PT PMA Paid-Up Capital: Do the Deed and Payment Records Match?

TL;DR

A company deed can state a paid-up capital amount while the records available to its current directors do not explain how that amount was contributed.

---

The Facts

Start with the evidence behind the figure

A company deed can state a paid-up capital amount while the records available to its current directors do not explain how that amount was contributed. For a PT PMA owner, the useful first step is a documented reconciliation: identify what the company says was paid, what evidence supports it, and what remains unresolved.

A 6 October analysis by TraceWorthy highlights this practical issue. It is professional commentary about existing obligations, not an announcement of a new capital rule or proof that a particular company has broken the law. Background analysis.

Keep different capital figures separate

Article 26(10) of Investment Ministry/BKPM Regulation 5/2025 sets a general minimum placed and paid-up capital of Rp2.5 billion per PT PMA, unless another applicable rule provides otherwise. This is distinct from the regulation's investment-value requirements. Those have their own calculation rules and sector exceptions. Primary regulation, Article 26.

Do not assume that the same number must appear as paid-up capital, planned investment and investment realised in LKPM. They describe different things. A useful review explains how the records relate, rather than changing figures simply to make them look identical.

Existing companies also need to check the rules attached to their licensing history. Articles 394–395 contain transitional provisions, including specific treatment of certain relocations, extensions and business development. The general current capital figure is not a sufficient basis, by itself, to rewrite an older company's documents. Primary regulation, Articles 394–395.

Build a capital history that someone else can follow

Collect the establishment deed, later amendments, shareholder records and accounting entries for each capital event. Add available transfer evidence, bank records and other contribution documentation. Identify any non-cash contribution separately and have its legal and accounting basis reviewed.

For each event, record the date, shareholder, amount stated, evidence available and accounting treatment. A missing document is a reason to investigate; it should not be disguised by creating a retrospective story about a payment.

An illustrative review might find that a deed records Rp5 billion while the files currently explain only Rp3 billion. That does not establish what happened to the remaining Rp2 billion. It may reflect missing records, an uncompleted contribution or another history requiring evidence. The review should establish the facts before selecting a correction.

Do not automatically turn a discrepancy into a loan

An unpaid contribution, a separate shareholder loan and a later transfer from the company to a shareholder are different fact patterns. They should not be relabelled as interchangeable transactions simply to clear an unexplained balance.

Ask the notary and accountant to consider the underlying documents together. Any proposed contribution, corporate amendment or accounting correction should follow the actual facts and applicable procedure. This article does not assume an automatic tax reclassification or an automatic Coretax match across every corporate and bank record.

Bali Zero take

Make the reconciliation understandable before a share transfer, financing discussion or due-diligence exercise. A dated record of what is supported, what is missing and who will resolve it is more useful than a capital figure repeated across forms without explanation.

Keep the original evidence and an audit trail for any correction. Never backdate documents or present an unsupported payment as completed.

Sources

Primary: Investment Ministry/BKPM Regulation 5/2025, Articles 26 and 394–395.

Background commentary: TraceWorthy, 6 October 2026. Regulatory and source review: 8 October 2026.

---

Bali Zero Take

Our Analysis

Make the reconciliation understandable before a share transfer, financing discussion or due-diligence exercise. A dated record of what is supported, what is missing and who will resolve it is more useful than a capital figure repeated across forms without explanation.

Keep the original evidence and an audit trail for any correction. Never backdate documents or present an unsupported payment as completed.

Primary Source

Exa: traceworthy.com

---