Minister of Trade Regulation No. 25 Year 2020 (“MOT 25”) revoked the previous regulation under Minister of Industry and Trade Decree No.121/MPP/KEP/2/2002 (“MOIT 121”). MOT 25 has been effective as of 19 March 2020.

MOT 25 regulates the same matters as MOIT 121 that certain companies must file its audited financial report to MOT. In line with the current various filing which is required to be made through online, filing of the audited Annual report to MOT is now required to be made through online as it is regulated under MOT 25 namely addressed to the Ministry of Trade’s online Integrated Licensing Information System (“SIPT”- Sistem Informasi Pelayanan Terpadu) through  

The applicant must already have had NIB to access SIPT and use the same username and password of OSS system.

The same as previously regulated under MOIT 121, the following are companies which are obliged to file such of audited annual financial report to MOT:

1. A limited liability company which meets one of these criteria:

-          A public company

-          engaged in a business sector which pooling public fund;

-          Issuing debt securities;

-          Having aktiva or assets at least Rp (twenty five billion Rupiah); or

-          A debtor which bank requires such debtor’s annual financial report to be audited.

2. A foreign company which is located and running its business in Indonesia including through its branch office, subsidiary, agent or representative office.

3. State owned companies which are PERSERO, PERUM and Perusahaan Daerah.

Failure to do such filing obligation, the obligor will be subject to administrative sanctions, starting from a warning letter up to revocation of business license or commercial/operational license.


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