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New Requirement for Annual Report Approval to Be Notarized in Indonesia

Indonesia has introduced a significant corporate compliance requirement through Minister of Law Regulation No. 49 of 2025 (Permenkum No. 49/2025). Under the regulation, the approval of a company’s Annual Report by the General Meeting of Shareholders (GMS/AGM) must be incorporated into a notarial deed and subsequently reported to the Ministry of Law through the Legal Entity Administration System (SABH).

This requirement represents a major shift from previous practice, where many private limited liability companies typically documented annual shareholder approvals through internal meeting minutes without any obligation to submit them to the government. The new framework strengthens regulatory oversight and formalizes annual corporate reporting obligations.