PT Annual Reports Exempt from Non-Tax State Revenue (PNBP) Fees Requirements and Submission Process

Good news for business owners in Indonesia. Minister of Law Regulation No. 13 of 2026 (Permenkum 13/2026) has set a zero-rupiah (Rp0) Non-Tax State Revenue (PNBP) fee rate for submitting the Annual Reports of joint-stock companies (PT persekutuan modal). This policy is available to companies that meet specific criteria.

Article 1 of Permenkum 13/2026 emphasizes that this regulation was established to improve compliance with legal administration services while providing legal certainty through fee waivers (up to Rp0 or 0%).

Definition of a Joint-Stock Company (PT Persekutuan Modal)

Permenkum 49/2025 distinguishes between two types of limited liability companies (Perseroan Terbatas or PT): joint-stock companies (PT persekutuan modal) and single-member companies (PT perorangan).

In this context, a joint-stock company is defined as a corporate legal entity established based on an agreement that conducts business operations with authorized capital entirely divided into shares.

Requirements for the PNBP Fee Exemption

Article 3 of Permenkum 13/2026 establishes a Rp0 PNBP rate for joint-stock companies submitting notification of Annual Report approval between August 1 and December 31, 2026.

This fee waiver applies to notifications for both audit-mandatory and non-audit-mandatory Annual Reports.

Therefore, the primary eligibility requirement is that the company submits its notification of Annual Report approval within the designated period from August 1 to December 31, 2026.

Prior to Permenkum 13/2026 taking effect:

  • Submitting notification of Annual Report approval for audit-mandatory companies incurred a PNBP fee of IDR 500,000 per filing.
  • Submitting notification for non-audit-mandatory companies incurred a fee of IDR 250,000 per filing.

Required Contents of the Annual Report

According to Article 16, Paragraph (6) of Permenkum 49/2025, a joint-stock company’s Annual Report must contain, at a minimum:

  1. Financial statements, comprising at least the balance sheet for the most recent fiscal year compared with the previous fiscal year, the profit and loss statement for the relevant fiscal year, the cash flow statement, the statement of changes in equity, and notes to the financial statements;
  2. A report on corporate activities;
  3. A report on the implementation of Corporate Social and Environmental Responsibility (CSER/TJSL);
  4. A detail of issues arising during the fiscal year that affected business operations;
  5. A report on supervisory duties executed by the Board of Commissioners during the preceding fiscal year;
  6. The names of members of the Board of Directors and Board of Commissioners; and
  7. Salaries and allowances for Directors, as well as salaries/honoraria and allowances for Commissioners, for the preceding fiscal year.

Submission Procedure

Permenkum 13/2026 stipulates that notifications of Annual Report approval must be submitted electronically via the official system provided by the Ministry of Law.

Pursuant to Permenkum 49/2025, companies are required to submit these filings through the Legal Entity Administration System (SABH).

Joint-stock companies have until December 31, 2026, to take advantage of this fee exemption.

Companies are strongly advised not to delay submission until the deadline. Early filing helps prevent system congestion and ensures companies do not miss the opportunity to benefit from the zero-fee rate.

Penalties for Non-Compliance

In addition to the fee structure, companies should pay close attention to the penalties for failing to submit their Annual Reports. Under Article 17 of Permenkum 49/2025, sanctions include:

  • Written warnings
  • System access blockages

If a company fails to fulfill its reporting obligation within 30 days of receiving a written warning notification via the SABH system, administrative sanctions will be imposed in the form of system access blockages.

This access restriction completely disables the company’s access to the SABH platform.

Conclusion

This temporary fee waiver under Permenkum 13/2026 provides a strategic window for businesses to satisfy statutory compliance requirements while cutting administrative costs. Beyond the cost savings, timely filing ensures uninterrupted administrative operations and safeguards company standing.

 

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