Indonesia Post-Deadline Compliance: KBLI 2025 & Annual Report RUPS

Q: Will my NIB or business license become invalid after the KBLI 2025 transition window?

No. The Joint Circular Letter issued by BKPM, the Ministry of Law and BPS confirms that all existing NIBs, basic requirement permits and sectoral licenses issued under KBLI 2020 remain valid. The code conversion is performed automatically in the OSS and AHU systems for most companies. What you should do is verify the result — especially if your old code was split into several new ones.

Q: Do I need to amend my company deed (akta) for KBLI 2025?

Usually not. If only the code number changes and your actual business activities stay the same, no deed amendment is required. An amendment is needed only if your activities change in substance — for example, you add a new line of business, or your old code was split into new codes not covered by the purposes clause of your current articles of association.

Q: What changed about the annual report deadline this year?

The 30 June RUPS deadline itself is old law (UU 40/2007 — within 6 months of fiscal year end). What is new for 2026 is Permenkum 49/2025: the shareholder approval must now be recorded in a notarial deed and filed into the Ministry of Law's SABH system within 30 days. What used to be an internal formality is now a public filing with sanctions.

Q: What happens if my company skips the annual report filing?

The Ministry of Law issues a written warning; continued non-compliance leads to the blocking of the company's SABH/AHU access. A blocked company cannot process any corporate changes — new directors, share transfers, address changes — and the freeze ripples into licensing updates and even expatriate work-permit renewals that depend on current corporate data.

Q: Does a dormant company also need to file the annual report?

Yes. The obligation attaches to the legal entity, not its activity level. A PT that traded nothing in 2025 still needs its shareholders to approve an annual report (even one with zero revenue) and file it via SABH. Dormant companies are precisely the ones most likely to discover a block only when they try to sell, restructure or close.

Bali Zero Editorial

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Indonesian 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 realize that June 2026 has passed with two separate compliance windows that, between them, touch every single company in the country.

KBLI 2025 transition window: the six-month alignment period for Indonesia's new catalogue of business classifications has ended; companies should now verify conversion results and remediate mismatches.
June 30: shareholders of every PT with a December fiscal year must approve the 2025 annual report — and, for the first time ever, that approval must be notarized and filed with the government.

The good news: for most companies, the KBLI conversion should resolve automatically, and annual-report filing can still be remediated if handled before the next blocked corporate action. The bad news: "most" is not "all," the penalties for missed corporate filing are genuinely new, and the two obligations interact in ways that can trap the unprepared.

Let's take them one at a time, in plain language.

Part One — KBLI 2025 after the transition window

What KBLI actually is (and why you have one)

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 the now-closed June 2026 transition window.

What happens automatically (most of it)

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.

If your old code maps to exactly one new code (one-to-one), or several old codes merge into one new code (many-to-one), the conversion happens automatically inside OSS (your licensing record) and AHU/SABH (your corporate record). The official conversion table went live in late April 2026.
Your NIB stays valid. Your licenses stay valid. The Circular is explicit: business licenses, basic requirement permits (zoning, environmental, building), and supporting licenses issued under KBLI 2020 all remain legally binding. Nothing is retroactively cancelled.
No new deed is required when only the number changes. If your company's actual activities are the same — same purpose clause in your articles of association, same business in practice — a renumbering is an administrative update, not a corporate change.

Myth-buster: three things that are NOT true

"My NIB expired when the KBLI 2025 window closed." 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.

Where you actually need to act

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. Post-window cleanup of your KBLI list costs little; carrying phantom codes into the current 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.

Your KBLI checklist

KBLI 2025 — post-window verification

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Part Two — June 30: the annual report grows teeth

The old ritual

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.

What Permenkum 49/2025 changed

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 now that the first filing cycle has started:

The RUPS approval of the annual report must be recorded in a notarial deed. Not a signed-and-scanned PDF — a deed, made by a notary.
The deed must be filed into the Ministry of Law's SABH system within 30 days of its signing — and the filing is done by the notary, not by you directly.
The fiscal-year 2025 report is the first one caught by the new rules. The SABH submission window for it opened on 1 June 2026.

Put the timeline together and the comfortable "we'll do it in December" habit is dead:

By 30 June 2026: RUPS approves the 2025 annual report (six-month statutory deadline).
Within 30 days of the deed: notary files it into SABH.
From November 2026 (per the ministry's announced enforcement timetable): sanctions start landing on companies that never filed.

The sanction that actually hurts

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:

appoint or replace directors and commissioners,
transfer shares or change shareholders,
amend its deed (including the KBLI amendments from Part One of this article),
update its registered address or capital,
and, because immigration and licensing systems read corporate data from the same pipes, it will hit walls renewing expatriate work permits and KITAS and updating OSS licensing records.

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 dormant-company trap

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.

Who gets a lighter ride

PT Perorangan (single-owner micro companies): no shareholders' meeting to convene — the regime requires the financial report itself, filed electronically, without the notarial-deed ceremony of a full PT.
Companies with non-December fiscal years: your six-month clock runs from your year end — the 30 June date is simply the deadline for the December majority.

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.

Your annual-report checklist

Annual report (FY2025) — done right before June 30

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The June 2026 calendar, on one page

Indonesia's June 2026 compliance crunch

The two deadlines side by side

Feature	KBLI 2025 transition BPS Reg 7/2025 + Joint Circular 4.S/2026	Annual report (RUPS) FY2025 UU 40/2007 + Permenkum 49/2025
Deadline	June 2026	June 30, 2026 (then 30 days to file)
Who is affected	Every business with an NIB	Every PT, including dormant ones
Automatic?	Mostly — verify in OSS/AHU	No — deed + notary filing required
Action needed when	Code split, sector reshuffled, PMA multi-code	Always (PT Perorangan: lighter e-filing)
If ignored	Wrong codes surface at next license action or due diligence	Warning, then SABH access block — company legally frozen

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.

The bottom line

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.