Company Annual Report Filing Through SABH Under Regulation 49 of 2025

Minister of Law Regulation 49 of 2025 was promulgated on 17 December 2025 and took effect the same day, replacing Regulation 21 of 2021. Article 16 requires the board of directors to submit the annual report to the General Meeting of Shareholders within six months after the financial year ends, once the board of commissioners has reviewed it. That part is familiar. The change is in the next paragraphs.

Article 16(2) requires the GMS approval to be set out in a notarial deed. Article 16(3) requires the directors to submit that approval to the Minister through the notary within 30 days of the date the deed is signed. Filing is electronic, through the SABH system, with two documents: the deed and the annual report.

Minutes kept in a company file are therefore no longer enough. A company that approved its annual report by circular resolution needs to change that practice.

What the report must contain

Article 16(6) lists seven minimum items: financial statements, a report on the company’s activities, implementation of social and environmental responsibility, details of problems during the year, the commissioners’ supervision report, the names of directors and commissioners, and their salaries and allowances.

The financial statements must include at least a balance sheet compared with the prior year, an income statement, a cash flow statement, a statement of changes in equity, and notes. A company that has prepared only a balance sheet and income statement needs to prepare the rest at year-end close.

Where accountants fit

The regulation does not mention public accountants. The GMS approves the annual report. The audit obligation still comes from Article 68 of the Company Law and from loan covenants, tenders, or sector rules. For companies in those categories, SABH adds a reason to appoint the auditor early: the auditor’s report comes before the GMS, the GMS before the deed, and the deed starts the 30 days.

If a company does not file

Article 17 provides for a written warning and blocked access. The warning arrives by SABH notification or email. If the obligation is still not met within 30 days, Article 18 closes the company’s access to SABH.

The effect appears when the company needs SABH for something else. The Directorate General of General Legal Administration said in June 2026, as reported at the time, that verifiers first confirm the annual report has been filed before processing transactions such as a change of directors or a share transfer.

On timing, a report dated 28 October 2026 cited the Directorate General’s official account: written warnings in December 2026 for companies that have not filed for 2025, blocking from 2 January 2027, and filing for 2026 from 2 January to 30 June 2027. The original announcement should be checked on the Directorate General’s own channels.

What to do now

First, check whether the 2025 annual report has been approved by the GMS and filed in SABH. If a meeting was held without a deed, ask the notary what form of deed is still available. Then build the 2026 calendar backwards from 30 June 2027: GMS date, auditor’s report date where an audit is required, and year-end close.

Finally, assign one person to own the report, because the seven items come from finance, the corporate secretary, and HR. Audit thresholds are set out on our page on audit requirements in Indonesia.