Indonesia

Financial Reporting Obligations for Companies in Indonesia

1. Registry for Financial Statement Submission

In Indonesia, companies are required to submit their financial statements (annual reports) to Otoritas Jasa Keuangan (OJK) (Financial Services Authority) (https://www.ojk.go.id/) for public companies and certain regulated entities. Non-public companies must submit their reports to Kementerian Hukum dan Hak Asasi Manusia (Kemenkumham) (Ministry of Law and Human Rights) (https://www.kemenkumham.go.id/).

Public Access to Financial Statements:

In Indonesia, financial statements of listed companies are publicly available through the Indonesia Stock Exchange (IDX) (https://www.ojk.go.id/).

However, financial reports of private companies (PT, non-listed entities) are not publicly accessible. Such reports are submitted to regulators but are not disclosed to the general public.

2. Legal Forms Required to Publish Financial Statements

In Indonesia, companies are obligated to submit financial statements depending on their legal form. Below is a list of common legal forms and their obligations.

  • Perseroan Terbatas (PT) - Limited Liability Company
    Explanation: The most common legal form for private entities in Indonesia, similar to a corporation (Inc.) in other countries.
    Obligations: Required to submit financial statements to the Otoritas Jasa Keuangan (OJK) (https://www.ojk.go.id/) if it meets size criteria or is publicly listed. External audits are required based on size thresholds.
  • Perusahaan Terbuka (Tbk) - Public Company
    Explanation: A public company whose shares are traded on the stock exchange.
    Obligations: Must submit financial statements to the OJK and the stock exchange, Bursa Efek Indonesia (IDX) (https://www.idx.co.id/). Audits are mandatory for all public companies.
  • Badan Usaha Milik Negara (BUMN) - State-Owned Enterprise
    Explanation: A company owned or controlled by the Indonesian government.
    Obligations: Required to submit financial statements and undergo annual audits, irrespective of size.
  • Koperasi - Cooperative
    Explanation: A cooperative formed for mutual benefit, typically owned and operated by its members.
    Obligations: Financial reporting requirements apply if revenue or asset thresholds are met. Audits are conditional based on the cooperative's size.
  • Persekutuan Komanditer (CV) - Limited Partnership
    Explanation: A partnership where at least one partner has unlimited liability while others have limited liability.
    Obligations: Not required to submit financial statements to OJK unless certain size criteria are met.
  • Firma (Fa) - General Partnership
    Explanation: A partnership where all partners have unlimited liability.
    Obligations: Generally not required to submit financial statements unless voluntarily registered or if they exceed certain thresholds.
  • Perusahaan Daerah (PD) - Regional Government-Owned Enterprise
    Explanation: A company owned by regional governments, typically engaged in public services or regional economic activities.
    Obligations: Must submit financial statements and undergo audits as per regulations.
  • Yayasan - Foundation
    Explanation: A non-profit organization established for social, religious, or humanitarian purposes.
    Obligations: Required to submit financial statements depending on revenue size, and audits may be mandatory if certain financial thresholds are met.
  • Perusahaan Perorangan - Sole Proprietorship
    Explanation: A business owned and operated by a single individual.
    Obligations: Sole proprietorships are generally exempt from mandatory financial statement submission unless they opt for formal incorporation or reach specific size thresholds.

Legal Forms Not Obliged to Submit Financial Statements:

  • Persekutuan Perdata (Civil Partnership): Civil partnerships focused on non-commercial activities typically do not have to submit financial statements unless they voluntarily incorporate under other forms.
  • Usaha Mikro Kecil dan Menengah (UMKM) - Micro, Small, and Medium Enterprises: These entities may be exempt unless they meet specific criteria set by Indonesian regulations concerning size, revenue, or assets.

3. Audit Requirements for Financial Statements

In Indonesia, the requirement to audit financial statements depends on the company's legal form and its size, based on criteria such as turnover, total assets, and the number of employees. Below is a detailed table with legal forms and the audit rules.

Legal Form

Rule

Criteria

Perseroan Terbatas (PT) (Limited Liability Company)

Audit is mandatory if size thresholds are met

Must meet two out of the following three criteria: - Total assets (no less than) IDR 50 billion - Total revenue (no less than) IDR 100 billion - Employees (no less than) 100

Perusahaan Terbuka (Tbk) (Public Company)

External audit required

All public companies must undergo an audit regardless of size.

Badan Usaha Milik Negara (BUMN) (State-Owned Enterprise)

Audit is compulsory

All state-owned enterprises must undergo an annual audit regardless of size or revenue.

Koperasi (Cooperative)

Conditional audit based on size

Audit required if the cooperative exceeds revenue or asset thresholds set by OJK.

Persekutuan Komanditer (CV) (Limited Partnership)

Conditional audit based on size

Audit is required if the business exceeds the size thresholds (similar to PT criteria).

Firma (Fa) (General Partnership)

Conditional audit based on size

Audits are required if the partnership meets the financial thresholds as mentioned above.

Perusahaan Daerah (PD) (Regional Government-Owned Enterprise)

Mandatory audit

Regional enterprises must undergo an audit regardless of their size.

Yayasan (Foundation)

Conditional audit based on size

Audit required if the foundation meets the financial thresholds for revenue or assets.

Perusahaan Perorangan (Sole Proprietorship)

No audit required

Not required to undergo an audit unless voluntarily incorporated into another legal form.

Key Audit Criteria for Legal Forms:

For most legal forms, an external audit is mandatory if the company meets two out of the following three criteria:

  • Total assets: IDR 50 billion or more.
  • Total revenue: IDR 100 billion or more.
  • Number of employees: 100 or more.

Notes:

  • Small and medium-sized enterprises (UMKM) are generally exempt from audit requirements unless they exceed the thresholds mentioned above.
  • Foreign-owned branches must follow the same audit rules as domestic companies, and audits are required if the size criteria are met.

4. Stock Exchange Listing and Reporting Requirements

For companies listed on the Bursa Efek Indonesia (IDX) (Indonesian Stock Exchange) (https://www.idx.co.id/), it is mandatory to publish their financial statements in compliance with the stock exchange's listing requirements.

Stock Exchange name : Bursa Efek Indonesia (IDX) (https://www.idx.co.id/)

5. Deadlines for Submission of Financial Statements

The deadline for the submission of financial statements varies by company type in Indonesia:

  • Perseroan Terbuka (Tbk) – Publicly listed companies must submit their financial reports within 90 days after the end of the financial year.
  • Perseroan Terbatas (PT) – Limited liability companies must submit their reports within 6 months after the end of the financial year.
  • Koperasi – Cooperatives are required to submit their reports within 6 months after the financial year ends.

6. Partial Financial Statements Submission

Partial financial statements may be required in specific scenarios, such as:

  • Perseroan Terbatas (PT) involved in mergers, acquisitions, or liquidation.
  • Companies operating in regulated sectors (e.g., banking, insurance) are required to submit quarterly financial statements in addition to their annual reports (overseen by OJK: https://www.ojk.go.id/).

7. Consequences of Late Submission

Failure to submit financial statements on time can result in various penalties and legal actions:

  • Fines: The Otoritas Jasa Keuangan (OJK) may impose fines on publicly listed companies ranging from IDR 1 million to IDR 50 million (OJK: https://www.ojk.go.id/).
  • Administrative penalties: Non-compliance by private companies (Perseroan Terbatas) can result in the revocation of business licenses by the Ministry of Law and Human Rights (Kemenkumham) (https://www.kemenkumham.go.id/).
  • Strike-off: Continuous failure to submit financial statements may lead to a company being struck off the business register, leading to the suspension or cessation of business operations.

8. Requirements for Foreign-Owned Branches and Newly Established Companies

Foreign-owned branches (PMA – Penanaman Modal Asing ) and newly established companies in Indonesia are subject to additional reporting obligations:

  • Foreign-Owned Enterprises (PMA) must file quarterly and annual reports to the Badan Koordinasi Penanaman Modal (BKPM) (Investment Coordinating Board) (https://www.bkpm.go.id/) and OJK (https://www.ojk.go.id/).
  • Newly established companies are required to submit their first financial reports within 6 months after the end of their first financial year.

Sources

Source Link
Otoritas Jasa Keuangan (OJK) https://www.ojk.go.id/
Kementerian Hukum dan Hak Asasi Manusia (Kemenkumham) https://www.kemenkumham.go.id/
Bursa Efek Indonesia (IDX) https://www.idx.co.id/
Badan Koordinasi Penanaman Modal (BKPM) https://www.bkpm.go.id/
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