What Comes Next for Compliance After the AGMS Report

Completing an AGMS doesn’t automatically close a company’s annual corporate compliance obligations in Indonesia. After the Annual General Meeting of Shareholders (AGMS) approves the annual report, companies must document the approval correctly and complete the required filing through the Legal Entity Administration System (SABH). 

Permenkum No. 49/2025 requires companies to record AGMS approval of the annual report in a notarial deed and submit it electronically through SABH. The SABH annual report filing system has been in effect since June 1, 2026, with submissions generally required within 30 calendar days of the deed date. 

For businesses, the risk is therefore no longer limited to holding the AGMS late. Proper post-AGMS documentation and SABH filing are crucial to maintain confidence in your company’s compliance status and avoid future issues. 

Key Takeaways

• Completing the AGMS is not the final step; businesses must still document and file the annual report approval through SABH. 
• Businesses must present the annual report to the AGMS within six months after the financial year ends. 
• After approval, businesses must record the decision in a notarial deed and file it through SABH within 30 calendar days of the deed date to ensure compliance and avoid penalties. 
• Businesses must upload the notarial deed and annual report, and SABH issues an official acceptance receipt once it receives the filing. 
• Missing the SABH filing deadline can lead to administrative sanctions, including fines, legal penalties, and restrictions on future corporate actions, highlighting the importance of timely compliance to avoid serious legal risks. 

Post-AGMS Compliance at a Glance 

Stage	What the Company Must Complete	Key Timing	What to Keep
AGMS approval	Present the annual report for shareholder approval	Within 6 months after the financial year ends	Approved annual report and AGMS records
Notarial documentation	Record the AGMS approval of the annual report in a notarial deed	After AGMS approval	Signed notarial deed
SABH filing	Submit the AGMS approval through a notary, with the deed and annual report	Within 30 calendar days from the deed date	SABH filing records
Compliance confirmation	Confirm that the submission has been received through SABH	After successful submission	Official notification acceptance receipt
If the filing is missed	Resolve the outstanding filing before access restrictions affect future corporate actions	A written warning may be followed by SABH access blocking if non-compliance continues	Evidence that the outstanding filing has been resolved

The filing documents include the notarial deed approving the annual report and the annual report itself.  

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What Must Companies Complete After the AGMS? 

After the shareholders approve the annual report during the AGMS, businesses should not treat AGMS approval as the final compliance step. 

Permenkum No. 49/2025 requires recording the approval of the annual report in a notarial deed. The Board of Directors then submits the approval to the Minister of Law through a notary using SABH. 

Companies should therefore make sure that: 

• The final AGMS resolutions correctly reflect shareholder approval. 
• The annual report approval is recorded in the required notarial deed. 
• The company submits the annual report and supporting documents correctly through SABH. 
• The corporate information used in filing matches the company’s latest records. 
• The company obtains and retains the official SABH acceptance receipt as confirmation that the filing is complete. 

When Must the AGMS Approval Be Filed Through SABH? 

Once the AGMS approves the annual report, the company must record the approval in a notarial deed and submit it electronically through SABH. 

The key filing requirements are: 

• The AGMS must record the approval of the annual report in a notarial deed. 
• The Board of Directors submits approval to the Minister of Law through a notary. 
• The submission must be completed within 30 calendar days from the date the notarial deed is signed. 
• The filing is made electronically through SABH. 
• Upload the notarial deed and annual report as supporting documents. 

For example, if the relevant notarial deed is signed on July 15, the 30-day SABH filing period starts on that deed date. 

During the 2026 transition period, companies with older deeds that exceeded the 30-day filing window can consult the Directorate General of General Legal Administration (Ditjen AHU) for temporary accommodations, ensuring they understand how to address past filings and avoid future sanctions. 

How Do You Know Your SABH Annual Filing Is Complete? 

After the Ministry of Law receives the annual report approval submission, the Directorate General of General Legal Administration issues a Surat Penerimaan Pemberitahuan, or notification acceptance receipt.  

Businesses should therefore confirm that: 

• The submission has actually been entered into SABH. 
• The required documents have been uploaded. 
• The filing has been accepted. 
• The official electronic notification acceptance receipt has been issued. 
• The receipt and supporting corporate documents are properly retained. 

The acceptance receipt provides important evidence that the SABH filing stage is complete. 

For groups managing several Indonesian entities, maintaining these records centrally can also reduce problems when future corporate actions require historical compliance confirmation. 

What Happens If a Company Misses the SABH Filing? 

Under Permenkum No. 49/2025, companies that miss the SABH filing requirement may face: 

• A written warning through SABH and/or email. 
• SABH access blocking if the filing remains unresolved for 30 calendar days after the warning. 
• Delays to corporate actions that require SABH access. 
• Additional steps to restore access by submitting the required documents through SABH. 

Administrative sanctions are expected to be enforced from November 2026, but annual report compliance may already be checked when companies process certain corporate filings. 

Businesses with outstanding filings should resolve them before they affect future corporate actions. 

Which Corporate Actions Can Be Affected by SABH Blocking? 

If SABH access is blocked, companies may face delays in corporate actions that require updates through the system, including: 

• Changes to the Board of Directors. 
• Changes to the Board of Commissioners. 
• Share transfers. 
• Updates to shareholder information. 

Other corporate changes submitted through SABH may also be affected until the compliance issue is resolved. 

For businesses planning restructurings, management changes, or shareholder transactions, unresolved post-AGMS compliance can therefore create avoidable delays. 

How InCorp Supports Post-AGMS Compliance and Future Corporate Actions 

Managing the AGMS is only useful if the decisions made during the meeting are carried through into the company’s legal records. 

InCorp Indonesia (an Ascentium Company) can support businesses in coordinating annual corporate compliance, including: 

• Preparing and assessing AGMS and annual report documentation. 
• Coordinating the required notarial documentation. 
• Managing SABH filing requirements and following up. 
• Confirming that the filing is complete and the relevant acceptance receipt is obtained. 
• Assessing outstanding corporate records before director, shareholder, capital, or other corporate changes. 
• Supporting subsequent corporate actions and ongoing corporate secretarial requirements. 

For companies entering Indonesia, you can apply the same approach from the business setup stage, so incorporation records, shareholder information, governance requirements, and future annual compliance obligations are managed consistently from the start. 

Already completed your AGMS but unsure whether the SABH filing is complete?  

Talk to our experts to assess your post-AGMS compliance position before your next corporate action. Fill out the form below for a free initial consultation. 

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