Indonesia New Regulatory Updates – Business Classification Code & Mandatory Annual Report Filings

KBLI Code

The Central Statistic Body (Badan Pusat Statistik – BPS) issued new business classification code under BPS Regulation No. 7 of 2025 dated 17 December 2025 (2025 KBLI) replacing the 2020 KBLI Code with immediate effect.

There are some changes to the KBLI codes under the 2025 KBLI.

The users of the KBLI Code shall make the necessary adjustments to the 2025 KBLI within 6 months from 17 December 2025 (by 17 June 2026).

This means if the current KBLI Code has been changed under the 2025 KBLI for the same line of business, a company shall amend its articles of association by 17 June 2026. However this would depend on whether the Indonesian Ministry of Law and the Capital Investment Coordinating Board (BKPM) have updated their electronic systems to be aligned with the 2025 KBLI so that the amendments could be filed accordingly.

Companies should check their respective articles of association if any amendments to its lines of business (Article 3) would be required.

Minister of Law Regulation No. 49 of 2025 on Requirements and Procedures for Incorporation, Amendments and Liquidation of Limited Liability Companies (MOLR No. 49/25)   

MOLR No. 49/25 is effective as of 11 December 2025.

Manual review: Any amendments to the articles of association and changes of company data (such as changes of shareholders, directors, and commissioners) would be subject to review by the Ministry of Law, and the review period is 14 working days from the date the application is submitted by the notary.

Previously, as soon as the notary submits the filing, the approval or receipt issued automatically by the Ministry of Law system. This means that there could be delays for obtaining the approvals and receipts from the Ministry of Law.

The changes of directors and commissioners are effective upon the shareholders’ resolutions are passed or any date as stipulated by the shareholders in the resolutions. Therefore, regardless the manual review, the changes as mentioned earlier could be effective before the Ministry of Law issues the receipt of the filing after the manual review.

Mandatory annual report submission: The Ministry of Law requires the annual report to be approved by an Annual General Meeting of Shareholders (AGM) within 6 months after the end of the financial year. The AGM resolutions shall be made in a notarial deed.

Such annual report (includes the financial statement) shall be filed to the Ministry of Law by the notary within 30 days from the date of the notarial deed. There is no such requirement under the Company Law.

The Ministry of Law could impose administrative sanctions for failure to submit the annual report of (i) a written warning; and (ii) blocking the access to the Ministry of Law system (if the company ignores the written warning), which means the company may not submit any corporate filings.