Permenkum 24/2026: New Provisions on Business Entity Administrative Services

Introduction

On 2 November 2026, the Minister of Law of the Republic of Indonesia enacted Regulation of the Minister of Law of the Republic of Indonesia Number 24 of 2026 on Services in the Field of Business Entities (“Permenkum 24/2026”), which took effect on 3 November 2026. Permenkum 24/2026 governs the administration of business entity services by the Directorate General of General Legal Administration (Direktorat Jenderal Administrasi Hukum Umum or “Ditjen AHU”), covering Limited Liability Companies (Perseroan Terbatas or “PT”), cooperatives, Village-Owned Enterprises (Badan Usaha Milik Desa or “BUM Desa”), civil partnerships, firms, and limited partnerships (persekutuan komanditer or “CV”).

Permenkum 24/2026 was issued to integrate various provisions concerning business entity administrative services that were previously dispersed across several Ministerial Regulations. Pursuant to Article 153, this regulation revokes and replaces the following eight regulations:

1. Regulation of the Minister of Law and Human Rights Number M.HH-03.AH.01.01 of 2009 on the Company Register;

2. Regulation of the Minister of Law and Human Rights Number 8 of 2018 on Legal Service Fees for the Establishment of Limited Liability Companies for Micro, Small, and Medium Enterprises;

3. Regulation of the Minister of Law and Human Rights Number 13 of 2020 on the Implementation of Taxpayer Status Confirmation for Certain Public Services;

4. Regulation of the Minister of Law and Human Rights Number 40 of 2021 on the Issuance of Certificates of Registration of Legal Entities for Village-Owned Enterprises/Joint Village-Owned Enterprises;

5. Regulation of the Minister of Law Number 13 of 2025 on the Ratification of Cooperatives;

6. Regulation of the Minister of Law Number 21 of 2025 on the Blocking and Unblocking of Access to Limited Liability Companies in the Legal Entity Administration System;

7. Regulation of the Minister of Law Number 25 of 2025 on the Provision of Legal Services for Civil Partnerships, Firms, and Limited Partnerships; and

8. Regulation of the Minister of Law Number 49 of 2025 on the Requirements and Procedures for the Establishment, Amendment, and Dissolution of Limited Liability Companies.

Furthermore, Articles 151 and 152 stipulate that Regulation of the Minister of Law and Human Rights Number 20 of 2024 on Procedures for Applying for Copies of Corporate Legal Service Products and Regulation of the Minister of Law Number 32 of 2025 on Procedures for Applying for Data Corrections of Legal Entities in the Form of Limited Liability Companies, Foundations, and Associations shall no longer apply to business entities governed by Permenkum 24/2026, but shall remain applicable to foundations and associations. Based on the considerations set out under the “Considering” section, this integration is necessary to improve the governance of business entity services in a systematic, integrated, and accountable manner, with the aim of ensuring effective, efficient, and accessible public services. The consolidation of these provisions is also intended to address potential regulatory overlaps and align the provision of services with legal developments and public needs.

Key Provisions

Book One: Limited Liability Company Services

Article 2 classifies companies into two types, namely capital-partnership limited liability companies (PT persekutuan modal) and individual limited liability companies (PT perorangan) that meet the criteria for micro and small enterprises. Pursuant to Articles 3 and 5, the establishment of a capital-partnership limited liability company must be carried out through an application submitted electronically by a notary through the Legal Entity Administration System (Sistem Administrasi Badan Hukum or “SABH”). Each application is subject to Non-Tax State Revenue (Penerimaan Negara Bukan Pajak or “PNBP”) as stipulated in Article 4.

Furthermore, Article 6 sets out the supporting document requirements that must be fulfilled in the process of establishing a Company. These documents include:

1. Copies and original counterparts (minuta) of the deed of establishment, as well as the original counterpart of the deed of merger if the Company is established as part of a merger;

2. Evidence of capital contribution in accordance with the form of contribution, whether in cash, in-kind, or in the form of the company's balance sheet;

3. A statement of undertaking to obtain licences from the relevant technical authorities, obtain a Taxpayer Identification Number (Nomor Pokok Wajib Pajak or “NPWP”), and submit Annual Tax Returns (Surat Pemberitahuan or “SPT”);

4. Information concerning the Company's full address; and

5. Documents relating to the Beneficial Owner, consisting of a power of attorney from the board of directors to the notary, a statement from the board of directors containing the identity of the Beneficial Owner, and the Beneficial Owner's consent.

These documents are generally retained by the notary as part of the administrative requirements for the establishment of the Company. Once the application has been received, the decree ratifying the Company's legal entity status is issued simultaneously and may be printed independently by the notary, as stipulated in Article 7.

Amendments to the Articles of Association and Company Data

Article 8 paragraph (3) governs amendments to the Articles of Association (“AoA”) that require the Minister's approval. Such amendments include changes to the Company's name, domicile, purposes and objectives, term of establishment, authorised capital, reduction of issued and paid-up capital, and changes in the Company's status from a private company to a public company or vice versa. Other amendments to the AoA, meanwhile, are subject only to notification to the Minister. The notification requirement also applies to changes in Company data, including changes to the composition of shareholders, the board of directors and the board of commissioners, mergers or spin-offs that do not involve amendments to the AoA, dissolution of the Company, and changes to the Company's address, as stipulated in Article 8 paragraphs (4) and (5).

Furthermore, Article 9 establishes a 30-calendar-day deadline for three obligations, namely incorporating resolutions of the General Meeting of Shareholders (“GMS”) into a notarial deed, notifying changes to the composition of the board of directors and the board of commissioners, and submitting an application for amendment, calculated from the date of the deed. If this deadline is exceeded, the application for amendment may no longer be submitted to the Minister. The application must be submitted electronically by the notary by uploading the deed, supporting documents, and a statement of responsibility, as stipulated in Articles 10 through 12. The obligation to attach the Annual Tax Return does not apply to Companies whose NPWP has been issued less than one year prior (Article 12 paragraph (2)).

Unlike the Company establishment process, applications for amendments are subject to examination within a maximum period of 14 working days. If any deficiencies in the documents are identified, the notary must rectify or complete the documents within 7 days. If this obligation is not fulfilled, the application will be rejected; however, the Company may submit a new application in accordance with Articles 13 through 15.

Annual Reports of Capital-Partnership Limited Liability Companies

Article 16 governs three stages of obligations:

1. The board of directors must submit the annual report to the GMS no later than 6 months after the end of the financial year;

2. The GMS approval of the annual report must be recorded in a notarial deed; and

3. Such approval must be submitted to the Minister through a notary no later than 30 days from the date the deed is signed, by uploading the deed and the annual report.

The annual report must at a minimum contain the financial statements, a report on the Company's activities, a report on social and environmental responsibility, a report on the supervisory duties of the board of commissioners, and details of the remuneration of the board of directors and the board of commissioners. Articles 17 and 18 stipulate the applicable sanctions. A written warning is sent through an SABH notification once the deadline has passed. If the obligation remains unfulfilled within 30 days thereafter, the Company's access to the SABH will be blocked. Consequently, all Company services, including amendments to the AoA and Company data, cannot be processed. The block may be lifted by submitting an application accompanied by the deed of approval and the annual report (Articles 19–20).

Individual Limited Liability Companies

Article 16 governs the obligation to submit the Company's annual report, which is carried out in three stages. First, the board of directors must submit the annual report to the GMS no later than 6 months after the end of the Company's financial year. Second, the GMS approval of the annual report must be recorded in a notarial deed. Third, such approval must be submitted to the Minister through a notary no later than 30 days from the date the deed is signed, by uploading the deed of approval and the annual report.

The annual report must contain, at a minimum, the financial statements, a report on the Company's activities, a report on the implementation of social and environmental responsibility, a report on the supervisory duties of the board of commissioners, and details of remuneration matters concerning members of the board of directors and the board of commissioners.

Articles 17 and 18 govern the sanctions for failure to fulfil the obligation to submit the annual report. The sanctions begin with a written warning delivered through an SABH notification after the deadline for fulfilling the obligation has passed. If the Company still fails to fulfil its obligation within 30 days from the date the warning is delivered, the Company's access to the SABH will be blocked. Such blocking results in the inability to process all Company administrative services, including applications for amendments to the AoA and Company data. To lift the block, the Company must submit an application accompanied by the GMS approval deed and the annual report, as stipulated in Articles 19 and 20.

Blocking and Unblocking of PT Access

Articles 30 through 39 govern the Blocking of Access upon application by an interested party, for example, in a share dispute. There are two types of blocking, namely a full block and a block limited to changes in shareholders (Article 32). Applicants may include the latest shareholders, former shareholders involved in a dispute (within a maximum of 3 years from the date they were recorded or following one transaction), heirs, government agencies, or Receivers. Applicants must attach a court judgment or court order granting the blocking request, evidence of the filing of Beneficial Owner information, and proof of PNBP payment. Shareholders holding more than 50% of the shares must also attach the Company's audited financial statements and tax reports (Articles 33–35). For individual limited liability companies, a former owner only needs to attach a statement of claim that has been registered with the court (Article 36). A power of attorney must be executed in the form of a notarial deed (Article 39).

The block may only be lifted if the dispute has ceased to exist. Evidence thereof may take the form of a deed or settlement agreement executed by all shareholders, a court judgment granting the unblocking request, or a court order revoking the case (Articles 42–44). In connection with any application for blocking or unblocking, the Director General may summon the parties for clarification before making a decision (Articles 38 and 48).

KSWP, Company Register, and Non-Electronic Services

Articles 50 through 52 require electronic Taxpayer Status Confirmation (Konfirmasi Status Wajib Pajak or “KSWP”) through the Directorate General of Taxes system before any amendments to the Company's AoA or data can be processed. If the taxpayer status is invalid, the application will not be processed until the status becomes valid. Articles 54 through 59 stipulate that the Company Register constitutes an official source of information that is open to the public. The register contains, among other things, capital structure, address, shareholders, management, and the financial statements of PTs that are required to undergo an audit. Such data may be obtained by anyone upon payment of PNBP. Article 60 provides for a non-electronic application channel in the event of internet network disruptions or if the SABH is non-operational, as confirmed by an official announcement. Article 61 stipulates that data concerning a blocked PT may still be requested in writing, together with information on its blocked status.

Book Two: Ratification of Cooperatives

Cooperative Names

Articles 67 through 73 require every cooperative establishment to be preceded by approval of its name. The name must consist of at least 3 words following the phrase “Koperasi” and the type of cooperative, except for Koperasi Merah Putih or government programmes. The name must also be written in Latin letters, must not already be in use, must not violate public order, and must not resemble the name of a state institution. Article 70 paragraphs (2)–(4) introduce three additional specific requirements: the phrase “TKBM” for port loading and unloading cooperatives, the word “Syariah” for sharia cooperatives, and the name of the subdistrict or regency/municipality for Koperasi Merah Putih where the village names are identical. Name approval is valid for a maximum of 30 days (Article 73).

Ratification of the Deed of Establishment

Article 74 requires an application for ratification to be submitted through a notary no later than 60 days from the date the deed of establishment is signed. If the deadline is missed, the process must be repeated from the beginning. Article 75 governs the documents to be retained by the notary, namely the original counterpart of the deed, minutes of the establishment meeting, evidence of capital contributions in an amount of at least the Mandatory Savings (Simpanan Pokok), and the work plan. The deed of establishment and the minutes of the meeting must also be uploaded to the SABH. Savings and loan cooperatives must additionally provide a work plan covering at least 3 years, an administrative and bookkeeping system, the curriculum vitae of prospective managers, and a list of work facilities (Article 76). The ratification decree is issued upon receipt of the application (Article 78).

Amendments to the AoA and Dissolution of Cooperatives

Articles 79 and 80 stipulate that amendments to business activities, mergers, and divisions of cooperatives require ratification and must be submitted no later than 60 days from the date of the amendment deed. Other amendments to the AoA are subject only to notification, which must be submitted no later than 30 days from the date the deed is signed (Article 87). Articles 91 and 92 stipulate that an application for the dissolution of a cooperative is not submitted by the cooperative itself. Instead, the dissolution is notified by the minister responsible for cooperatives in the form of a Decree on Dissolution, following which the Minister of Law revokes the cooperative's legal entity status.

Book Three: Issuance of Certificates of Registration of Legal Entities for Village-Owned Enterprises/Joint Village-Owned Enterprises

Certificate of Legal Entity Registration

Articles 97 and 98 stipulate that applications for the registration and amendment of the AoA of BUM Desa must be submitted through the Village Information System (Sistem Informasi Desa or “SID”) application, rather than directly through the SABH. Following verification by the ministry responsible for village affairs, the Minister of Law issues the certificate electronically. Changes to the name and domicile result in the issuance of an amended certificate, whereas other amendments to the AoA are subject only to a notification receipt letter.

Book Four: Provision of Legal Services for Civil Partnerships, Firms, and Limited Partnerships

Registration of Establishment, Amendments, and Dissolution

Articles 103 through 116 stipulate that all partnership-related services must be submitted through a notary via the Business Entity Administration System (Sistem Administrasi Badan Usaha or “SABU”). The applicable deadlines are 60 calendar days from the date of the deed for establishment and 30 calendar days for amendments to the AoA. If these deadlines are exceeded, the application may no longer be submitted (Articles 104 and 109). Before registration, the notary must check the proposed name against criteria similar to those applicable to cooperative names. The notary uploads the deed and a stamped statement letter, while retaining the original counterpart of the deed and Beneficial Owner data (Articles 105–106 and 111–112). Dissolution may take place upon expiry of the partnership's term, achievement of its objectives, destruction of partnership property, the partners' decision, or other legal grounds (Article 114). Proof of registration takes the form of a Certificate of Registration (Surat Keterangan Terdaftar or “SKT”), which is printed and stamped by the notary.

Blocking, Data Access, and Non-Electronic Services

Articles 117 through 126 stipulate that applications for blocking and unblocking must be submitted in writing by a partner, an authorised officer or agency, or a Receiver. A partner must attach a court judgment or court order for a blocking application, and evidence of a settlement, withdrawal of proceedings, or court judgment for an unblocking application. Partnership data is open to the public (Article 127). The non-electronic channel is available only where there is no internet connection or the SABU is non-operational (Article 129).

Book Five: Procedures for Applying for Corrections to Business Entity Data

Scope, Documents, and Examination

Articles 132 through 139 stipulate that a notary may apply for corrections if data recorded in the SABH or SABU is incorrect. For PTs, corrections are limited to 17 data elements, including the name, NPWP, address, capital, shares, shareholders, board of directors, board of commissioners, and public accountant. For partnerships, corrections cover the name, NPWP, address, assets, partners, management, and deed data. The documents that must be uploaded are the application letter, the notary's stamped statement of responsibility, a copy of the deed, and a copy of the Decree or SKT to be corrected. Corrections to shareholders' email addresses and telephone numbers require only an application and a power of attorney from the board of directors (Article 135). Examination must be completed within a maximum of 14 working days. Incomplete applications are immediately rejected without an opportunity to rectify or complete the documents, although a new application may be submitted (Articles 137–139). It should be noted that, for the purposes of Books Five and Six, “Day” means a working day.

Book Six: Applications for Copies of Business Entity Legal Service Products

Requirements and Time Limits

Articles 141 through 149 stipulate that copies of decrees, notification receipt letters, certificates, or certificates of registration relating to PTs, cooperatives, and partnerships may only be requested if the original legal service product has been lost or damaged. Applicants may be members of the board of directors, the chairperson of the management board, active partners, or their authorised representatives. For lost documents, a certificate of loss issued by the Police must be attached. For damaged documents, the original damaged document or evidence of the damaged product must be attached. Specifically for cooperatives, copies are only available for legal service products issued on or after 28 September 2019. Examination must be completed within a maximum of 3 working days, deficiencies must be rectified within 14 working days, and the copy must be issued within a maximum of 14 working days.

Transitional Provisions

Permenkum 24/2026 adopts the principle that applications submitted and being processed before the regulation comes into force shall continue to be processed in accordance with the previous regulations. Article 62 stipulates that applications for the registration of the establishment, amendment, and dissolution of Limited Liability Companies (PTs) that have been submitted and are being processed shall continue to be processed pursuant to Permenkum 49/2025.

With regard to the blocking of access, Article 63 confirms that PTs whose Access is under a Blocking status prior to the entry into force of Permenkum 24/2026 shall remain blocked. Meanwhile, applications for the lifting of an Access Block that have been submitted and are being processed shall continue to be completed pursuant to Permenkum 21/2025.

The same principle applies to Civil Partnerships, Firms, and Limited Partnerships (CVs). Pursuant to Article 130, applications for the registration of establishment, amendments to the AoA, dissolution, Blocking of Access, and the lifting of Blocking of Access that have been submitted and are being processed prior to the entry into force of Permenkum 24/2026 shall continue to be processed pursuant to Permenkum 25/2025. Furthermore, Civil Partnerships, Firms, and CVs whose Access is under a Blocking status prior to the entry into force of this regulation shall remain blocked.

Closing

Permenkum 24/2026 integrates the provision of administrative services for various forms of business entities within a single regulatory framework, covering establishment, amendments, dissolution, blocking of access, data correction, and the issuance of copies of legal service products. This regulation not only simplifies the administrative framework previously dispersed across various regulations, but also establishes document requirements, submission mechanisms, deadlines, and the consequences of failure to fulfil administrative obligations.

For Limited Liability Companies, several provisions require particular attention, especially the deadlines for submitting amendments to the AoA and Company data, the obligation to submit annual reports, and the consequences of blocking access to the SABH if such obligations are not fulfilled. In addition, the provisions concerning KSWP and public access to the Company Register further strengthen the aspects of compliance and administrative transparency for Companies. Similar provisions are also applied through mechanisms adapted to cooperatives, BUM Desa, civil partnerships, firms, and CVs.

With the entry into force of Permenkum 24/2026, notaries and business operators must adjust their implementation of business entity administrative services to the new requirements and procedures, particularly with regard to document completeness, deadlines, and the use of the applicable electronic administration systems. Compliance with these obligations is essential to ensure the smooth processing of services and to maintain the orderly administrative status of business entities in accordance with the applicable laws and regulations.