Date : 24 April 2020 Author : IKRAIKRA

In March 2020, the Minister of Trade of the Republic of Indonesia (“MOT’) issued MOT Regulation No. 25 of 2020 regarding Company Annual Financial Reports (“MOT Regulation 25/2020”). This regulation has been in force since 19 March 2020 and replaces Minister of Industry and Trade Decree No. 121/MPP/Kep/2/2002 dated 25 February 2002.

Several key provisions under MOT Regulation 25/2020 are as follows:

(1) MOT Regulation 25/2020 requires certain companies to submit their Annual Financial Report (“LKTP”) to the MOT through the Directorate General of Domestic Trade by not later than six months following the end of their financial year. The LKTP must first be audited by a public accountant and approved by the General Meeting of Shareholders or any other company organ authorized to doing so based on the prevailing laws and regulations.

(2) The companies which are subject to this requirement are the following companies:

(a) Limited Liability Companies (Perseroan Terbatas) having fulfilled one of the following criteria:

    • classified as a public or listed company;
    • having a line of business in managing public funds;
    • issuing letters of indebtedness;
    • having total assets of at least IDR 25 billion; or
    • being a debtor whose annual financial reports are required to be audited;


(b) Foreign companies which have domicile and run their business within the Republic of Indonesia, including their branch offices, subsidiaries, etc.; or

(c) State-Owned Companies (PERSERO), Public Service Companies (PERUM), and Region-Owned Companies.

(3) The LKTP shall be submitted online through the Integrated Licensing Information System (SIPT) portal ( The MOT will issue an LKTP Submission Receipt (“STP-LKTP”) within five business days since complete submission of the LKTP.

(4) Any incompliance with the requirements under MOT Regulation 25/2020 may be subject to the following administrative sanctions: written warnings; revocation of STP-LKTP (as applicable); revocation of business license and/or operational/commercial licenses for companies carrying out trading business activities; and/or recommendation of revocation of business license and/or operational/commercial licenses for companies carrying out non-trading business activities.