12 June 2020

The Minister of Trade (“MoT”) has issued a new regulation, namely MoT Regulation No. 25 of 2020 on Annual Company Financial Report (“Reg 25/2020”) to revoke Decree of the Minister of Industry and Trade No. 121/MPP/Kep/2/2002 on the Submission of Annual Company Financial Reports (“Decree 121/2002”).

Similar to what has been regulated in Decree 121/2002, companies are required to submit Annual Company Financial Reports (Laporan Keuangan Tahunan Perusahaan – “LKTP”) to the MoT via the Directorate General of Domestic Trade (“DGDT”) if the companies fulfill one of the following criteria:

  • limited liability companies/Perseroan Terbatas that:
    • are public companies;
    • operate in a business sector related to the allocation of public funds;
    • issue acknowledgements of indebtedness;
    • have assets with a minimum value of IDR25 billion; or
    • are debtors required by banks to audit their financial reports.
  • foreign companies which are located within and that conduct their business activities within Indonesian jurisdiction (including branch offices, subsidiary companies, agents and company representatives) and that are able to enter into agreements; or
  • PERSERO, PERUM and regional companies.

The LKTP must be submitted by the companies within six months after the end of the companies’ accounting year. The LKTP must be audited by an independent public accountant, has been authorised through General Meeting of Shareholders and at least include information regarding (i) the company’s balance sheet that can show the company’s financial position; (ii) statement of income; (iii) report on the changes of equity (if any); (iv) cash flow report; and (v) annotated financial statements which should at the least outline the current condition of any debts.

Reg 25/2020 sets out a new method for the submission of a company’s LKTP which requires the company to submit their LKTP online to DGDT through the Integrated Licensing Information System or Sistem Informasi Perizinan Terpadu (“SIPT”) portal. The LKTP should then be submitted as Portable Document Format (PDF) files in accordance with the original documents and should be in line with the relevant company profiles on the SIPT Portal. In the event that the SIPT cannot be utilised for more than 24 hours, then the submission of LKTP may be completed manually or through emails which are sent to the Directorate of Business Development and Distribution Agents.

The latest update that we obtained from our no-name basis research is that the system to submit LKTP online in the SIPT portal is still in development and improvement process. Due to the implementation of Large-Scale Social Restrictions or Pembatasan Sosial Berskala Besar (“PSBB”) within the province of DKI Jakarta, the MoT office is closed until further instruction from the Government of Indonesia and LKTP must be submitted online. A company can submit its LKTP and supporting documents to lktp.bupd@gmail.com.

Below are the supporting documents for manual LKTP submission (not conducted via SIPT system):

  • the original company profile printed on the company’s letterhead and executed on stamp duty (meterai);
  • the company profile in digital version; and
  • the original Power of Attorney (“PoA”) from the company if the submission is delegated to the company’s public accountant.

If you have any questions or require any additional information, please contact contact Hanim Hamzah or Andina Sitoresmi of Roosdiono & partners (a member of ZICO Law).

This alert is for general information only and is not a substitute for legal advice.


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