For years, many private limited liability companies (PT PMA and PMDN) in Indonesia treated the Annual General Meeting of Shareholders (GMS) as an internal formality. When there were no changes to the Board of Directors or shareholders, the meeting minutes were often prepared and kept solely as internal corporate records.
That approach is no longer valid. As of late 2025, Indonesia has fundamentally changed how Annual GMS compliance is enforced.
Under Minister of Law and Human Rights Regulation No. 49 of 2025, the government has moved from a largely voluntary reporting model to a mandatory annual filing system, with direct legal and operational consequences for non-compliance.
Companies that fail to align their compliance strategy for the 2026 reporting cycle face automatic AHU system blocking, a sanction that can immediately restrict corporate actions and disrupt ongoing business operations.
This article outlines what has changed under the new regulation, how Annual GMS reporting now works, and what steps companies must complete in 2026 to avoid administrative rejection and operational restrictions.
ILA Global Consulting supports PT PMA and PT PMDN companies with Annual GMS compliance, including coordination with licensed notaries, preparation of supporting documentation, and submission through the AHU Online (SABH) system.
These services form part of ILA’s broader corporate secretarial and legal compliance support for both domestic and foreign businesses operating in Indonesia.
How Has Annual GMS Reporting Changed?
Previously, companies were only required to involve a notary and notify the Ministry of Law (AHU) when amending their Articles of Association or changing management. If no amendments occurred, the Annual GMS did not need to be reported.
Under Regulation No. 49 of 2025, every Annual GMS must now be reported to the AHU Online system, regardless of whether any corporate data has changed.
Failure to comply is no longer treated as an administrative oversight, but as a violation that can directly restrict a company’s legal and operational capacity.
What Are the Three Mandatory Steps for Annual GMS Compliance in 2026?
All Indonesian limited liability companies must now follow a three-step legal process:
- Holding the Annual GMS
The Annual GMS must be held within six months after the end of the financial year, typically no later than 30 June for companies with a 31 December year-end. - Converting the GMS Resolution into a Notarial Deed
The approval of the Annual Report and Financial Statements must be formalized in a Notarial Deed of Shareholders’ Resolution. Internal meeting minutes alone are no longer sufficient for government records. - Reporting the Deed to AHU Online
The notary, or an appointed legal representative such as ILA Global Consulting, must upload the notification to AHU Online (SABH) within 30 calendar days of the deed’s signing date. Missing this deadline exposes the company to administrative rejection and compliance sanctions.
| Term | Definition |
|---|---|
| Annual General Meeting of Shareholders (GMS) | A mandatory yearly meeting of shareholders to approve the company’s annual report and financial statements, which must be held within six months after the financial year ends. |
| Notarial Deed of GMS Resolution | A formal deed prepared by a licensed notary that legally records shareholder resolutions, replacing internal meeting minutes for regulatory purposes. |
| AHU Online Reporting | An electronic notification process through the Ministry of Law’s AHU Online system, which must be completed within 30 calendar days after the notarial deed is signed. |
Why Could Your Company Be Blocked in 2026?
To enforce compliance, the Ministry of Law has introduced system blocking as a direct consequence of non-reporting.
If a company fails to report its Annual GMS, its AHU profile will be blocked. While blocked, the company cannot:
- Appoint or replace Directors or Commissioners
- Increase or decrease paid-up capital
- Amend Articles of Association, business purpose, or address
- Difficult to complete bank KYC updates
- Renew or modify OSS and OJK-related licenses
This effectively freezes the company’s legal and operational flexibility.
| Term | Definition |
|---|---|
| System Blocking | An administrative sanction applied by the AHU system that restricts a company’s ability to update corporate data due to non-compliance with annual GMS reporting obligations. |
| Operational Freezing | A practical consequence of system blocking where companies are unable to amend management, capital structure, or licensing information. |
What Documents Must Be Uploaded to AHU Online?
The following documents are required for AHU Online notification:
| Document | Description |
|---|---|
| Notarial Deed | The finalized deed regarding the “Approval of the Annual Report.” |
| Annual Report File | The actual annual report document (PDF). |
| Beneficial Owner Declaration | A statement identifying the Beneficial Owner (mandatory under the new law). |
| Power of Attorney | Formal authorization from the Board of Directors to the notary to perform the filing. |
| Proof of Payment | Payment of the PNBP (Non-Tax State Revenue) fee for the notification. |
What Documents Are Required by the Notary to Draft the Deed?
To comply with Minister of Law and Human Rights Regulation No. 49 of 2025 (Permenkumham 49/2025), companies must prepare two separate sets of documents. Those required by the notary to draft the deed, and documents required for submission through AHU Online (SABH).
The checklist below focuses on the documents that must be submitted to the notary to meet the 30-day statutory reporting deadline.
Before the notary can issue the Deed of Statement of Shareholders’ Resolution (Akta Pernyataan Keputusan Rapat), the following documents must be provided:
- Internal GMS Minutes (Notulen)
Signed internal minutes of the meeting, explicitly stating the approval of the Annual Report and Financial Year 2025. - Attendance List (Daftar Hadir)
Documentation confirming that the required shareholder quorum was met. - Annual Report
A complete copy of the report was presented to the shareholders. - Financial Statements
Balance sheet and profit and loss statements, audited where mandatory audit requirements apply. - Company Legality Documents, including: Latest Articles of Association (Akta Pendirian and subsequent amendments); Latest AHU approvals or decrees (SK Kemenkumham); NIB (Business Identification Number)
- Identification Documents
Copies of KTP or passports and NPWP of all Directors, Commissioners, and Shareholders.
What Is the Correct Annual GMS Timeline for 2026?
To avoid AHU system blocking, companies should follow this timeline:
- Step 1 (Max 6 Months post-FYE): Hold the GMS (usually by June 30, 2026, for a Dec 31 financial year end).
- Step 2 (Immediate): Take the internal minutes to your notary for conversion into a formal Notarial Deed.
- Step 3 (Max 30 Days post Deed): The notary must upload the notification to AHU.
If the filing is submitted on the 31st day, AHU may reject the notification, forcing the company to repeat the meeting or face administrative penalties.
How Does the New Requirement Compare to the Old Practice?
| Requirement | Old Practice (Common) | New Requirement (Reg. No. 49 of 2025) |
|---|---|---|
| Annual GMS Reporting | Only required if the company data changed | Mandatory every year |
| Form of Document | Internal meeting minutes (Notulen) | Notarial deed required |
| Submission Portal | Not applicable unless amending company data | AHU Online (SABH) |
| Reporting Deadline | No fixed deadline | 30 days after the deed is signed |
Failing to report your Annual GMS in 2026 is no longer a technical oversight. It is a direct trigger for AHU system blocking that can freeze your company’s legal and operational capacity.
ILA Global Consulting handles every step of Annual GMS compliance for PT PMA and PT PMDN companies. Our services cover notarial coordination, AHU Online reporting, and corporate secretarial support.
Contact ILA Global Consulting to make sure your Annual GMS is documented correctly, reported on time, and meets Minister of Law Regulation No. 49 of 2025. Act now to avoid system blocking that could disrupt your business.
