Indonesia’s compliance ecosystem for Domestic Investment Companies enters a critical phase in 2026 with the full implementation of Government Regulation No. 28 of 2025 (PP 28/2025), which replaces PP No. 5 of 2021.
For PT PMDN, compliance is no longer viewed as routine administration.
It now functions as a strategic lever to maintain the company’s compliance standing inside the Online Single Submission (OSS) system.
This shift is strengthened by the harmonization of norms under the Minister of Investment and Downstreaming/Head of BKPM Regulation No. 5 of 2025.
The practical implication is clear. Investment realization reporting (LKPM), corporate tax obligations under the Coretax ecosystem, and licensing governance through NIB and KBLI updates are increasingly interconnected.
In this environment, the PT PMDN Compliance Calendar 2026 becomes a central reference for managing regulatory obligations in a structured way.
A well-managed calendar supports licensing continuity, reduces exposure to system-triggered supervision, and protects regulatory credibility.
The New Integrated Compliance Architecture in 2026
OSS Risk-Based Approach (OSS RBA) continues to evolve from a licensing issuance platform into a continuous monitoring framework.
LKPM now serves as a primary dataset used by the government to evaluate risk and determine a company’s compliance profile.
BKPM 5/2025 reinforces this structure by aligning reporting standards and strengthening LKPM’s role in investment supervision.
As a result, inconsistencies between LKPM investment realization and Coretax-related tax reporting are more likely to surface as system-detected compliance signals rather than isolated administrative errors.
This is why 2026 requires a more deliberate approach.
Alignment across reporting systems matters as much as submission itself.
Determining LKPM Obligations Based on Paid-Up Capital in the NIB
LKPM obligations for PT PMDN are determined by business scale.
The scale is assessed using paid-up capital recorded in the NIB, not operational revenue or annual turnover.
Companies must actively monitor whether capital increases change their reporting frequency.
LKPM Reporting Obligations by Business Scale:
| Business Scale | Paid-Up Capital | Reporting Frequency |
| Micro | Up to IDR 1 billion | Not required |
| Small | Above IDR 1 billion – IDR 5 billion | Semi-annual |
| Medium | Above IDR 5 billion – IDR 10 billion | Quarterly |
| Large | Above IDR 10 billion | Quarterly |
Because frequency is tied to the NIB-based capital classification, a capital injection can shift a company from semi-annual to quarterly reporting.
If the company continues using the old frequency after a scale change, the OSS system may treat it as non-compliance even when submissions are timely.
Practical LKPM Reporting Timeline for 2026
BKPM 5/2025 effectively extends the LKPM submission window to the 15th of the following month.
Earlier regimes commonly used the 10th.
However, early 2026 includes transitional deadlines that still follow the older cut-off.
Key LKPM Reporting Deadlines 2026
| Reporting | Coverage | Deadline |
| Q4 2025 | Oct-Dec 2025 | 10 January 2026 (transition) |
| Semester II 2025 | Jul-Dec 2025 | 10 January 2026 (transition) |
| Q1 2026 | Jan-Mar 2026 | 15 April 2026 |
| Q2 2026 | Apr-Jun 2026 | 15 July 2026 |
| Semester 1 2026 | Jan-Jun 2026 | 15 July 2026 |
| Q3 2026 | Jul-Sep 2026 | 15 October 2026 |
| Q4 2026 | Oct-Dec 2026 | 15 January 2027 |
Even though the deadline is the 15th, OSS access typically spikes in the final days.
Submitting in the first week reduces the risk of system overload that may result in an “unreported” status.
Repeated failures can trigger automated warnings and lower the company’s OSS compliance score.
Corporate Tax Compliance as a Core Part of the 2026 Calendar
Corporate tax compliance in 2026 relies heavily on Coretax integration.
The government has directed corporate taxpayers to activate and update their profiles for smoother data synchronization.
Monthly tax obligations remain highly time-sensitive because penalties accumulate when deadlines are missed.
Typical monthly obligations include:
- PPh Article 21 (employee payroll tax): Payment by the 15th of the following month, reporting by the 20th.
- Unified withholding taxes (including Articles 22, 23, 26, and Article 4(2)): Payment by the 15th, reporting by the 20th.
- PPh Article 25 (corporate income tax installments): Payment by the 15th, reporting by the 20th.
- VAT and Luxury Goods VAT: Payment and reporting by the end of the following month.
- Stamp duty (for collectors): Payment by the 15th of the following month, reporting by the 15th.
Late uploading of output tax invoices can create downstream issues for counterparties and trigger administrative consequences.
Annual tax deadlines in 2026 also require structured planning, including:
- 31 March 2026: Deadline for Individual Income Tax Annual Return (and NPPN notice where applicable).
- 30 April 2026: Deadline for Corporate Income Tax Annual Return for Fiscal Year 2025, including settlement of any underpayment before filing.
- 31 December 2026: Deadline for Country-by-Country Report (CbCR) notification/reporting for eligible corporate groups for Fiscal Year 2025.
Public holidays should always be factored into planning, as deadlines usually shift to the next working day.
Structuring LKPM Reports to Minimize Revisions
LKPM revisions commonly stem from inconsistent reporting logic rather than missing data.
Verifiers examine how numbers connect across report components.
Several checks help reduce revision risk:
- Workforce and working capital alignment: additional headcount should logically correlate with higher working capital realization (wages, benefits, routine operational costs).
- Fixed capital versus working capital classification: fixed capital covers long-term assets such as land, buildings, and machinery, while working capital reflects operational expenses for the cycle (commonly three months for quarterly reporting).
- Construction versus production stage consistency: construction-stage entities should not report production realization; operational entities should update status accordingly in OSS so their reporting is accepted.
From a technical standpoint, preparation in OSS RBA typically follows a sequence:
- Verify business profile data, project location details, and KBLI accuracy
- Input fixed capital realization limited to asset acquisition during the reporting period
- Input working capital supported by internal accounting records (materials, energy, payroll, administration)
- Report workforce data accurately, distinguishing domestic workers and foreign workers, and ensure foreign workforce is supported by valid work authorization
- Complete CSR/TJSL disclosure for eligible businesses with program details, budget allocation, and output
- Explain constraints transparently, especially when investment realization stagnates across multiple periods
Numeric units are a common rejection trigger. Currency denomination mistakes and extra zeros can make investment values appear unreasonable and lead to system rejection or revision.
NIB Updates and the Mandatory Transition to KBLI 2025
2026 is a pivotal year as KBLI 2025 replaces KBLI 2020.
KBLI determines business risk level and licensing requirements inside OSS RBA.
Key KBLI 2025 timeline points include:
- KBLI 2025 applies fully from 18 December 2025
- All businesses must complete adjustment by 18 June 2026
Failure to update KBLI may restrict OSS access and disrupt LKPM reporting.
The update process usually requires:
- Internal audit of current business activities against the KBLI 2025 structure
- Corporate governance steps when business descriptions in Articles of Association need substantive adjustment (including shareholder approval and notarial update, where required)
- Synchronization between AHU data and OSS data, followed by OSS “Perubahan Data Usaha” validation
- Correct mapping of primary and supporting KBLI, since OSS may block supporting KBLI additions when the primary KBLI is not properly registered
Sanctions Framework Under PP 28/2025
PP 28/2025 introduces stronger post-licensing enforcement.
Compliance is assessed based on accuracy, consistency, and substance.
Sanctions can include:
- Written warnings issued in stages (Warning 1 to 3), with escalation when the business fails to respond within specified periods
- Temporary suspension of business activity, including partial or full suspension in relevant circumstances
- Administrative fines as a significant instrument introduced in the 2026 enforcement posture, with amounts governed by sectoral rules
- Police-enforced corrective measures that enable forced closures or activity stops when companies ignore suspension orders or create public risk
- Revocation of business licenses as the most severe outcome, rendering NIB and related technical licenses ineffective
This framework makes repeated non-compliance costlier and faster to escalate.
Understanding the OSS Compliance Scoring System
OSS assigns dynamic compliance scores that influence supervision and licensing ease.
The scoring bands include:
| Skor Range | Rating | Operational Impact |
| 81-100 | Very Good | Easier licensing & incentives |
| 60-80 | Good | Routine supervision |
| 40-59 | Less Good | Coaching & increased oversight |
| 0-39 | Poor | High risk of heavy sanctions |
Lower scores increase regulatory friction and inspection risk.
Strategic Compliance Risk Mitigation for PT PMDN
Compliance management in 2026 requires structured coordination across Finance, HR, and Legal. Data misalignment between payroll records and LKPM workforce reporting remains a frequent trigger for revision and inconsistency flags.
Practical mitigation measures include:
- Establishing an internal compliance task force that integrates Finance, HR, and Legal workflows.
- Periodic audits of NIB and licensing data, especially after expansion or location changes, since operating in unregistered locations can be treated as a serious administrative violation.
- Maintaining supporting documentation for investment realization, such as invoices, vendor contracts, and physical progress evidence.
- Using LKPM consultation services (Klinik LKPM) offered by local DPMPTSP or BKPM before deadlines to clarify interpretation and reduce last-minute risk
Integration between investment data and tax data also becomes more sensitive.
LKPM investment realization can function as a reasonableness parameter in tax scrutiny, so consistency between the Corporate Annual Return and the aggregated LKPM record across the year supports a healthier risk profile.
Navigating the PT PMDN Compliance Calendar 2026 with XPND as Your Strategic Partner
The 2026 regime reflects higher transparency, automation, and regulatory expectations.
PT PMDN entities must align LKPM reporting, tax compliance, and NIB governance under KBLI 2025.
A disciplined compliance calendar ensures continuity, protects OSS scores, and minimizes disruptions.
XPND supports businesses through regulatory advisory, compliance structuring, and ongoing reporting assistance.
With deep expertise in OSS RBA, LKPM strategy, and integrated compliance governance, XPND helps PT PMDN maintain full compliance and long-term resilience.
