As October begins, there are two obligations that business actors should keep on their radar. First, the submission of the Investment Activity Report (Laporan Kegiatan Penanaman Modal or “LKPM”) for Quarter III 2026 through the Online Single Submission (OSS) system, the period for which ends on 15 October 2026. This obligation is based on Articles 284 through 286 of Regulation of the Minister of Investment and Downstreaming/Head of the Investment Coordinating Board Number 5 of 2025 (“BKPM Regulation 5/2025”), which governs the types of reports, the parties required to report, and the submission deadlines. Second, the Company’s Annual Report, which under Law Number 40 of 2007 on Limited Liability Companies (“Company Law”) must be submitted to the General Meeting of Shareholders (“GMS”) no later than six months after the end of the financial year. Both are often viewed as routine administrative matters, yet each carries legal consequences, both for the company’s business licensing and for the Board of Directors and Board of Commissioners.
Q3 2026 LKPM
The LKPM obligation originates from Article 15 letter c of Law Number 25 of 2007 on Investment (“Investment Law”), which requires every investor to prepare an investment activity report and submit it to the competent authority. The technical rules are now set out in Government Regulation Number 28 of 2025 and BKPM Regulation 5/2025, which took effect on 2 October 2025 and revoked BKPM Regulation Number 5 of 2021. According to the OSS announcement dated 1 October 2026, the third quarter LKPM, covering activities from July to September 2026, must be submitted during the period of 1 to 15 October 2026.
One change worth noting is the deadline. The previous regulation set the 10th of each period as the cut-off, whereas BKPM Regulation 5/2025 extends it to the 15th. The obligations differ according to business scale:
- Micro-scale businesses are not required to submit an LKPM.
- Small-scale businesses submit the LKPM every semester; for Semester II, no later than 15 January 2027.
- Medium and large-scale businesses submit the LKPM every quarter; for Quarter III, no later than 15 October 2026.
Aside from this classification by business scale, LKPM submission is also not required for business activities financed by the State Budget (APBN) or Regional Budget (APBD). The LKPM covers investment realization, employment, production, and the obstacles encountered, and is submitted per business activity and location in accordance with the NIB. Because this data is used for government supervision, it should be kept consistent with the company’s financial statements and licensing documents.
BKPM Regulation 5/2025 also provides for administrative sanctions for non-compliance with the LKPM submission requirement. Non-compliance may be subject to administrative sanctions according to the type of violation, the stage, and the applicable provisions. In general, Article 34 of the Investment Law also provides for administrative sanctions in the form of a written warning, restriction of business activities, suspension of business activities and/or investment facilities, or revocation of business activities and/or investment facilities. This means that continued non-compliance is no longer merely an administrative matter, but may affect the continuity of the Business License.
The Company’s Annual Report
Under Article 66 paragraph (1) of Company Law, the Board of Directors must submit the annual report to the GMS, after review by the Board of Commissioners, no later than six months after the end of the financial year. For a company whose financial year runs from 1 January to 31 December 2025, the deadline fell on 30 June 2026 and has passed. A company that has not yet held its annual GMS should rectify this promptly. A company with a non-calendar financial year calculates the deadline from the end date of its own financial year; for example, a financial year ending on 30 June 2026 means a deadline of 31 December 2026.
This requirement is now reinforced by Minister of Law Regulation No. 49 of 2025 on the Requirements and Procedures for the Establishment, Amendment, and Dissolution of the Legal Entity of Limited Liability Companies (“Ministerial Regulation 49/2025”), which was issued on 11 December 2025, took effect on 17 December 2025, and replaces Minister of Law and Human Rights Regulation No. 21 of 2021. Article 16 paragraph (1) reaffirms the obligation of the Board of Directors of a limited liability company (a capital-based partnership) to submit the annual report, as reviewed by the Board of Commissioners, to the GMS no later than six months after the end of the financial year. A new requirement is set out in Article 16 paragraph (2) to (4): the GMS approval of the annual report must be recorded in a notarial deed and submitted to the Minister by the Board of Directors, through the notary, no later than 30 (thirty) days from the date the notarial deed is signed, electronically via the Legal Entity Administration System (SABH). The annual report is therefore no longer merely an internal company document, but an administrative obligation supervised by the state.
For non-compliance with the obligation to submit the GMS approval of the annual report, Ministerial Regulation 49/2025 provides for administrative sanctions ranging from a written warning to the blocking of the company’s access to SABH, which may impede the company’s administrative services through SABH. Because the Annual GMS for financial year 2025 is held in 2026, that is, after this regulation took effect, companies need to ensure that the notarial deed and the reporting through SABH have been completed.
Actions
- Confirm the business scale and LKPM obligation in OSS, then submit the Q3 LKPM before 15 October 2026 without waiting for the last day.
- Reconcile investment realization, employment, and production data with the financial statements before filling in the report and monitor the LKPM status in OSS until it is approved.
- Check whether the annual GMS for financial year 2025 has been held, whether the financial statements have been audited where required, and whether the approval has been recorded in a notarial deed and reported through SABH.
The LKPM and the Annual Report both lead to orderly corporate governance and legal protection for the company and its management. SW Indonesia is ready to assist with compliance checks, LKPM preparation, and the holding of Annual GMS.
Disclaimer: This article is prepared for general information purposes and does not constitute legal advice. Its application to your company’s specific circumstances should be discussed with our team.
