The Minister of Law has issued Minister of Law Regulation No. 49 of 2025, under which the Board of Directors of a limited liability company (“PT”) is required to submit the annual report that has been approved by the General Meeting of Shareholders (“GMS”) to the Minister of Law as part of the company’s compliance obligations.

The annual report must be submitted by the Board of Directors to the GMS no later than 6 months after the end of the PT’s financial year. Prior to its submission to the GMS, the annual report must first be reviewed by the Board of Commissioners.

Once the annual report has been approved by the GMS, such approval must be set forth in a notarial deed. Subsequently, the Board of Directors, through a notary, is required to submit a notification of the approval of the annual report to the Minister of Law within a maximum period of 30 days from the date of execution of the notarial deed.

The submission is carried out electronically through the Legal Entity Administration System of the Ministry of Law (Sistem Administrasi Badan Hukum or “SABH”) by uploading supporting documents in the form of the notarial deed of approval of the annual report and the annual report of the PT itself. The annual report must at least contain financial information, a report on the company’s business activities, the implementation of corporate social and environmental responsibility, issues affecting business activities, a report on the supervisory duties performed by the Board of Commissioners, the composition of the Board of Directors and the Board of Commissioners, as well as information on salaries, honoraria, and allowances.

After the notification has been fully received, the Ministry of Law will issue an acknowledgment letter as evidence that the reporting obligation has been fulfilled.

If a PT fails to fulfill its obligation to submit the annual report or exceeds the stipulated time limit, the PT may be subject to administrative sanctions in the form of a written warning and the blocking of access to the Ministry of Law’s SABH system.

Minister of Law Regulation No. 49 of 2025 came into force on 17 December 2025 and simultaneously revoked the previous regulation. Therefore, the Board of Directors of a PT must ensure that the obligation to submit the annual report is carried out in a timely manner and in accordance with the applicable regulations in order to avoid potential sanctions. Should you be interested or wish to obtain further information regarding the regulations on the obligation to submit annual reports, please do not hesitate to contact us.