Annual SPT support is available year-round
Free Consultation
Back to Blog
ahu pt-annual-report rups permenkum-49-2025 corporate-compliance

PT Annual Reports to AHU Apply from 1 June 2026

Probosuko Adji Irfansah

Since 1 June 2026, Indonesian limited liability companies need to treat the annual report as more than an internal corporate document. Now that AHU’s annual report submission service through SABH applies, the RUPS approval of the annual report must be reported to the Minister of Law through a notary.

This change does not appear out of nowhere. AHU’s socialization material on Annual Reports of Limited Liability Companies after the enactment of Minister of Law Regulation No. 49 of 2025 reaffirms the mandate under Law No. 40 of 2007 on Limited Liability Companies and connects it with the electronic mechanism under Minister of Law Regulation No. 49 of 2025.

The practical message is simple: an annual RUPS remains mandatory, but holding the RUPS may no longer be enough. The approval of the annual report must also enter the state administration system through SABH.

What Changes?

Previously, the annual report obligation was often understood mainly as an internal governance matter: the Board of Directors prepared the report, the Board of Commissioners reviewed it, and the General Meeting of Shareholders approved the annual report and ratified the financial statements. In many private PTs, the process often stopped at internal company records.

Minister of Law Regulation No. 49 of 2025 clarifies the administrative layer. For a capital partnership company or Perseroan persekutuan modal, the RUPS approval of the annual report must be:

  1. recorded in a notarial deed;
  2. submitted to the Minister by the Board of Directors through a notary;
  3. filed electronically through SABH;
  4. supported by the notarial deed and the annual report.

In other words, corporate compliance is no longer proven only by saying “the RUPS has been held.” Companies also need to make sure the RUPS approval is properly recorded in the AHU system.

Timeline Directors Should Track

There are two deadlines that need to be separated.

First, under the Company Law, the Board of Directors must submit the annual report to the RUPS after it has been reviewed by the Board of Commissioners no later than 6 months after the end of the company’s financial year. The annual RUPS must also be held no later than 6 months after the financial year ends.

If a company’s financial year ends on 31 December 2025, the annual RUPS for the 2025 financial year generally needs to be held by 30 June 2026.

Second, under Minister of Law Regulation No. 49 of 2025, the RUPS approval of the annual report must be submitted to the Minister through a notary no later than 30 calendar days from the date the notarial deed is signed.

For example:

  • the annual RUPS is held on 20 June 2026;
  • the notarial deed is signed on 22 June 2026;
  • the SABH submission should ideally be completed by 22 July 2026.

Because AHU’s reporting system has applied since 1 June 2026, companies that have not completed the 2025 annual RUPS should promptly confirm that the financial statements, RUPS agenda, draft annual report, and notary coordination are ready.

Minimum Content of a PT Annual Report

The Company Law and Minister of Law Regulation No. 49 of 2025 both treat the annual report as an accountability document for the Board of Directors and the Board of Commissioners. At minimum, the annual report should contain:

  1. financial statements, including the end-of-year balance sheet with prior-year comparison, income statement, cash flow statement, statement of changes in equity, and notes to the financial statements;
  2. a report on the company’s activities;
  3. a report on social and environmental responsibility;
  4. details of issues arising during the financial year that affected the company’s business activities;
  5. a report on the supervisory duties carried out by the Board of Commissioners;
  6. names of members of the Board of Directors and Board of Commissioners;
  7. salaries and allowances for the Board of Directors, as well as salaries, honorarium, and allowances for the Board of Commissioners for the past financial year.

The annual report must also be signed by all members of the Board of Directors and Board of Commissioners who served during the relevant financial year. If anyone does not sign, the reason should be stated in writing.

When Must the Financial Statements Be Audited?

Not every private PT is automatically required to have its financial statements audited by a public accountant. However, Article 68 of the Company Law requires the Board of Directors to submit the company’s financial statements to a public accountant for audit if the company:

  • collects or manages public funds;
  • issues debt instruments to the public;
  • is a public company;
  • is a state-owned company;
  • has assets and/or business turnover of at least IDR 50 billion;
  • is required to be audited under other laws or regulations.

For these companies, AHU annual report compliance cannot be separated from audit readiness. The audit schedule, finalization of financial statements, RUPS, notarial deed, and SABH upload should be managed as one compliance calendar.

Risk of Non-Submission

Minister of Law Regulation No. 49 of 2025 allows administrative sanctions for a Perseroan persekutuan modal that fails to comply or passes the deadline for submitting the RUPS approval of the annual report. The sanctions are:

  1. written warning;
  2. access blocking.

SABH access blocking can become a serious operational issue. A company may be unable to process AHU services when it needs them, such as amendments to articles of association, changes to directors and commissioners, changes to shareholders, corporate actions, or legal due diligence for financing and investment.

The risk is not only “receiving a sanction.” The more practical business risk is an administrative bottleneck when the company urgently needs legal documents.

Readiness Checklist After 1 June 2026

Use this checklist to map your company’s position:

  1. Confirm the company’s financial year and annual RUPS deadline.
  2. Finalize the 2025 financial statements, including prior-year comparative figures.
  3. Check whether the company falls into a mandatory audit category.
  4. Prepare the business activity report, significant issues report, and Board of Commissioners supervisory report.
  5. Review social and environmental responsibility obligations, especially if the business operates in or relates to natural resources.
  6. Update data on directors, commissioners, shareholders, address, and company information.
  7. Schedule the annual RUPS with agenda items for annual report approval and financial statement ratification.
  8. Coordinate early with the notary for the RUPS deed and SABH submission.
  9. Keep complete records: annual report, notarial deed, submission evidence, and AHU receipt.

For PTs that have not routinely prepared annual reports, the most realistic starting point is to rebuild the 2025 reporting package first: financial statements, management list, shareholding composition, business activities, significant issues, and RUPS resolutions.

Although this obligation sits under AHU corporate administration, its impact is closely connected to accounting and tax. A proper annual report depends on clean bookkeeping. Balance sheet, income statement, cash flow statement, statement of changes in equity, and notes to the financial statements cannot be prepared at the last minute without data reconciliation.

Companies also need to keep consistency between:

  • financial statements for RUPS;
  • internal bookkeeping;
  • corporate annual income tax return;
  • transaction and VAT invoice data;
  • banking or investor documents.

If the numbers are inconsistent, the issue can move beyond AHU compliance into tax risk, audit risk, or financing obstacles.

Conclusion

The PT annual report submission system through AHU, effective since 1 June 2026, is a signal that Indonesian corporate administration is becoming more digital and easier to verify. The annual RUPS remains the main forum for shareholders, but the approval of the annual report should now be closed with electronic reporting through SABH.

For directors, the safest move is to make sure the annual report is ready, the financial statements are reliable, audit requirements have been checked, and the RUPS and notary timeline does not miss the applicable deadlines.

Need help cleaning up bookkeeping and financial statements before the annual RUPS? Arunika Consulting can help review financial statements, reconcile tax data, and prepare document readiness before the notarial process. Contact us for an initial consultation.

This article is educational and refers to AHU socialization material, the Company Law, and Minister of Law Regulation No. 49 of 2025. For specific corporate legal decisions, consult your notary, legal counsel, or relevant professional adviser.