PT PMDN Annual Compliance Checklist 2026: Every Obligation Indonesian Companies Must Meet

A manufacturing company in East Java needed to amend its Articles of Association in February 2026 to reflect a capital increase that had been approved at the previous year’s shareholder meeting. The legal team submitted the amendment through SABH and received an immediate system block. The reason: the company had held its Annual General Meeting of Shareholders in June 2025 but had never submitted the notarised meeting resolutions to SABH within the required 30-day window. Until the outstanding submission was processed, no further corporate filings could proceed. The capital amendment, which was needed to secure a credit facility from a state bank, was delayed by three weeks.

This is the pattern that Minister of Law Regulation (Peraturan Menteri Hukum or Permenkum) No. 49 of 2025 was designed to create. By integrating SABH access directly with annual reporting compliance, the Ministry of Law transformed what was previously an inconsistently enforced administrative obligation into a hard operational dependency. For finance and legal teams managing PT PMDN compliance, this means the annual governance calendar is no longer a back-office concern. It is a prerequisite for the company’s ability to execute corporate actions throughout the year.

This guide sets out the complete compliance framework for PT PMDN companies in 2026, organized by obligation type and timeline, with the regulatory basis and operational consequences for each.

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What Changed in 2026 That Finance Teams Need to Know

Two regulatory developments have materially raised the compliance bar for PT PMDN companies since late 2025.

Permenkum No. 49 of 2025, which took effect on 17 December 2025, replaced the previous company administration framework under Permenkum No. 21 of 2021 and introduced mandatory annual reporting through SABH with real enforcement. Under the new regime, a PT PMDN that fails to submit its RUPS annual resolution through SABH within the prescribed deadline loses access to the system entirely. With SABH blocked, the company cannot process any corporate change: director appointments, share transfers, address amendments, capital increases, or restructuring actions. Every downstream corporate action depends on an unblocked SABH status, which depends on annual reporting compliance being current.

PP No. 28 of 2025 on Risk-Based Business Licensing strengthened post-licensing supervision and accelerated the escalation path from LKPM non-compliance to license suspension. The combination of these two regulations means that a PT PMDN with compliance gaps in either its corporate governance track or its investment reporting track faces operational disruption that is no longer administrative in nature.

For companies with in-house finance and legal functions, the practical implication is that annual compliance across the corporate governance, tax, and licensing tracks needs to run as an integrated calendar rather than three separate processes managed by different teams against different deadlines.

Monthly Obligations

PPh 21 withholding, remittance, and reporting

Every PT PMDN with employees must withhold Income Tax Article 21 (Pajak Penghasilan Pasal 21 or PPh 21) monthly under Government Regulation (Peraturan Pemerintah or PP) No. 58 of 2023 and Ministry of Finance Regulation (Peraturan Menteri Keuangan or PMK) No. 168 of 2023. The Average Effective Rate (Tarif Efektif Rata-rata or TER) system applies from January through November, with the December reconciliation calculated against the progressive Article 17 brackets. Withholding must be remitted by the 10th and reported through Coretax by the 20th of the following month.

For a detailed breakdown of TER categories, PTKP classification, and the December reconciliation methodology, refer to the PPh 21 calculation guide. 

VAT reporting

Registered Taxable Entrepreneurs (Pengusaha Kena Pajak or PKP) must file monthly VAT returns through e-Faktur within Coretax and remit any VAT payable by the end of the following month. PT PMDN companies that have crossed the IDR 4.8 billion annual turnover threshold but have not yet registered as PKP are in a compliance exposure position that typically surfaces during tax audits.

BPJS contributions

BPJS Kesehatan and BPJS Ketenagakerjaan contributions for all enrolled employees must be paid by the 10th of the following month. The contribution base is the reported wage, and the rates are fixed by regulation. Late payment attracts a 2 percent per month penalty on the outstanding amount, which accumulates quickly across a sizeable workforce.

PPh 25 monthly instalments

Companies subject to advance Corporate Income Tax instalments must remit PPh 25 by the 15th and report by the 20th of each month. The instalment amount is set based on the prior year’s tax liability.

Quarterly Obligations

LKPM (Investment Activity Report) submission

Under PP No. 5 of 2021 on Risk-Based Business Licensing as strengthened by PP No. 28 of 2025, PT PMDN companies classified as medium or large scale must submit LKPM to BKPM (Badan Koordinasi Penanaman Modal) through OSS RBA every quarter. Submission windows are the 1st to 15th of January, April, July, and October. Small-scale PT PMDN companies submit semi-annually, with windows in January and July.

A point worth stating explicitly: the compliance obligations in this checklist apply to every PT PMDN regardless of company size. What changes with scale is not whether the obligations exist, but their frequency and intensity. A PT PMDN that starts as a small-scale company and grows into medium or large scale does not receive a formal notification that its reporting obligations have changed. The reclassification is automatic once the investment threshold is crossed, and companies that are unaware of it routinely find themselves filing at the wrong frequency without realising it.

The LKPM must reflect actual investment realization for the period, including capital expenditure, employment data, and business activity descriptions. Four consecutive quarters of zero realization triggers automated warnings from the OSS system and can escalate to license suspension under PP No. 28 of 2025.

One classification issue that frequently affects growing PT PMDN companies: scale classification for LKPM purposes is based on total investment value, not paid-up capital. A company whose total investment realization has grown above the medium-scale threshold without a corresponding reclassification may be filing at the wrong frequency. Finance teams should confirm the applicable LKPM classification each year and adjust the reporting schedule accordingly. For the full LKPM reporting methodology including investment component classification and common submission errors, the LKPM reporting guide covers the process in detail.

Annual Obligations: Corporate Governance Track

RUPS Tahunan (Annual General Meeting of Shareholders)

Under Law No. 40 of 2007 on Limited Liability Companies (Undang-Undang Perseroan Terbatas or UUPT), every PT must convene an Annual General Meeting of Shareholders (Rapat Umum Pemegang Saham Tahunan or RUPS Tahunan) within six months of the financial year-end. For a January-to-December fiscal year, the deadline is 30 June. The meeting must formally approve the Board of Directors’ annual report, ratify the prior year’s financial statements, and resolve the allocation of profits or treatment of losses.

Notarisation and SABH submission

This is the obligation with the most direct operational consequence under the 2026 framework. Under Permenkum No. 49 of 2025, the RUPS Tahunan resolutions must be recorded in a notarial deed and submitted to the Ministry of Law through SABH within 30 days of the deed’s signing. The notary submits the notification through SABH on behalf of the company.

Missing this 30-day window is not a minor administrative lapse. It blocks the company’s entire SABH profile until the late submission is processed. Any corporate action that requires a SABH filing, including director changes, shareholder transfers, capital amendments, and restructuring approvals, cannot proceed while the company’s profile is blocked. Legal and finance teams that schedule this submission as a low-priority year-end task are routinely the ones managing the downstream consequences when a time-sensitive corporate action is needed mid-year.

Annual report submission to SABH

Permenkum No. 49 of 2025 requires PT persekutuan modal, which includes all standard PT PMDN companies, to submit the annual report approved at the RUPS Tahunan electronically through SABH. The report must include the financial statements and a summary of the company’s activities for the year.

Beneficial ownership data verification

Under the Presidential Regulation on Beneficial Ownership, PT PMDN companies must maintain current and accurate beneficial ownership records. Any change in beneficial owner that occurred during the year must be updated in SABH. Inaccurate or incomplete beneficial ownership data blocks future SABH filings and creates exposure during due diligence processes.

Annual Obligations: Tax Track

SPT Tahunan Badan (Annual Corporate Income Tax Return)

Every PT PMDN must file its annual Corporate Income Tax Return through Coretax no later than the end of April for a January-to-December fiscal year. The return must include the fiscal reconciliation schedule, all withholding tax summaries, and documentation supporting any tax facility claims. Under the General Tax Provisions Law (Undang-Undang Ketentuan Umum dan Tata Cara Perpajakan or UU KUP), a late filing carries a penalty of IDR 1 million and interest on any underpayment.

PPh 21 December reconciliation

In the December payroll cycle, every employer must calculate the total annual PPh 21 liability for each employee under the progressive Article 17 brackets, compare it against cumulative TER-based withholdings from January through November, and collect or refund the difference. Bukti Pemotongan must be issued to each employee for the full year.

Withholding tax reconciliation

All PPh 23, PPh 4(2), and where applicable PPh 26 withholdings made during the year must be reconciled against the monthly returns filed through Coretax. The Directorate General of Taxes (Direktorat Jenderal Pajak or DJP) runs automated cross-checks between the SPT Tahunan Badan figures and the monthly returns. Discrepancies are a primary trigger for SP2DK (Surat Permintaan Penjelasan atas Data dan/atau Keterangan) clarification requests. How SP2DK risk is managed and what the DJP looks for in post-filing reviews is covered in the annual tax reporting compliance guide. 

Final tax scheme assessment for qualifying companies

PT PMDN companies with annual gross turnover below IDR 4.8 billion may apply the final income tax rate of 0.5 percent on gross turnover under PP No. 55 of 2022. Companies using this scheme should confirm annually whether their turnover remains below the threshold and document the basis for the scheme’s application in their SPT Tahunan Badan.

Annual Obligations: Licensing and Administrative Track

WLKP (Wajib Lapor Ketenagakerjaan Perusahaan)

Every employer must submit the annual mandatory Company Labor Report through the SIAPkerja platform. WLKP proof of submission is a prerequisite for various operational licenses and is verified during Dinas Ketenagakerjaan inspections.

Business license and KBLI verification

Under PP No. 28 of 2025, post-licensing supervision includes periodic verification of whether a company’s actual activities match its licensed KBLI classifications. Finance and legal teams should confirm annually that all OSS-issued licenses remain valid and that the KBLI codes registered in the system accurately reflect current business activities. A mismatch identified during a supervision audit escalates to license suspension faster under the 2025 framework than under prior regulations.

The operational consequences of operating under an incorrect KBLI code, including license invalidity, LKPM sanctions, and OSS system flags, are covered in detail in the guide on wrong KBLI code consequences and how to fix them. 

NIB data consistency review

The NIB record in OSS RBA must remain consistent with the company’s notarial deed, tax registration, and SABH data. Any corporate changes processed during the year, including director appointments, address changes, or capital amendments, must be reflected consistently across all three systems. Inconsistencies surface most visibly during bank account renewals, credit facility applications, and partner due diligence.

Compliance Calendar Summary 

How XPND Manages PT PMDN Compliance

For finance and legal teams running compliance across the three tracks above, the coordination burden is not the obligations themselves. It is the interaction between them. A SABH block triggered by a missed governance deadline creates a queue of stalled corporate actions. An LKPM classification error that goes undetected for a year creates a backlog of retroactive corrections at the next reporting cycle. A withholding tax reconciliation gap identified during an SPT Tahunan review arrives at the worst possible moment, typically when the company is also managing year-end close and audit preparation simultaneously.

XPND works with PT PMDN companies as a compliance management partner across all three tracks. The corporate governance calendar is managed as a fixed annual process: RUPS scheduled, notarised, and submitted to SABH within the deadline as a standard deliverable. LKPM reports are prepared with investment realization data validated against actual expenditure records. Tax obligations run on a calendar that is integrated with the payroll and accounting cycle, not managed separately.

For companies that have identified gaps in their current compliance position, whether a missed SABH submission, an unreconciled withholding tax position, or an LKPM classification that no longer reflects the company’s scale, the most effective starting point is a compliance audit before the next filing cycle begins.

Reach out to the XPND team at info@xpnd.co.id to assess your company’s current position against the 2026 compliance framework.