Kemenkum Announces a 2026 Grace Period for PT Annual-Report Compliance

TL;DR

Indonesia’s Ministry of Law has announced temporary relief around implementation of Minister of Law Regulation No.

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The Facts

Indonesia’s Ministry of Law has announced temporary relief around implementation of Minister of Law Regulation No. 49 of 2025 (Permenkum 49/2025), the rule governing the submission of annual reports by limited liability companies.

The regulation itself has been in force since 17 December 2025. It requires a company’s annual report to be approved through a General Meeting of Shareholders (RUPS), recorded in a notarial deed, and submitted electronically through the Legal Entity Administration System (SABH). The submission deadline is 30 days after the date of the notarial deed. The regulation also provides for administrative warnings and, at the final stage, blocking of the company’s access to SABH.

In September 2026, Minister of Law Supratman Andi Agtas publicly announced two implementation measures intended to give companies more time to adjust: the relevant Non-Tax State Revenue charge, or PNBP, would be set at Rp0, and enforcement of the blocking sanction would be postponed through 31 December 2026.

Those measures should be understood carefully. The underlying annual-report obligation has not been cancelled. The announcement creates a grace period for compliance; it does not remove the statutory process established by Permenkum 49/2025.

There are also two practical boundaries. First, a Rp0 government charge does not necessarily mean the entire filing process is free. Notarial, professional, and administrative-service costs are separate from PNBP. Second, companies should confirm how the temporary measures are implemented in SABH with their notary or corporate adviser, particularly because a publicly reported ministerial announcement is not a substitute for checking the current system and any implementing instrument.

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Bali Zero Take

Our Analysis

For PT and PT PMA owners, the important message is simple: this is a cleanup window, not permission to postpone corporate governance.

The new reporting framework connects the annual RUPS, the notarial deed, the company’s annual report, and its SABH record. That creates a more visible compliance trail. A company that leaves gaps now may encounter problems later when it needs to amend its articles, replace directors or commissioners, transfer shares, update beneficial-owner information, or complete another transaction requiring access to SABH.

Foreign-owned companies in Bali often focus on operational licences, tax filings, and immigration documents while treating annual corporate housekeeping as secondary. Permenkum 49/2025 makes that separation increasingly risky. The annual report is now part of the company’s formal legal-administration record.

The safest interpretation of the announced relief is therefore conservative: use the period through the end of 2026 to identify missing annual reports, align corporate data, hold the necessary RUPS, prepare the notarial documentation, and submit within the applicable deadline.

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Next Steps

Primary Source

Exa: tvonenews.com

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