The Annual General Meeting of Shareholders (AGMS) in Indonesia now has an additional post-meeting compliance requirement. Under Permenkum 49/2025, companies must document approval of the annual report in a notarial deed and submit it electronically through the Legal Entity Administration System (SABH).
The SABH annual-report filing service has been available since June 1, 2026, and AHU has announced that administrative sanctions, including fines or restrictions, for non-compliance will begin in November 2026.
For PT PMA and PT PMDN companies, this means holding the Annual General Meeting of Shareholders alone no longer completes the annual compliance cycle. Companies must also complete the required documentation and post-AGMS filing.
Key Takeaways
- The annual report must generally be submitted to the AGMS within six months after the financial year ends.
- AGMS approval of the annual report must be documented in a notarial deed under Permenkum 49/2025.
- The approval must generally be submitted through SABH within 30 days from the date the notarial deed is signed.
- Meeting the SABH filing deadline helps companies avoid warnings and access issues.
- Companies should treat Annual General Meeting of Shareholders preparation, notarial documentation, and SABH filing as one connected annual compliance cycle.
Annual General Meeting of Shareholders compliance at a glance
| Compliance Area | Key Requirement | What Businesses Should Know |
| Annual Report | Reviewed and submitted to the Annual General Meeting of Shareholders within 6 months after financial year-end | Prepare financial and corporate information early |
| Audit | Required for companies meeting applicable statutory criteria | Confirm audit requirements before finalising the annual report |
| AGMS Approval | Shareholders approve the annual report | Approval must also be documented in a notarial deed |
| SABH Filing | Annual report approval is submitted electronically through SABH | Generally required within 30 days from the notarial deed date |
| Supporting Documents | Notarial deed and approved annual report | Completing the Annual General Meeting of Shareholders alone does not complete the post-AGMS obligation |
| Non-Compliance | Written warning and potential SABH access blocking | SABH access may be blocked if the obligation remains unresolved for 30 days after notification |
Why AGMS compliance matters more in 2026
The key change is what happens after shareholders approve the annual report.
Permenkum 49/2025 requires documenting the approval in a notarial deed and submitting it electronically through SABH. This creates a clearer compliance chain:
Annual report → AGMS approval → notarial deed → SABH filing.
This matters beyond annual reporting. AHU has indicated that it may check annual-report status when companies process certain corporate changes, including changes to directors or commissioners, share transfers, and changes to shareholder names.
An incomplete annual filing can therefore become an issue precisely when the company needs to complete another corporate action.
AGMS approval vs SABH filing: Key differences
AGMS approval and SABH filing are separate steps. The AGMS approves the annual report, while SABH records approval with the Ministry of Law.
| Area | AGMS Approval | SABH Filing |
| Purpose | Shareholders approve the annual report | Records the approved annual report with the Ministry of Law |
| Timing | Generally, within 6 months after the financial year-end | Generally, within 30 days from the notarial deed date |
| Main Parties | Directors, commissioners, and shareholders | Directors and notary |
| Key Document | Annual report and AGMS documentation | Notarial deed and approved annual report |
| Outcome | Formal shareholder approval | Electronic submission through SABH |
| If Incomplete | Annual corporate approval remains outstanding | May lead to a written warning and potential SABH access blocking |
Under Permenkum 49/2025, AGMS approval must also be documented in a notarial deed and filed through SABH.
Where companies commonly face AGMS compliance issues
AGMS compliance problems often stem from coordination, not the meeting itself.
- Annual report delays: Financial or corporate information is not ready for shareholder approval.
- Late audit preparation: An audit is required and identified too close to the AGMS.
- Shareholder coordination: Overseas or multiple shareholders complicate scheduling and approvals.
- Incomplete documentation: The AGMS is completed, but the notarial documentation remains outstanding.
- Missed SABH filing: The company completes the meeting but overlooks the separate post-AGMS submission.
- Corporate data inconsistencies: Outdated company information can complicate subsequent corporate filings.
Identifying these issues before the AGMS helps prevent delays from carrying into the post-meeting filing.
What businesses need to keep AGMS compliance on track
Completing AGMS compliance requires coordination before, during, and after the shareholder meeting.
Annual report and audit readiness
Companies should complete the annual report before shareholders approve it. Companies should also determine early whether they need an external audit.
Under Article 68 of the Company Law, certain companies must undergo an audit, including those with assets and/or annual turnover of at least IDR 50 billion, public companies, companies managing public funds, and other specified categories.
Shareholder and AGMS coordination
Companies must coordinate the meeting, required shareholder approvals, supporting documentation, and any participation by overseas or foreign shareholders to comply with SABH and AGMS regulations.
Preparing these items early reduces the risk of delaying the annual compliance timeline.
Notarial documentation
Once the annual report has been approved, the approval must be documented in the required notarial deed. This step connects the shareholder’s decision with the subsequent SABH filing.
SABH filing
The approved annual report must then be submitted electronically through SABH, together with the required supporting documents. Permenkum 49/2025 generally provides 30 days from signing the notarial deed to make this submission.
Holding the Annual General Meeting of Shareholders without completing this step leaves the post-AGMS obligation outstanding.
What happens when AGMS compliance is incomplete
Incomplete AGMS or SABH compliance can affect more than the annual filing itself.
- Corporate actions can be delayed: Outstanding reporting may affect changes to directors, commissioners, shareholders, or share ownership.
- SABH access can be blocked: An unresolved filing after the warning period can restrict the company’s SABH access.
- Transactions may require remediation first: Historical compliance issues may need to be addressed before other corporate changes can proceed.
- Due diligence can become more complicated: Missing or inconsistent annual corporate records can create additional questions during investment, financing, or M&A reviews.
- Administrative costs can increase: Late compliance may require additional coordination among management, shareholders, notaries, and advisers.
AHU has specifically indicated that annual-report compliance may be checked when certain company-change applications are processed.
What to do if your AGMS or SABH filing is already late
A late Annual General Meeting of Shareholders and SABH filing involve different outstanding obligations and should be addressed separately.
If the AGMS is late
Complete the outstanding annual report, audit where required, shareholder approval, and meeting documentation before proceeding with the post-AGMS requirements.
If the SABH filing is late
If the Annual General Meeting of Shareholders is already complete, confirm the notarial documentation and complete the outstanding SABH submission. Late filing may lead to a written warning, followed by SABH access blocking if the obligation remains unresolved within 30 days after notification.
AHU has announced that administrative sanctions for the new annual-report filing requirement will begin in November 2026.
Companies with outstanding filings should therefore identify what remains incomplete and address it before the issue affects other corporate actions. Talk to our team ->
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InCorp can keep your AGMS and SABH compliance on track
AGMS compliance involves more than arranging the shareholder meeting. Companies must coordinate the annual report, shareholders, required documentation, the notarial process, and SABH submission within the applicable timelines.
InCorp Indonesia (an Ascentium Company) supports PT PMA and PT PMDN companies across the full process, including:
- Annual report and corporate document review
- Annual General Meeting of Shareholders preparation and shareholder coordination
- Audit coordination where required
- Notarial documentation coordination
- SABH annual report filing
- Review and remediation of outstanding filings
If your Annual General Meeting of Shareholders is approaching, already overdue, or completed without the subsequent SABH filing, our team can assess what remains outstanding and help complete the required corporate compliance steps.
Fill out the form below for a free initial consultation.
Frequently Asked Questions
What is an annual general meeting of shareholders in Indonesia?
The Annual General Meeting of Shareholders (AGMS) is the annual meeting where shareholders review and approve the company’s annual report and other matters requiring shareholder approval.
Does a PT PMA need to hold an AGMS?
Yes. PT PMA companies established as standard limited liability companies generally must hold an AGMS under Indonesia’s Company Law.
When must the AGMS be held?
The annual report must generally be submitted to the AGMS within six months after the company’s financial year ends. For companies with a December 31 year-end, this normally means by June 30.
Is completing the AGMS enough?
No. Under Permenkum 49/2025, approval of the annual report must also be documented in a notarial deed and submitted electronically through SABH.
What is the difference between AGMS approval and SABH filing?
The AGMS is the shareholder approval stage, while SABH is the post-AGMS filing stage with the Ministry of Law. Both steps are required to complete the annual reporting process.
How long do companies have to file through SABH?
Companies must generally submit the annual report for approval through SABH within 30 days of the notarial deed date.
Does every company need audited financial statements for the AGMS?
No. Audited financial statements are required only for companies that meet the applicable statutory criteria, such as certain assets or revenue thresholds and regulated business categories.
What happens if the SABH filing is late?
A late SABH filing may result in a written warning. If the outstanding obligation is not resolved within the applicable remediation period, SABH access may be blocked.
What should a company do if its AGMS is already late?
The company should identify which requirements remain incomplete, such as the annual report, audit, shareholder approval, or meeting documentation, and complete them before proceeding with the post-AGMS filing.
Can InCorp Indonesia handle the AGMS and SABH filing process?
Yes. InCorp Indonesia (an Ascentium Company) can support annual report readiness, AGMS preparation, shareholder coordination, notarial documentation, SABH filing, and remediation of outstanding corporate compliance requirements.
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Hotdo Nauli
Senior Legal & Delivery Manager at InCorp Indonesia
Hotdo heads the Legal and Delivery team at InCorp Indonesia, managing Product Registration, Legal Advisory, and Business Licensing. With over 8 years of experience, she focuses on compliance and integrity, ensuring all client operations align with Indonesian laws and regulatory standards, including contract reviews and sector-specific licenses. She is also a licensed advocate and a member of the Indonesian Advocates Association (PERADI).
