Many foreign investors are surprised when they suddenly receive a notification in the OSS RBA system stating that their business license status has changed to warning, and in some cases their Business Identification Number (NIB) is suspended due to issues related to the Proof of Capital Injection for Foreign Investment Limited Liability Company (PT PMA).
This issue does not occur because the investor lacks capital. Instead, it arises because the capital injection and investment reporting processes do not comply with banking validation standards and BKPM supervision procedures.
Why does this issue frequently occur?
Because in practical implementation, many parties only prepare a “statement of capital injection” in corporate documents, while in reality the funds are:
- Not actually transferred into the PT PMA corporate bank account
- Transferred using methods that do not meet banking compliance requirements
- Reported in LKPM without valid financial evidence
Since 2025, supervisory integration between OSS RBA, BKPM, and the banking system through the Foreign Exchange Flow Report (LLD) has become significantly stricter.
When LKPM reports state that “investment realization has taken place,” but there is no supporting bank record, no increase in assets, or a mismatch in account balances, the system may trigger:
- Administrative warnings
- Requests for clarification
- Suspension of the NIB
This article explains the technical standards used to validate the Proof of Capital Injection for Foreign Investment Limited Liability Company (PT PMA), what is considered legally valid, and how to recover a suspended license.
Golden Rules Validasi Bank untuk Bukti Setor Modal PT PMA
Many investors assume that proof of capital injection is sufficiently demonstrated through:
- ATM receipts
- Basic transfer slips
- Screenshots of bank statements
From a compliance perspective, these are not sufficient.
To ensure that capital injection is recorded as Equity (Share Capital) rather than Shareholder Loan, several technical rules must be followed.
Below are the key compliance principles.
Source of funds must clearly originate from the registered shareholders
Capital funds must be transferred from the bank account of the shareholder listed in the corporate deed to the official bank account of the PT PMA.
The following transfer methods are high risk and may be rejected as valid capital:
- Transfers from third-party accounts
- Transfers from the personal account of a director who is not a shareholder
- Cash deposits through teller counters without sender identification
If the source of funds is inconsistent with the shareholder structure, banks frequently classify the transaction as a temporary loan rather than share capital.
The consequences include:
- The transfer is not recognized as valid capital injection
- The Proof of Capital Injection becomes disputable during BKPM audit
- The LKPM report may be flagged for clarification
The transfer remark field must be completed (this is the most critical validation element)
For every capital injection transfer, the remark field must clearly state:
Capital Injection for [Company Name] or Share Capital Subscription for [Company Name].
This element is crucial because if the remark field is left empty, banks frequently classify the transfer as a shareholder loan, not as Equity or Capital Injection.
The implications include:
- Inconsistencies in financial statements
- Unbalanced equity ratios
- Difficulty in verifying transaction authenticity during audit sampling
The transfer remark functions as the legal identifier of a capital transaction. Without a proper remark, the capital injection may not be considered valid.
LLD (Foreign Exchange Flow) validation for funds transferred from overseas
For capital originating from overseas, the receiving bank in Indonesia is required to report the transaction to Bank Indonesia through the LLD reporting mechanism.
The transaction code must be recorded as:
Equity Participation or Capital Injection
and not as a trade payment, services remittance, or personal transfer.
If the LLD code is entered incorrectly, the transaction may not be recorded as Foreign Direct Investment (FDI) at the national reporting level.
This creates a significant risk during BKPM investment verification.
Investors must ensure that the bank records the transaction as FDI Equity Capital Injection.
How to Complete LKPM Reporting so Capital Injection is Recognized as Valid by BKPM
Many tax consultants are familiar with tax reporting obligations, yet LKPM reporting requires a different technical approach and supervisory framework.
When must capital injection begin to be reported?
Reporting begins in the first quarter following the issuance of the NIB.
Failure to submit LKPM may trigger:
- Inactive status indicators
- OSS administrative warnings
- Potential clarification requests
Correct input for investment realization fields
Funds must be recorded under:
- Fixed Capital: If funds are used for asset acquisition, equipment, renovation, or facility development.
- Working Capital: If funds remain as cash in the corporate bank account.
A common mistake occurs when iInvestment realization is reported, but the corporate bank balance reflects zero. This immediately triggers system suspicion and may escalate to a field audit.
Documents commonly requested during sampling review
Although LKPM operates under a self-assessment mechanism, BKPM may still request supporting documents including:
- Bank statements from the month the capital was injected
- Bank-validated deposit slips
- Proof of capital injection remarks
- Asset purchase documentation (if realization has begun)
If documentation is inconsistent, the LKPM report may be:
- Returned for correction
- Flagged for clarification
- Escalated toward permit suspension
What to Do If Your NIB Has Already Been Suspended?
At this stage, investors often experience concern or panic.
However, the situation can still be recovered if corrective actions are taken appropriately.
Below is a recommended recovery plan.
Immediately perform a supplemental capital injection
Funds must be genuinely transferred into the PT PMA corporate bank account.
Ensure that:
- The source of funds originates from the registered shareholder
- The transfer remark states capital injection
- Bank validation is obtained
The sooner corrective capital is injected, the lower the risk of prolonged sanctions.
Revise the LKPM report for the relevant reporting period
Reopen the affected period and:
- Update the investment realization entry
- Attach valid proof of capital injection
- Provide clarification in the remarks section
BKPM generally prioritizes real capital supported by evidence, rather than large unrealized or fictitious investment figures.
Submit clarification to the BKPM Implementation Control Unit
Supporting evidence may be submitted through:
- Formal letter
- Email correspondence to the implementation control division
- Clarification features in OSS RBA
The objective is to demonstrate corrective intent, prove that capital has been injected, and explain discrepancies in previous reporting.
Consider adjusting capital structure if the declared capital is unrealistic
If the declared capital structure is excessively high and impractical to fulfil, the company may consider restructuring its capital and updating company data in OSS so that it reflects realistic and verifiable capital injection capacity.
It is safer to maintain a smaller capital structure that is genuinely injected, than a large capital figure that exists only on paper and is never realized in practice.
Additional Technical Considerations
These recommendations help prevent future compliance issues.
Temporary use of escrow or holding accounts
Escrow arrangements may be used temporarily when:
- The PT PMA corporate bank account is not yet available
- The director is still located overseas
Once the PT PMA account becomes active:
- Funds must be transferred immediately
- Transfer evidence must remain clear and traceable
Escrow should only serve as a transitional phase, not a permanent solution.
Do not use capital funds for personal transactions
BKPM analyzes transaction behavior patterns.
If substantial capital funds are injected and later transferred to a personal account without legitimate business justification, the transaction may be classified as:
- Hidden divestment activity
- Potential money laundering indication
- Misuse of investment capital
Capital funds must be used to support:
- Operational activities
- Asset procurement
- Business development and not personal transactions
Need Support to Validate the Proof of Capital Injection for Your Foreign Investment Limited Liability Company (PT PMA)?
If your NIB status is under warning or at risk of suspension due to issues related to the Proof of Capital Injection for PT PMA, or if you need clarity on how to:
- Ensure that capital injection records are compliant with banking validation standards
- Align capital transactions with LKPM investment realization reporting
- Prepare supporting documentation for OSS or BKPM clarification
The XPND team supports companies in resolving compliance findings related to capital injection records and LKPM reporting.
Our role is to help you ensure that:
- Capital funds are properly recorded and verifiable
- Supporting documents remain consistent across bank statements, LKPM reports, and OSS data
- Your licensing status and investment position remain protected during review or monitoring
If your company is currently facing NIB warnings, clarification requests, or uncertainty regarding capital injection validation, you may contact our team to discuss your case and explore available remediation options.
