The issuance of Regulation No. 25 of 2020 on Annual Company Financial Reports by the Minister of Trade (“Regulation 25/2020”) has set out several provisions relating to the submission of Annual Company Financial Reports (Laporan Keuangan Tahunan Perusahaan – “LKTP”). Herewith the outline of the provisions:

1. LKTP shall be submitted to the Director-General of Domestic Trade by:
2. Limited Liability Companies (PT) under one of these criterias:

• Public companies;
• Operate within a business sector relating to the allocation of public funds;
• Issue acknowledgements of indebtedness (surat pengakuan utang);
• Own assets with a minimum value of IDR 25 billion; or
• Debtors which are required by banks to audit their annual reports;

1. Foreign companies which conduct their business activities within Indonesian jurisdiction (including branch offices, subsidiary companies, agents, and company representatives) and which are able to enter into agreements; and
2. PERSERO, PERUM and regional companies.
3. LKTP shall be submitted within 6 (six) months of the end of the accounting year and meet several requirements;
4. The submission of LKTP should be via the Integrated Licensing Information System (Sistem Informasi Perizinan Terpadu – “SIPT”) portal;
5. All company financial information from SIPT shall be available to the general public, with written request and certain tariffs.

One of the most significant progress of legislation made by the Regulation 25/2020 was company financial information that is sourced from the submission of LKTP shall be accessible to public. This provision has allowed the interested parties to be able to review companies’ financial status, thus by way of illustration enables the interested parties to ensure that they are better informed in terms of the companies’ ability to fulfill their financial obligations.

However, enforcing Regulation 25/2020 would not be as straightforward as it was written and interpretations toward Regulation 25/2020 are still relative and unclear as the Regulation 25/200 was recently enacted and its implementing regulation has yet been legalized. Therefore, further inquiries and assistance relating to LKTP shall be available through contact to our associate specializing in corporate compliance, Mr. Yudho Adi Nugroho (yudhoadi@sajogolaw.com or [email protected]).                                  

Source  :     'New Submission Procedure for Annual Company Financial Reports Introduced', Indonesian Legal Brief, 21 April 2020, Accessed 22 April 2020, (www.hukumonline.com).