Annual Report Filing: Key Actions Ahead of the 2026 Reporting Deadline

Issue 25, June 2026

The annual reporting season is here. If your company’s financial year ended on 31 December 2025, now is the time to ensure your Annual Report (Laporan Tahunan) and Annual General Meeting of Shareholders (AGMS) process are on track. For further background, please refer to our earlier advisory on this topic.

Key dates to keep in mind

• 30 June 2026 – the Board of Directors (BOD) must submit the Annual Report to the AGMS after it has been reviewed by the Board of Commissioners.
• 31 July 2026 – the approved Annual Report and the notarial deed recording of the AGMS resolutions must be filed through the AHU system of the Ministry of Law (MOL).

There have been informal discussions about a possible grace period due to AHU system readiness. However, no formal extension has been issued. Companies should therefore continue to work toward the statutory deadlines.

What should be prepared now?

To stay ahead of the process, companies should review the following:

1. Annual Report content – confirm that the Annual Report includes all required information, including: financial statements, the company activity report, Board of Commissioners (BOC) supervisory report, material events, details of the members of the BOD and BOC, and remuneration disclosure.
2. Signatures – the Annual Report must be signed by all serving members of the BOD and BOC for the relevant financial year. If a signature cannot be obtained, the Annual Report should include a written explanation.
3. AGMS documentation – approval of the Annual Report must be recorded in a notarial deed. If approval is obtained by circular resolution, the resolution must still be restated before an Indonesian notary.
4. Audit requirement – confirm whether your company is required to prepare audited financial statements under Article 68 of the Company Law.
5. Financial year alignment – AHU system currently does not distinguish between companies that use a calendar financial year (1 January to 31 December) and those that use a non-calendar financial year.

If your company follows a financial year that does not coincide with the calendar year, we understand that you may avoid a non-compliant status by submitting a formal letter to the MOL explaining the company's financial year and the basis for the filing approach adopted.  

Late or incomplete filing may result in administrative sanctions, including written warnings and possible suspension of access to the corporate administration system, which may affect future corporate actions.

Please feel free to contact us if you would like to discuss the next steps for your company. 

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Click the "download file" button to read the PDF version.

If you have any questions, please contact

1. Maria Sagrado, Partner - maria.sagrado@makarim.com
2. Namira Assagaf, Associate - namira.assagaf@makarim.com

_{M&T Advisory is a digital publication prepared by the Indonesian law firm, Makarim & Taira S. It informs generally on the topics covered and should not be treated as legal advice or relied upon when making investment or business decisions. Should you have any questions on any matter contained in M&T Advisory, or other comments in general, please contact us at the emails provided at the end of this article.}