing local file annually.

Finding 2: Unreconciled Tax Accounts

Issue: Tax prepayment and payable balances in the books do not match actual tax filings and payments. Fix: Monthly tax reconciliation (see our bookkeeping guide).

Finding 3: Missing Revenue Cut-Off

Issue: Revenue recognized in the wrong period (December services billed in January, or vice versa). Fix: Implement proper revenue recognition procedures and cut-off analysis.

Finding 4: Unsubstantiated Expense Claims

Issue: Expenses without proper supporting documentation (receipts, invoices, contracts). Fix: Enforce a "no receipt, no reimbursement" policy and maintain organized document archives.

Finding 5: Fixed Asset Discrepancies

Issue: Physical assets do not match the fixed asset register (missing items, disposed but not removed from books). Fix: Annual physical asset verification and register updates.

Audit Timeline

Month	Activity
October-November	Engage auditor, plan timeline
December	Year-end close, inventory count
January	Prepare supporting documents
February-March	Fieldwork
March	Draft findings, management discussion
April	Final audited statements
April 30	Submit with SPT Tahunan
June 30	RUPS approval deadline

Frequently Asked Questions

How much does a PT PMA audit cost in Indonesia?

Audit costs vary significantly by firm size and company complexity. Local KAP (audit firms): IDR 30-100 million for small to medium PT PMA. Mid-tier international affiliates (BDO, Grant Thornton, RSM): IDR 80-200 million. Big 4 firms (Deloitte, EY, KPMG, PwC): IDR 200-500+ million. The cost depends on revenue size, transaction volume, number of employees, and industry complexity.

Can a PT PMA choose to be audited even if not required?

Yes. Voluntary audits are common for PT PMA companies that want to: secure bank financing (many banks require audited statements for loans above IDR 1 billion), attract investors, demonstrate credibility to business partners, or prepare for future regulatory requirements. A voluntary audit follows the same professional standards as a mandatory one.

What happens if a PT PMA that requires an audit does not get one?

Non-compliance with mandatory audit requirements can result in: DJP rejecting the corporate tax return (SPT Badan), penalties from OJK for regulated entities, shareholder lawsuits (minority shareholders can challenge unaudited financial statements), difficulty obtaining bank loans, and potential issues with business license renewals.

How Bali Zero Can Help

Bali Zero connects PT PMA owners with qualified audit firms and manages the entire process:

Auditor selection based on your company's size and sector
Audit preparation through our accounting partners
Year-round bookkeeping (ensures clean books at year-end)
Tax compliance to prevent audit issues
New company formation (IDR 20,000,000) with proper accounting framework from day one