Audit requirements in Indonesia depend on the company, not on who owns it. A foreign-owned PT PMA is not audited because it is foreign. It is audited when it crosses a legal trigger, and two thresholds matter most: total assets or turnover of at least IDR 50 billion under Article 68 of the Company Law, and total assets of at least IDR 25 billion under the annual financial report rule in Government Regulation 24 of 1998. Many investors guess wrong in both directions. Skipping a mandatory audit creates exposure in tax reviews, license renewals and shareholder reporting, and ordering an unnecessary audit wastes money. This guide covers the legal framework, the thresholds, the sector rules and what to prepare.
The Legal Framework: Separate Obligations, Separate Rules
Three obligations are often mixed up, and they come from different sources.
- The statutory audit
Article 68 of Law 40 of 2007 on Limited Liability Companies (the Company Law) lists when directors must submit the financial statements to a public accountant for audit. - The annual report to shareholders and the filing with the Ministry of Law
Article 66(1) of the Company Law requires the board to present the annual report to the general meeting of shareholders (RUPS) within six months after the financial year ends. Ministerial Regulation of Law 49 of 2025 (Permenkum 49/2025) governs the electronic submission through SABH. - The annual financial report to the Minister of Trade
Government Regulation 24 of 1998, as amended by Government Regulation 64 of 1999 (PP 64/1999), sets who must file an audited annual financial report. The ministerial regulation that set the procedure was revoked in 2025. See the section below.
Keeping them apart avoids a common mistake: assuming that a company filing a report must also be audited, or the reverse.
Who Must Have Their Financial Statements Audited
Triggers Under Article 68
Under the text of Article 68(1) of the Company Law, directors must submit the financial statements to a public accountant for audit if:
- the company’s business is collecting and/or managing public funds;
- the company issues debt acknowledgment instruments to the public;
- the company is a public company (Perseroan Terbuka);
- the company is a state-owned company (persero);
- the company has assets and/or business turnover of at least IDR 50 billion; or
- another law or regulation requires it.
The Company Law has been touched by later legislation, including the Job Creation Law package, so confirm the current wording of Article 68 against an official consolidated text before quoting it in a contract or a legal opinion.
What Foreign Ownership Does Not Change
Foreign ownership is not on the list. A PT PMA that stays below the IDR 50 billion line, and that is not in a regulated sector, has no statutory audit duty under Article 68 on its own. Lenders, parent companies and investors may still require one, and that is a commercial condition rather than a statutory one.
A Second Source: Government Regulation 24 of 1998
Separately from Article 68, Article 4 of Government Regulation 24 of 1998, as amended by PP 64/1999, requires an annual financial report to be filed by:
- a PT that is a public company, works with public funds, issues debt instruments, has total assets of at least IDR 25 billion (Article 4A lowered it from IDR 50 billion from financial year 2000), or is a debtor whose bank requires audited statements;
- foreign companies established and operating in Indonesia, including branches, sub-offices, subsidiaries and agents or representatives with authority to sign agreements; and
- state-owned and regional companies.
Article 4(2) says that report must be audited by a public accountant. A group parent that consolidates does not remove the filing duty of an Indonesian subsidiary that meets a criterion, according to the elucidation of the regulation. This test uses assets only, and a PT PMA with IDR 25 billion to IDR 50 billion in assets can fall inside it while falling outside Article 68.
The IDR 50 Billion Threshold: What It Means in Practice
Assets or Turnover: Either One Is Enough
The test is “assets and/or turnover”, so reaching IDR 50 billion on either measure is enough. Two illustrations:
- A manufacturer holds IDR 30 billion in machinery and IDR 25 billion in inventory and receivables. Total assets are IDR 55 billion, so the audit duty applies.
- A consulting firm has few assets but bills IDR 55 billion in a year. Turnover crosses the line, so the audit duty applies.
Why Investment Value Is Not Total Assets
Foreign investors often confuse two numbers. Under Investment Minister Regulation 5 of 2025, a PT PMA must have an investment plan of more than IDR 10 billion per five-digit KBLI code and per location, excluding land and buildings. That figure is a plan, not the balance sheet. A company can plan IDR 10 billion and still report total assets far below IDR 50 billion in its first years. Check the balance sheet, not the investment plan. Our guide to PT PMA establishment costs and the analysis of BKPM Regulation 5 of 2025 explain the capital side.
If your numbers sit close to the line, ask your accountant for a forecast. A company that expects to cross IDR 50 billion in the coming year should plan the audit before the year closes. For a view of the books that auditors will want to see, start with our accounting and bookkeeping in Indonesia service.
Explore Our Services Accounting and Bookkeeping in Indonesia
The Ministry of Trade Annual Report: Still in Force, but the Procedure Was Revoked
Companies file the annual financial report (LKTP) with the Minister of Trade. Until 2025, the procedure sat in Ministerial Regulation of Trade 25 of 2020: submission through the SIPT portal, a six month deadline, and warnings leading to possible license revocation.
Ministerial Regulation of Trade 26 of 2025, signed on 30 June 2025 and effective on promulgation, revoked Permendag 25/2020 together with three other trade regulations (Article 1 letter c). It has no transitional provision and names no replacement.
What that means, on the texts we read:
- The duty at regulation level appears to remain. The criteria, the IDR 25 billion asset trigger and the audited-report rule are in Government Regulation 24 of 1998 as amended by PP 64/1999. The official JDIH BPK database lists Government Regulation 24 of 1998 as in force and shows no revoking regulation.
- The procedure and sanctions are uncertain. The SIPT process, the six month deadline and the warning regime came from the revoked Permendag. We could not find a replacement.
Practical approach: treat a company with assets of IDR 25 billion or more, or a bank loan that requires audited statements, as within scope. Keep audited statements ready, and confirm with the Ministry of Trade or your adviser which channel and deadline apply now. Do not assume the duty has disappeared because the implementing regulation was revoked.
Sectors Where Sector Rules Add an Audit Duty
Some companies are audited because of what they do, not because of their size. Article 68(1) already covers companies that collect or manage public funds, issue debt to the public, are public companies or are state-owned. In practice this brings in banks, insurers, multifinance companies, pension funds and listed issuers, which also follow the rules of the Financial Services Authority (OJK).
For a PT PMA outside these sectors, the question is usually the IDR 50 billion test or a contractual requirement from a lender or investor. If you operate in a regulated sector, check the sector regulator’s rules as well, since they can set requirements beyond Article 68.
Who Conducts Audits in Indonesia
A statutory audit must be performed by a licensed public accountant (Akuntan Publik) working through a licensed public accounting firm (KAP). Your group’s international auditor cannot sign the Indonesian statutory opinion unless it operates through a licensed local firm. Many multinational networks do, so ask who will sign.
The opinion is on fair presentation under Indonesian Financial Accounting Standards (SAK). Since 1 January 2025, SAK EP replaces SAK ETAP for entities without public accountability. If your parent reports under IFRS, plan the reconciliation early, because the Indonesian statements and the group statements will not always match line for line.
How Audit Connects to Permenkum 49/2025
Permenkum 49/2025 was issued on 11 December 2025, takes effect on promulgation and replaces Permenkum 21 of 2021 (Articles 33 and 34). For an ordinary PT (a capital partnership company), Articles 16 to 20 set the annual report process:
- Six months to the RUPS. The directors deliver the annual report to the general meeting of shareholders after review by the board of commissioners, no later than six months after the financial year ends (Article 16(1)).
- 30 days to SABH. The RUPS approval is recorded in a notarial deed and submitted to the Minister through the notary within 30 days of the deed being signed, electronically through SABH with the deed and the annual report uploaded (Article 16(3) to (5)).
- What the annual report must contain. At minimum, financial statements (year-end balance sheet with prior year comparison, profit and loss, cash flow, changes in equity and notes), a report on company activities, the social and environmental responsibility report, issues that affected the business, the commissioners’ supervisory report, and the names and remuneration of directors and commissioners (Article 16(6)).
- Sanctions. A company that misses the filing may receive a written warning through a SABH notification or email. If it still does not comply within 30 days of the notification, its access to SABH is blocked (Articles 17 and 18). It can apply to reopen access by filing the missing documents (Articles 19 and 20).
The regulation does not decide who must be audited. It refers to companies that “wajib diaudit” (must be audited) in its document lists (for example Article 12(1)(h)) and leaves the audit duty to the Company Law and sector rules. Where an audit applies, it has to be finished before the RUPS approves the statements, so audit timing drives the whole calendar.
Because SABH is the system used to file changes to directors, commissioners and shareholders, a blocked account can stall those changes in practice. Our note on what every PT must know about Permenkum 49/2025 goes through the filing in detail.
A December year end gives a calendar like this: statements January to February, audit February to April, RUPS by 30 June, SABH submission within 30 days of the deed.
What Makes a Company Audit-Ready
Records the Auditor Will Ask For
- Books kept on SAK EP and reconciled each month
- Monthly bank reconciliations and a clean cut-off at year end
- Supporting documents for revenue, payroll and BPJS contributions
- Consistent revenue recognition
Our guide on bookkeeping requirements for a PT in Indonesia covers the record-keeping side, and the PT PMA annual compliance checklist shows where the audit sits in the yearly calendar.
Group and Tax Documentation
- Documented intercompany transactions and confirmation of balances with the parent
- Reconciliation to group consolidation where the parent requests it
- Transfer pricing documentation under Minister of Finance Regulation 172 of 2023, where it applies
Auditors often ask for these late in the process, which is why they are best prepared early. Strong files also help in a tax review, so link the audit work with your tax compliance in Indonesia calendar.
How XPND Supports Audit Readiness
XPND does not perform statutory audits, which are reserved for licensed public accountants. What we do is get the company ready for one: monthly accounting and reconciliations, tax filings that tie to the books, and the corporate secretary work around the RUPS and SABH submission. If you are unsure whether the IDR 50 billion test applies to you, talk to XPND about your audit position before the year closes.
