Accounting and reporting duties of a PT PMA

This page is for a foreigner who owns or runs a PT PMA, a foreign-owned limited liability company, and wants to know what the company must keep, file and report after it is licensed. It is general information, not legal advice. It states what the written law says, with the article, and says where two texts do not fit together. What accountants and offices say is usual is mostly left out.

We used the texts in force on 6 October 2026: UU 40/2007 on limited liability companies (Pasal 66 to 71, 77, 78, 82, 91 and 100); UU 6/1983 on general tax provisions (the KUP law), Pasal 3, 7, 28 and 32, as UU 28/2007 and UU 7/2021 left them; PMK 81/2024 on the core tax administration system, as amended; UU 8/1997 on company documents; PP 24/1998 on the annual financial statements of companies, as amended by PP 64/1999, with the trade ministry's regulation under it; PP 28/2025 and Permeninves/BKPM 5/2025 for investment reports; Permenkum 49/2025, Perpres 13/2018 and Permenkum 2/2025 for the annual filing and the beneficial owner. The status pages of peraturan.bpk.go.id show UU 40/2007 amended by UU 11/2020 and UU 6/2023, and UU 6/1983 amended up to UU 6/2023; those amendments change other articles than the ones used here (UU 6/2023 Pasal 109 changed only Pasal 1, 7, 32 and 153 of UU 40/2007). The four amendments of PMK 81/2024 (PMK 11/2025, 53/2025, 54/2025 and 1/2026) leave the articles used here alone.

Duties that other pages already hold are named in one line and linked, not repeated: the investment report with its dates and warnings, the approval of the annual report and its filing at the Ministry of Law (the page on setting up a PT PMA, section on reports), the tax dates (the page on tax deadlines), the labour report and social security (the page on employing staff in Bali), and the yearly report on foreign workers (the page on working legally in Indonesia). What becomes of these duties when a company is wound up is on the page on closing a company. Criminal penalties are not stated here: UU 1/2026 adjusted the criminal fines of older laws, and the only sanctions given are the administrative ones that the texts name.

Who keeps books. A company taxpayer in Indonesia must keep books (pembukuan), and a PT PMA is one (UU 6/1983 Pasal 28(1); PMK 81/2024 Pasal 448(1)). Books must be kept in good faith and show the real state of the business (Pasal 28(3); PMK Pasal 455(2)(a)). At the least they record assets, liabilities, capital, income and costs, and purchases and sales, so that the tax owed can be worked out (Pasal 28(7); PMK Pasal 455(7)).

Standards and method. Books follow the financial accounting standards that apply in Indonesia, unless a tax law says otherwise (PMK 81/2024 Pasal 455(1)). They use the accrual or the cash method, applied consistently (Pasal 28(5); PMK Pasal 455(2)(c)). A change of method, of the book year, of the way stock is valued or of the depreciation method needs the approval of the Director General of Taxes (Pasal 28(6); PMK Pasal 455(5) and (6)). The cash method is open only to a company that may keep books under the standards for micro and small businesses and whose gross turnover in the year before was no more than Rp4,800,000,000, and the company must notify DJP of it for each tax year (PMK Pasal 456(2) and (3), 458(1)).

Language and currency. Books are kept in Indonesia, in Latin letters, Arabic numerals and rupiah, and are written in Indonesian, or in a foreign language that the Minister of Finance allows (Pasal 28(4); PMK Pasal 455(2)(b); UU 8/1997 Pasal 8(2) and (3)). Books in a foreign language and a currency other than rupiah need the Minister's permission (Pasal 28(8); PMK Pasal 455(3)).

English and US dollars. The tax office's own service page says that certain company taxpayers may apply for permission to keep books in English and US dollars, and the first it lists is a taxpayer in the framework of foreign investment that operates under the foreign investment rules. The application is made no later than 3 months after the company was founded, or before the start of the book year in which the new books begin, and the company must meet the conditions for a fiscal certificate (Surat Keterangan Fiskal). The same category stood in PMK 196/PMK.03/2007 as amended by PMK 123/2019 (Pasal 3(1)(a)), and PMK 81/2024 repeals only Pasal 7(2) and (3) of that regulation (Pasal 483 angka 4). If permission is given, the company files its annual income tax return with its attachments in Indonesian, except the financial statements, and in US dollars (PMK 81/2024 Pasal 161(2)), and pays in dollars its income tax instalments (PPh Pasal 25), the income tax still due at the end of the year (PPh Pasal 29) and tax bills and decisions issued in dollars that raise the tax due (PMK Pasal 106(2)(a)).

Keeping the papers. Books, records and the documents they rest on, and data processed electronically or by an online application, must be kept for 10 years in Indonesia, for a company at its seat (UU 6/1983 Pasal 28(11)); PMK 81/2024 Pasal 460(2)(b) says at its seat and/or its place of business. UU 8/1997 Pasal 11(1) also sets 10 years for records, proofs of bookkeeping and supporting financial data, counted from the end of the company's book year. The directors must keep the annual report, the financial documents, the register of shareholders and the minutes at the company's seat (UU 40/2007 Pasal 100(1) and (2)).

Form of the records. UU 8/1997 says the annual balance sheet and profit and loss account are signed by the head of the company or an officer it appoints (Pasal 9(1)) and are made on paper (Pasal 10(1)); other records may be on paper or by other means (Pasal 10(2)). Company documents may be transferred to microfilm or other media, and every transfer is legalised (Pasal 12(1) and 13).

The directors give the annual report to the general meeting of shareholders (GMS, RUPS), after the commissioners have reviewed it, no later than six months after the end of the financial year, and the annual GMS must itself be held within the same six months (UU 40/2007 Pasal 66(1) and 78(2)). The filing of the meeting's approval at the Ministry of Law is on the page on setting up a PT PMA.

What the financial statements hold. At least the balance sheet at the end of the year compared with the year before, the profit and loss account of the year, the cash flow statement, the statement of changes in equity and the notes (Pasal 66(2)(a)); they follow the financial accounting standards (Pasal 66(3)). The other parts of the annual report are in Pasal 66(2)(b) to (g) and on the page on setting up a PT PMA.

Signing. All directors and all commissioners who served in the year sign the annual report, and it lies at the company's office for the shareholders to inspect from the day the meeting is summoned (Pasal 67(1)). A director or commissioner who does not sign must give written reasons, or the directors state them in a separate letter attached to the report; one who neither signs nor gives reasons is taken to approve its content (Pasal 67(2) and (3)).

The meeting. The summons goes out at least 14 days before the meeting, not counting the day of the summons or the day of the meeting, by registered letter and/or an advertisement in a newspaper, and states the date, time, place and agenda and that the papers are at the office from the day of the summons (Pasal 82(1) to (3)). The annual meeting must be given all the documents of the annual report (Pasal 78(3)). A meeting may be held by video or other electronic means if all participants can see and hear one another, and its minutes are approved and signed by all participants (Pasal 77(1) and (4)). Shareholders may also take a binding decision outside a meeting if all shareholders with voting rights approve in writing by signing the proposal (Pasal 91).

What the meeting decides. The meeting approves the annual report, which includes adopting the financial statements and the commissioners' supervision report (Pasal 69(1)). If the financial statements turn out to be untrue or misleading, the directors and commissioners are jointly liable to those who suffer loss, unless they prove it was not their fault (Pasal 69(3) and (4)). The meeting also decides how the net profit is used, including how much goes to the reserve (Pasal 71(1)). While retained earnings are positive, the company must set aside part of the net profit each year for a reserve, until the reserve reaches at least 20 percent of issued and paid-up capital (Pasal 70(1) to (3)).

Audit by a public accountant. The directors must hand the company's financial statements to a public accountant (akuntan publik) for audit if the company's business is raising or managing public funds; if it issues debt notes to the public; if it is a public company; if it is a persero (a state company); if it has assets and/or turnover of at least Rp50,000,000,000; or if a law requires it (UU 40/2007 Pasal 68(1)). If a required audit is not done, the meeting does not adopt the financial statements (Pasal 68(2)). The audit report goes in writing to the meeting through the directors (Pasal 68(3)). For a company in the first three cases, the balance sheet and profit and loss account are announced in one newspaper within 7 days after the meeting's approval (Pasal 68(4) and (5)). The law lets a government regulation lower the Rp50 billion figure (Pasal 68(6)); we found none. How to check that an accountant is licensed is on the page on how to check a professional.

Audited statements and tax. The annual income tax return of a company that keeps books carries its balance sheet and profit and loss account, and if the statements were audited, the audited statements (PMK 81/2024 Pasal 165(3) and (4)). A request to extend the time for the annual return must then carry a statement of the public accountant that the audit is not finished (Pasal 175(1)(e)).

Audited statements to the Minister. For a company that must be audited, the balance sheet and profit and loss account must be submitted to the Minister, that is the Minister of Law, as the laws provide (UU 40/2007 Pasal 66(4) and Pasal 1 angka 16). The only procedure we found is the annual filing in SABH described on the page on setting up a PT PMA, which takes the annual report of a company with two or more shareholders, audited or not (Permenkum 49/2025 Pasal 16).

The trade ministry's filing. PP 24/1998, as amended by PP 64/1999, says that every company must submit its annual financial statements to the minister responsible for trade, and that they are public information (Pasal 1 angka 2 and 2(1) and (2)). The duty applies to a limited liability company that is a public company, deals in public funds, issues debt notes, has assets of at least Rp25,000,000,000 from the book year 2000, or is a debtor whose bank requires an audit; to foreign companies established in Indonesia, with their branches, subsidiaries, agents and representatives; and to state and regional companies. The statements must be audited by a public accountant (Pasal 4(1) and (2) and 4A, as changed by PP 64/1999). The trade ministry's regulation that set the deadline of six months after the book year, and the filing through its online system with an NIB, Permendag 25/2020 (Pasal 6 and 7), was revoked by Permendag 26/2025, in force from 30 June 2025. peraturan.bpk.go.id still shows PP 24/1998 as in force. We found no text that replaces the revoked regulation or says where such statements are now filed.

Two figures. UU 40/2007 sets Rp50 billion for the audit, in assets and/or turnover; PP 24/1998 as amended sets Rp25 billion, in assets, for the filing of audited statements. We do not know which figure a notary or an auditor would apply to a company that lies between them; the questions at the end ask.

Every taxpayer must fill in each tax return correctly, completely and clearly, in Indonesian, in Latin letters, Arabic numerals and rupiah, sign it and file it with the tax office where it is registered, or another place that the Director General sets (UU 6/1983 Pasal 3(1)). The returns a company may have are the monthly return for income tax under Pasal 21 and/or 26, the unified monthly return for other income tax that the taxpayer withholds, collects or pays itself, the monthly VAT return of a business registered as a VAT-taxable entrepreneur (PKP), and the annual income tax return (PMK 81/2024 Pasal 162(1)). The payer that withholds files the Pasal 21 and 26 return, the taxpayer that withholds, collects or pays itself files the unified return, and every PKP files the VAT return, all in electronic form (Pasal 163(1), (2) and (6)). The dates, the extension of the annual return and where to file are on the page on tax deadlines.

Attachments. The annual return of a company that keeps books carries the balance sheet and the profit and loss account, each company's own (PMK 81/2024 Pasal 165(3) and (6)). A return that is not fully accompanied by the statements and documents the rules require is treated as not filed (UU 6/1983 Pasal 3(7)(b)).

Who signs and who answers. A company acts in its tax affairs through its management (pengurus), which includes a person who really has authority to take part in setting policy or taking decisions in running the company (UU 6/1983 Pasal 32(1)(a) and (4)). The management is personally and/or jointly liable for the tax the company owes, unless it can prove to the Director General of Taxes that it truly could not be made responsible (Pasal 32(2)). A company may appoint an attorney under a special power of attorney (Pasal 32(3)), who must have certain tax competence (Pasal 32(3a)); a return signed by an attorney carries that power of attorney (PMK 81/2024 Pasal 167(1) and (2)).

Late or missing returns. If a return is not filed by the deadline, or by the extended deadline, the fine is Rp500,000 for a monthly VAT return, Rp100,000 for any other monthly return and Rp1,000,000 for the annual income tax return of a company (Pasal 7(1)). The fine is not imposed on a company that no longer does business but has not yet been dissolved under the rules (Pasal 7(2)(e)). The penalties for paying late are not given here.

The investment activity report (LKPM), its dates, the checks and the warnings that follow a failure to file are on the page on setting up a PT PMA, section on reports. Five points are not there. First, the duty has a second part: a business actor also reports on its compliance with the basic requirements and licences of its activity, under the standards that the ministry or agency of its sector sets (PP 28/2025 Pasal 240(1), (2) and (4); Permeninves/BKPM 5/2025 Pasal 284(1) and (3)), while the LKPM carries the progress of the investment and of the investor's duties through OSS (PP 28/2025 Pasal 240(5); Permeninves/BKPM Pasal 284(4)). Second, the LKPM is filed for each business activity and location after the NIB is obtained, and the activities include the main and the supporting ones (Pasal 285(1) and (2)). Third, activities financed from the state budget or a regional budget do not have to file (Pasal 286(2)(b)). Fourth, after a request for correction (Pasal 287(5)), we read the text to let the company correct its report until the end of the reporting period (Pasal 287(6)); this is our reading, because on its face ayat (6) refers back to ayat (4), the receipt of approval, and not to ayat (5).

Fifth, the period is announced each time. For the first quarter of 2026 the ministry's notice gave 1 to 15 April 2026. When a date falls on a national holiday, the period is adjusted by an official notice to business actors (Pasal 286(7)), so read the notice of each quarter.

The duty to name the beneficial owner, the criteria for a PT, the yearly update, the five years for keeping the documents, the sanctions and the report of a change are on the page on setting up a PT PMA and on the page on selling and leaving (section on a PT PMA). This section adds who may report, how the report is checked and how the sanctions work.

Who reports. The company must give the authority true information on its beneficial owner, with the company's own statement that it is true (Perpres 13/2018 Pasal 18(1) and (2)). The report may be made by a founder or a member of the management, by a notary, or by someone they authorise (Pasal 18(3)). A company that gave only a statement of willingness when it was set up must name and report its beneficial owner within 7 working days after it receives its licence or registration (Pasal 19(1)(b) and (2)).

Checks. The company checks the information against its supporting documents when it reports the founding, a change or an update (Permenkum 2/2025 Pasal 6(1) and (3)). The notary checks when the company uses the notary's services (Pasal 7). The Ministry of Law checks the information and the questionnaire that the company fills in (Pasal 8), matching them at least against the identity number, the tax number and/or other documents that show identity (Pasal 12(2)). It may check data, first for companies it rates as high risk, and may ask the company to clarify differences (Pasal 14(1) to (3)). Besides the owner the company named, the Minister may name another beneficial owner on the result of the checks and the data analysis (Pasal 17).

Steps. The sanctions named on the page on setting up a PT PMA are imposed step by step, although in certain cases the Minister may impose one without the earlier steps (Permenkum 2/2025 Pasal 24). The reprimand is a notice on AHU Online or an e-mail, the blacklist is an electronic announcement on the website of the Directorate General of General Legal Administration, and the blocking closes the company's access to AHU Online (Pasal 23). The blacklist and the blocking can be lifted when the company has reported correctly, and the company may ask for that (Pasal 25(1) to (4)).

These duties have their own pages and are not repeated here: the labour report to the manpower ministry, social security through BPJS Ketenagakerjaan, the monthly payments and the records an employer keeps (the page on employing staff in Bali), and the yearly report on each foreign worker, the report when a contract ends and what follows if they are not filed (the page on working legally in Indonesia). The income tax that an employer withholds is reported in the monthly returns described in the section on tax returns.

Rates and the working out of income tax, VAT, withholding and stamp duty; registering a company as a VAT-taxable entrepreneur; tax incentives; import duties; the regional taxes on a villa let to guests (the page on renting a villa to guests and the page on tax deadlines); branches and representative offices; listed companies; one-person companies; the sector reports of a particular activity; payroll; the winding up of a company (the page on closing a company); and criminal penalties (UU 1/2026).

Does the company meet a trigger for a public audit now (Pasal 68(1)), or will it in the next year, and which figure, Rp50 billion or Rp25 billion, would you apply to us? Will a lender, the notary or a buyer ask for an audit even if the law does not?

Which accounting standard and which method will the books follow, who keeps them, and where in Indonesia are the books and documents kept for 10 years?

Should the company apply for permission to keep books in English and US dollars, and by which date, counted from the founding or from the start of the book year?

When is the annual general meeting, who signs the annual report, who keeps the minutes, and is a decision outside a meeting accepted for the annual report?

Does the notary file the approval of the annual report in SABH, and by which date after the notarial deed?

Is the company still asked to file annual financial statements with the trade ministry, and if so where and in what form?

Which monthly returns does the company file (withholding, payments to suppliers, VAT), who prepares each, who signs, and who answers for the tax owed?

Who files the LKPM each quarter, and which reports does our activity owe to its sector ministry besides?

Who updates the beneficial owner each year, how soon after a change is it reported, and who holds the supporting documents?

Where is the calendar of all these duties kept, who is responsible for each, and will you confirm the answers in writing?

Whether the filing of annual financial statements with the trade ministry still applies. PP 24/1998, as amended, is shown as in force and still says all companies must file; its implementing regulation, Permendag 25/2020, was revoked on 30 June 2025, and we found no replacement and no notice that the filing was dropped. PP 24/1998 Pasal 7 leaves the further rules to the minister.

Whether a PT PMA with a foreign parent counts as a foreign company under PP 24/1998 Pasal 4(1)(b) as amended, which names foreign companies established in Indonesia and lists their subsidiaries. The text does not say whether a company set up under Indonesian law is meant.

Which figure governs a company with assets between Rp25 billion and Rp50 billion (see the section on audit). UU 40/2007 Pasal 68(1)(f) lets another law require an audit, and PP 24/1998 Pasal 4(2) requires audited statements for the filing, but we found no text that links the two.

Whether a government regulation lowers the Rp50 billion figure of UU 40/2007 Pasal 68(1)(e) as Pasal 68(6) allows. We found none on peraturan.bpk.go.id.

How the rule of UU 8/1997 Pasal 10(1), that the annual balance sheet and profit and loss account are made on paper, fits with books kept in electronic form. We did not find a later text on it.

The place and the start of the 10 years of keeping. UU 6/1983 Pasal 28(11) says at the seat of a company; PMK 81/2024 Pasal 460(2)(b) says at the seat and/or the place of business; only UU 8/1997 Pasal 11(1) says the years run from the end of the book year.

The rule behind the English and US dollar books. The tax office's service pages of 2025 list who may apply and the steps in Coretax, but do not name the regulation they rest on, and we read none. PMK 196/PMK.03/2007 as amended by PMK 123/2019 lists the same category of foreign investment, and PMK 81/2024 repeals only part of it.

Whether UU 40/2007 Pasal 91 (a binding decision outside a meeting when all voting shareholders sign) can replace the meeting's approval of the annual report that Pasal 69(1) requires. We found no text that says so in terms.

The date from which the year of the beneficial owner's update runs. Perpres 13/2018 Pasal 21 and Permenkum 2/2025 Pasal 3(1) say every year, and we found no text that sets a date.

Whether UU 6/1983 has been amended after UU 6/2023. The status page of peraturan.bpk.go.id lists none on 6 October 2026; we did not check bills before the House.