2026 Compliance Obligation: Financial Reporting and GMS Obligations for PMA Companies

Starting in 2026, Indonesia is moving toward a more integrated and digitally monitored corporate compliance system. For all companies operating in Indonesia, compliance is no longer just an administrative requirement, it is becoming part of a closely supervised, technology-driven corporate governance framework.

Under Indonesian Company Law, every PMA company must prepare annual financial statements that comply with Indonesian Financial Accounting Standards (SAK). These reports provide transparency, support informed business decisions, and fulfill statutory reporting obligations.

Once completed, the annual financial statements must be approved through the General Meeting of Shareholders (GMS). The approved annual report must also be signed by the Board of Directors and the Board of Commissioners, confirming their responsibility for the accuracy of the company's financial information.

Depending on the company's business activities and size, financial statements may also be subject to an independent audit by a licensed public accountant.

With the implementation of the Ministry of Law and Human Rights Regulation No. 49 of 2025, corporate reporting and GMS compliance will be increasingly monitored through the Legal Entity Administration System (SABH). This digital system enables authorities to verify whether companies have fulfilled their statutory obligations in a timely manner.

Failure to comply may result in administrative sanctions, restricted access to the SABH system, and potential delays in corporate actions such as changes to directors, shareholders, or company information.

As Indonesia strengthens its corporate governance framework, PMA companies should ensure their financial reporting, GMS implementation, and statutory filings are completed accurately and on time. Staying compliant not only minimizes legal risks but also strengthens corporate credibility and supports long-term business growth.

The Consequences of Ignoring Compliance: What Every Company Must Know

Companies that fail to submit their annual report and GMS approval through the SABH may face written warnings followed by the suspension of their access to the SABH system if the obligation remains unfulfilled.

Once SABH access is blocked, the impact goes beyond a simple administrative penalty. Companies may be unable to process essential corporate actions, including:

● Changes to directors, commissioners, or shareholders.

● Amendments to the Articles of Association.

● Updates to company data and other legal filings with the Ministry of Law.

For businesses, delayed compliance can disrupt investment transactions, financing activities, corporate restructuring, mergers and acquisitions, and other strategic decisions that require updated legal documentation.

Please note that the submission of the Annual General Meeting of Shareholders (AGMS/RUPTS) is not included in our Tax and Accounting services.

Our scope of services includes:

• Reviewing the company's corporate records and compliance status for the relevant financial year.

• Preparing the Annual General Meeting of Shareholders (AGMS) resolutions relating to the 2025 Financial Statements, together with all required corporate documents in accordance with applicable Indonesian laws and regulations.

• Coordinating with the appointed notary for the preparation and execution of the notarial deed.

• Processing and submitting the required documents through the Ministry of Law's AHU online system, where applicable.

• Providing end-to-end administrative support, including document preparation, process monitoring, coordination with the notary, execution of the signing process, and ongoing follow-up until the completion of the submission.