PT PMA First-Year Compliance Checklist 2026

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Why Your First Year Matters Most

Congratulations on establishing your PT PMA. The hard part of incorporation is done, but the compliance clock is now ticking. Indonesia has a complex web of reporting obligations that begin immediately after your company receives its NIB (Nomor Induk Berusaha). Missing a single deadline can result in penalties ranging from warning letters to license revocation.

This guide walks you through every compliance obligation in your PT PMA's first 12 months, organized chronologically so you know exactly what to do and when.

2026 Compliance Alert: Mandatory Annual Reports

Regulation 49/2025 (Permenkum 49/2025, in force since 17 December 2025): the Ministry of Law mandates that all PT PMAs submit a notarized Annual Report (GMS Approval) via the SABH system — within 30 days of the notarial deed, with the GMS held no later than 6 months after fiscal year-end. This is separate from your quarterly LKPM reports. Failure to submit triggers a written warning followed by blocking of the company's SABH/AHU access, which freezes all future corporate-legal changes (directors, articles, shares). Read the full guide on the 2026 Corporate Reporting Mandate →

Month 1: Immediate Post-Incorporation Obligations

The first 30 days after your PT PMA is officially registered are the most critical. Several time-sensitive registrations must happen simultaneously.

NPWP Registration (Tax ID)

Your PT PMA should receive its NPWP (Nomor Pokok Wajib Pajak) automatically through the OSS system when you obtain your NIB. However, verify this by:

Logging into your OSS account and checking the NPWP field
Visiting the local KPP (Kantor Pelayanan Pajak) to confirm activation
Registering for DJP Online access at pajak.go.id

Required documents for DJP Online activation:

Company NPWP
Director's NPWP (personal)
Company deed (Akta Pendirian)
SK Kemenkumham (AHU approval letter)
NIB printout

Bank Account Opening

Open a corporate bank account within the first two weeks. You will need this for:

Capital deposit proof
Tax payments
BPJS contributions
Payroll processing

Recommended banks for PT PMA: BCA, Mandiri, BNI, CIMB Niaga. Most require:

Minimum initial deposit of IDR 10-50 million
Director's personal appearance with passport and KITAS
Full company documentation set

LKPM Initial Report

The LKPM (Laporan Kegiatan Penanaman Modal) is your investment activity report to BKPM. Your first report must be filed within 30 days of NIB issuance.

LKPM Detail	Requirement
Filing method	OSS RBA system (online)
First report deadline	30 days after NIB
Quarterly deadlines	Q1: Apr 15, Q2: Jul 15, Q3: Oct 15, Q4: Jan 15
Content	Capital realization, employment, production status
Penalty for non-filing	Warning letter, then license suspension

BPJS Registration

If you hire any employees (including yourself as a foreign director with KITAS), BPJS registration must happen within 30 days.

Two separate registrations:

BPJS Kesehatan (health insurance) - Register at bpjs-kesehatan.go.id
BPJS Ketenagakerjaan (employment insurance) - Register at bpjsketenagakerjaan.go.id

See our detailed guides on BPJS Kesehatan and BPJS Ketenagakerjaan for contribution rates and enrollment procedures.

Month 1-3: Tax Setup and First Filings

PPh 25 Monthly Installments

Even before your company generates revenue, you may need to file monthly PPh 25 (corporate income tax installment) returns. For new companies, the first year is typically "nihil" (zero), but the filing obligation still exists.

Monthly PPh 25 timeline:

Due date: 15th of the following month
Filing deadline: 20th of the following month
Example: January PPh 25 is due for payment by February 15, filed by February 20

PPh 21 Employee Tax

If you have employees, you must withhold and remit PPh 21 (employee income tax) monthly.

PPh 21 Bracket (2026)	Annual Income	Rate
Bracket 1	Up to IDR 60M	5%
Bracket 2	IDR 60M - 250M	15%
Bracket 3	IDR 250M - 500M	25%
Bracket 4	IDR 500M - 5B	30%
Bracket 5	Above IDR 5B	35%

Important: Foreign workers (TKA) are taxed as residents if they hold KITAS and are present in Indonesia for more than 183 days in 12 months.

PKP Registration Assessment

Assess whether you need PKP (VAT) registration:

Mandatory: If projected annual gross revenue exceeds IDR 4.8 billion
Voluntary: If your clients require VAT invoices (e-Faktur) or you want to claim input VAT credits
Timeline: Apply at your KPP; processing takes 5-10 working days

Once registered as PKP, you must:

Issue e-Faktur for every taxable transaction
File monthly SPT Masa PPN (VAT return) by the end of the following month
Maintain proper VAT records

Month 3-6: Operational Compliance

Company Regulations (Peraturan Perusahaan)

If you employ 10 or more workers, you must draft and register Company Regulations (PP) with the local Manpower Office (Disnaker) within 30 days of reaching the threshold.

Required contents:

Working hours and overtime rules
Wages and allowances
Leave policies (annual, sick, maternity)
Disciplinary procedures
Termination conditions

Wajib Lapor Ketenagakerjaan

Mandatory employment reporting to the Manpower Office must be done:

Initial report: Within 30 days of commencing operations
Annual update: Every December
Upon changes: Within 30 days of significant workforce changes

Environmental Compliance

Depending on your business activities and KBLI codes, you may need:

Risk Level	Requirement	Timeline
Low risk	Standard NIB (no additional permits)	Automatic with NIB
Medium-low	Standard certificate via OSS	Apply within 30 days
Medium-high	Verified certificate (inspected)	30-90 days
High risk	Full environmental permit (AMDAL/UKL-UPL)	3-6 months

Month 6-9: Mid-Year Review and Adjustments

LKPM Semester Review

By mid-year, you should have filed at least two LKPM reports. Review them to ensure:

Capital realization figures are accurate
Employment numbers match actual headcount
Production/revenue figures align with your tax filings

Common discrepancy: LKPM reports capital in USD (original investment plan) while tax filings are in IDR. Ensure the exchange rates used are consistent.

Transfer Pricing Documentation

If your PT PMA conducts transactions with related parties (parent company, affiliates, shareholders), you need transfer pricing documentation. This requirement applies regardless of transaction volume.

Three tiers of documentation:

Master File - Global business overview
Local File - Indonesian entity transactions
Country-by-Country Report - For groups with consolidated revenue above IDR 11 trillion

Most PT PMAs need at minimum the Local File, which must be available by the corporate tax return deadline.

Tax Compliance Review

Conduct a mid-year tax health check:

Are all monthly PPh 21 and PPh 25 filings current?
Are VAT returns filed on time (if PKP)?
Is withholding tax (PPh 23/26) being applied to service payments?
Are BPJS contributions calculated on correct salary base?

Month 9-12: Year-End Preparation

Annual Tax Return Preparation

Your first corporate income tax return (SPT Tahunan PPh Badan) is due by April 30 of the following year. Preparation should begin in Q4.

Key documents to prepare:

Complete general ledger and trial balance
Financial statements (balance sheet, P&L, cash flow)
Fixed asset register
Accounts receivable and payable aging
Bank reconciliations
Tax reconciliation worksheets

Financial Statement Preparation

Even if an audit is not mandatory in your first year, prepare proper financial statements following Indonesian PSAK (accounting standards):

Balance Sheet (Neraca)
Profit and Loss Statement (Laporan Laba Rugi)
Cash Flow Statement (Laporan Arus Kas)
Statement of Changes in Equity (Laporan Perubahan Ekuitas)
Notes to Financial Statements (Catatan Atas Laporan Keuangan)

LKPM Annual Summary

Your Q4 LKPM report (due January 15 of the following year, per BKPM Regulation 5/2025) serves as your annual summary. Ensure it accurately reflects:

Total capital invested (paid-up vs authorized)
Full-year employment figures (Indonesian and foreign workers)
Revenue and production data
Planned activities for the next year

Complete First-Year Compliance Calendar

Month	Obligation	Authority	Deadline
1	NPWP verification	DJP	Immediate
1	Bank account opening	Bank	Within 2 weeks
1	LKPM initial report	BKPM/OSS	30 days after NIB
1	BPJS registration	BPJS	30 days after hiring
1	Wajib Lapor initial	Disnaker	30 days after operations begin
Monthly	PPh 25 payment & filing	DJP	15th/20th of following month
Monthly	PPh 21 payment & filing	DJP	10th/20th of following month
Monthly	BPJS contributions	BPJS

Common First-Year Mistakes

Mistake 1: Ignoring LKPM Reports

Many new PT PMA owners do not realize LKPM is mandatory from day one. BKPM tracks compliance and will issue warning letters. Three consecutive missed reports can trigger license review.

Mistake 2: Late BPJS Registration

Some companies wait until they have "enough employees" to register for BPJS. The law requires registration for even one employee. Directors on KITAS count as employees for BPJS purposes.

Mistake 3: Missing PPh 21 for Foreign Directors

Foreign directors receiving salaries or director fees must have PPh 21 withheld. Even if the salary is paid from overseas, the Indonesian entity must report and withhold the tax if the director is a tax resident.

Mistake 4: Not Separating Personal and Company Finances

Using personal bank accounts for company transactions creates tax and audit risks. Always use the corporate bank account for all business transactions.

Mistake 5: Forgetting Withholding Tax on Services

When your PT PMA pays for services (legal, consulting, marketing), you must withhold PPh 23 (2% for resident providers) or PPh 26 (20% for non-resident providers) and remit it to the tax office.

Mistake 6: Incomplete OSS Profile

Your OSS/NIB profile must be kept current. Changes in directors, shareholders, address, or KBLI codes must be updated within 30 days. An outdated OSS profile can delay license renewals.

Estimated First-Year Compliance Costs

Item	Estimated Annual Cost
Accounting/bookkeeping service	IDR 3-8M/month
Tax filing service (monthly + annual)	IDR 2-5M/month
Annual audit (if required)	IDR 30-100M
BPJS contributions (per employee)	~8-11% of salary
Virtual office (if needed)	IDR 5,000,000 via Bali Zero
Company revision (Akta Perubahan)	Contact Bali Zero for quote
Legal compliance review	IDR 5-15M

How Bali Zero Can Help

Setting up a PT PMA is just the beginning. Bali Zero provides end-to-end compliance support including:

Company formation: IDR 20,000,000 for new PT PMA setup
Monthly bookkeeping and tax filing through our accounting partners
LKPM reporting as part of our compliance package
BPJS registration and management
Annual tax return preparation
Company revisions when you need to update your deed

Frequently Asked Questions

When is the first LKPM report due for a new PT PMA?

Your first LKPM report is due within 30 days of NIB issuance, covering the period from incorporation to the end of that quarter. Subsequent reports are due quarterly, within the 1st–15th of the month after the quarter: Q1 by April 15, Q2 by July 15, Q3 by October 15, and Q4 by January 15 (deadlines extended from the 10th to the 15th by BKPM Regulation 5/2025).

Do I need to register for PKP immediately?

PKP (Pengusaha Kena Pajak) registration is mandatory once your gross revenue exceeds IDR 4.8 billion per year. However, you can register voluntarily before reaching that threshold. If you deal with VAT-registered suppliers or clients, early registration is recommended.

What happens if I miss BPJS enrollment deadlines?

Failure to enroll employees in BPJS within 30 days of hiring can result in administrative sanctions including denial of government services, business license restrictions, and penalties. The company can be fined and lose access to government tenders and permits.