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Bali Zero Editorial
Corporate Compliance Desk
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Bali Zero handles visas, company setup, tax and property compliance in Indonesia. Ask us directly on WhatsApp.
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Topics

Bali Zero Editorial
Corporate Compliance Desk
Bali Zero handles visas, company setup, tax and property compliance in Indonesia. Ask us directly on WhatsApp.
Chat with Bali Zero on WhatsAppIndonesian bureaucracy rarely does drama. It prefers accumulation: one regulation in December, a circular letter in March, an online system update in May — and then suddenly you look at the calendar and realize that June 2026 contains two separate deadlines that, between them, touch every single company in the country.
The good news: for most companies, the first deadline resolves itself automatically, and the second is entirely manageable if you start now. The bad news: "most" is not "all," the penalties for the second one are genuinely new, and the two deadlines interact in ways that can trap the unprepared.
Let's take them one at a time, in plain language.
Every business in Indonesia is filed under one or more KBLI codes — five-digit numbers from the national classification of business activities, maintained by the statistics agency (BPS). Think of it as the government's master menu: a beach club is 56301, a software house is in the 62-series, a villa rental sits in the 55-series. Your code determines which licenses you need, how risky the state considers your activity, and — for foreign-owned companies — whether and how much foreign ownership is allowed.
The menu gets refreshed roughly every five years. In December 2025, BPS issued Regulation No. 7 of 2025, replacing KBLI 2020 with KBLI 2025 — aligned to the latest international standard (ISIC Revision 5). New economic realities got their own numbers: proprietary crypto-asset trading (64994), carbon unit trading (64995), carbon capture and storage (39001–39009). Other sectors were reorganized, renumbered, merged, or split.
Article 5 of the regulation gave everyone six months to align. Six months from 18 December 2025 is 18 June 2026.
Here is the part the alarmist posts leave out. In March 2026, the investment ministry (BKPM), the Ministry of Law and BPS issued a Joint Circular Letter (No. 4.S of 2026) that settles how the transition actually works — and the answer, for the large majority of companies, is: the systems do it for you.
"My NIB expires on June 18." False — existing NIBs and licenses remain valid; the Circular Letter says so in as many words.
"Everyone needs a new akta." False — a deed amendment is required only when the substance of your activities changes, not when the code number does.
"I must apply for new licenses under the new codes." False — the government's own guidance (echoed by the Coordinating Ministry for Economic Affairs) is that the transition "does not require new licensing" for continuing activities.
Three profiles of company should not just sit back:
1. Your old code was split (one-to-many). Some KBLI 2020 codes were divided into several more specific 2025 codes. The systems cannot always know which of the children describe you — that is a business judgment. The Circular's rule: if all the new candidate codes still fall within the purposes stated in your articles of association, you pick the right ones administratively, no deed needed. But if one of the new activities falls outside your deed's purpose clause, a deed amendment becomes mandatory. Either way, someone has to look.
2. Your sector was materially reorganized. Software and IT services (the old 62-series) were renumbered; motor vehicle repair left the trade sector; new digital-asset and carbon codes exist where nothing did. If you operate in a reshuffled sector, verify what OSS now shows for you — a code that converts to something subtly wrong can change your risk classification under the licensing framework, and with it the permits you are supposed to hold.
3. You are a PT PMA with multiple codes — or about to expand. Foreign-investment companies carry a minimum-investment requirement of more than IDR 10 billion per five-digit KBLI code. The Joint Circular is silent on what happens when one old code becomes three new ones — whether the requirement multiplies. The conservative reading: keep only the codes you genuinely use. Spring-cleaning your KBLI list before the window closes costs little; carrying phantom codes into the new system may cost a lot. (An honest note: this point is genuinely unresolved in the regulation as written — it is exactly the kind of question to put to an advisor rather than to chance.)
And a Bali favorite for the record: villa accommodation moved from 55193 to 55203, a classic one-to-one renumber — low risk classification, automatic conversion, no deed needed if renting villas is what your deed already says you do.
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Indonesian company law (UU 40/2007) has always required this: within six months of the fiscal year end, the directors present an annual report — financial statements, activity summary, supervisory notes — and the general meeting of shareholders (RUPS) approves it. For the standard December year-end, six months lands on 30 June.
For decades this was, in practice, an internal ritual. Many small PTs "held" the meeting on paper, filed the minutes in a drawer, and nothing more happened. No filing, no register, no consequence.
In December 2025, the Ministry of Law issued Regulation No. 49 of 2025, and the drawer era ended. We covered the regulation in detail when it was issued; here is the operational core as the first real deadline approaches:
Put the timeline together and the comfortable "we'll do it in December" habit is dead:
The regulation's penalty is not a fine. It is something more paralyzing: after a written warning and a grace period, the ministry blocks the company's access to SABH — the system through which every corporate legal change in Indonesia flows.
A blocked company cannot:
In other words: the company keeps existing, but it is legally frozen. And the freeze tends to reveal itself at the worst moment — mid-transaction, mid-hire, mid-renewal.
The obligation attaches to the legal entity, not to its turnover. A PT that did zero business in 2025 still owes its shareholders an annual report — even a near-empty one — and still owes the SABH filing. Indonesia has thousands of quietly dormant PTs (a holding vehicle for a villa, a venture that never launched). Their owners will mostly discover the block only when they try to sell, restructure, or dissolve. If you own a sleeping PT, wake it up once this month: one short report, one deed, one filing.
One more nuance worth knowing: company law (UU 40/2007, Article 91) allows shareholders to take decisions in writing without a physical meeting (circular resolution), provided everyone signs. Many notaries are using exactly this route to process the June wave efficiently — but how it is papered into the required deed varies, so let your notary drive the format. The deadline does not care whether the approval happened around a table in Kuningan or by signature circulating on DocuSign; it cares that the deed exists and gets filed.
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Notice how the two deadlines chain together: if your KBLI situation does require a deed amendment and you also haven't filed your annual report, an SABH block from the second failure will stop you from fixing the first. Compliance debts in Indonesia rarely stay in their own lane.
And June's crunch doesn't end at midnight on the 30th — for companies on the UMKM 0.5% tax scheme, 2026 also started the countdown clocks created by PP 20/2026. If that's you, read our companion guide: who keeps the 0.5% tax and who loses it.
Neither of these deadlines is difficult. Both are cheap to meet and expensive to miss. The KBLI transition needs fifteen minutes of verification for most companies and a deliberate decision for a few. The annual report needs a closed set of accounts, one shareholder decision, and a notary appointment — booked before everyone else in the country wants the same slot.
The pattern behind both is worth registering, because it is the story of Indonesian compliance in 2026: obligations that used to live on paper now live in connected systems, and the systems enforce automatically what officials used to overlook indefinitely.
Bali Zero's corporate desk is running June-deadline packages: KBLI verification + annual report RUPS + notarized SABH filing, handled end to end. Message us on WhatsApp or ask Zantara AI — ideally before your notary's calendar fills.