INTRODUCTION

The Ministry of Law has introduced a new electronic filing requirement for annual reports of Indonesian limited liability companies (“PT”) through the Legal Entity Administration System (Sistem Administrasi Badan Hukum or "SABH"), effective 1 June 2026.

While the obligation to prepare an annual report is not new, the practical consequence now is far more significant: annual report compliance may directly affect a company’s ability to process certain corporate actions through SABH. For companies planning board changes, shareholder updates, share transfers, or restructuring transactions, this is no longer merely an internal compliance matter — it is a filing readiness issue that can impact deal execution and corporate timelines.