The Ministry of Law of the Republic of Indonesia has issued a policy that benefits businesses organized as limited liability companies (PT), namely an exemption from Non-Tax State Revenue (PNBP) fees for the filing of Annual Reports.
A PNBP fee of Rp0 is granted to every limited liability company that submits a notification of approval for its Annual Report between August 1 and December 31, 2026. This policy applies to both PTs that are subject to mandatory audits and those that are not.
Legal Basis and Provisions
This policy is set forth in Minister of Law Regulation (Permenkum) No. 13 of 2026 concerning the Amount, Requirements, and Procedures for Imposing Rates of up to Rp0.00 or 0% on Types of State Non-Tax Revenues Applicable to the Ministry of Law, which was drafted to implement Article 6, paragraph (3) of Government Regulation No. 30 of 2026.
Under these regulations, a PNBP rate of Rp0 is granted to every joint-stock company that submits a notification of approval of its Annual Report during the period from August 1 to December 31, 2026. This policy applies to both PTs that are subject to mandatory audits and those that are not.
Comparison with the Standard Rate
Outside of this grace period, the submission of a notification regarding approval of the Annual Report is subject to the following PNBP fees:
Category: PTTariff: Normal PNBP Fee: Audit Required: Rp500,000 per notification; Audit Not Required: Rp250,000 per notification
Under Ministerial Regulation No. 13/2026, all corporations—regardless of their audit requirement category—may submit their reports free of charge, provided they are submitted within the specified timeframe.
Reporting Process
The process for approving the Annual Report follows the steps below:
The Annual General Meeting of Shareholders approved the Company's Annual Report;
The agreement is set forth in a notarial deed;
The Board of Directors, through a notary public, submits the approved Annual Report to the Minister of Law via the Legal Entity Administration System (SABH).
As a side note, the provisions regarding the obligation to file this Annual Report are generally set forth in Ministry of Law and Human Rights Regulation No. 49 of 2025, which also establishes a tiered system of administrative sanctions—ranging from written warnings to the blocking of access to the SABH — for companies that fail to submit their reports by the specified deadline.
Recommendations
Given that this fee waiver is valid only through December 31, 2026, we recommend that any company that has not yet submitted its approved Annual Report promptly complete the necessary documents and file the report through a notary public before this period ends.
This article is intended for general informational purposes only and is not intended as legal advice for any specific case. For further consultation regarding your business’s legal compliance, please contact our team.
