The board of directors of a limited liability company (PT) needs to immediately review the company’s administrative compliance. The Directorate General of General Legal Administration (Ditjen AHU) of the Ministry of Law has stipulated that administrative sanctions for PTs that fail to submit annual reports will take effect in November 2026. The transition period is only a few weeks long.
The SABH Service Has Been in Operation Since June 1
The service for submitting PT annual reports through the Legal Entity Administration System (SABH) has been in effect since June 1, 2026. Submissions are made electronically. In addition to the General Meeting of Shareholders’ approval of the annual report, the company must upload two supporting documents: a notarial deed regarding the approval of the annual report and the annual report itself.
The Directorate General of AHU has also granted some leeway. Companies whose certificates have exceeded the 30-day period may still submit reports through the available system. During the transition period, no Non-Tax State Revenue (PNBP) fees will be charged for report submissions.
Types of Sanctions
The provisions regarding sanctions are based on Ministry of Law and Human Rights Regulation No. 49/2025. Companies that fail to fulfill this obligation may be subject to administrative sanctions in the form of a written warning and the blocking of access to the SABH. The process is phased. If a company fails to fulfill its obligation within 30 days of receiving the written warning notification in the SABH, its access will be blocked.
Blocking access to SABH has a direct impact on operations. The company may face delays when processing changes to corporate data that are handled through that system.
It Has Already Affected Other Services
Before the sanctions take effect, compliance with reporting requirements is already part of the service review process. When a company submits a request for changes to its board of directors and commissioners, a transfer of shares, or a change in a shareholder’s name, officials first verify that the annual report has been filed. Companies planning to undertake corporate actions at the end of the year should not delay.
This policy also aims to ensure data quality. The submission of annual reports is part of the government’s efforts to maintain the validity and accuracy of data on legal entities stored in the SABH.
Guidance for Business Owners
The Directorate General of AHU has repeatedly reminded business owners not to wait until they face penalties and to promptly submit their annual reports through SABH.
Practical steps the company can take:
Ensure that the annual shareholders’ meeting has been held and that the annual report has been approved.
Ask the notary to prepare the deed of approval for the annual report.
Upload articles of incorporation and annual reports via SABH by November 2026.
Check your SABH account notifications regularly so you don’t miss any warnings.
With sanctions just weeks away, reporting early is far cheaper and easier than dealing with the process of unblocking access.
This article is intended solely for general informational purposes and is not intended as legal advice. The application of these provisions may vary depending on the circumstances and needs of each corporation. To obtain advice tailored to your corporation’s specific circumstances, please contact our team of professionals.
