PT PMA Owners - Take Note: What You Need to Know to Be Compliant in 2025
If you own a PT PMA in Indonesia, the most important thing to note is that regulatory enforcement has become considerably stricter in 2025. Indonesian authorities are now taking a much more systematic approach to making sure that foreign investment companies are meeting their compliance obligations.
PT PMAs in Bali are now under increased government scrutiny. Compliance with immigration and business regulations is more critical than ever to ensure smooth operations.
Recent enforcement measures have shown that the government is committed to making sure PT PMAs are operating in accordance with Indonesia’s regulatory requirements. In recent news, 267 foreign-owned companies have had their business licenses revoked following what is known as Operation Wira Waspada. This operation went underway as part of a broader movement focused on ensuring immigration law compliance, and has involved increased scrutiny on foreign owned companies. If you own one, it’s critical that you understand and follow regulatory requirements so you can continue business as usual in all other aspects.
What's Changed in 2025?
The Indonesian authorities have now improved their monitoring of businesses through the Online Single Submission system (OSS), as well as strengthening coordination between BKPM and Immigration authorities. PT PMA owners should maintain active compliance rather than assuming minimal oversight, as the days of informal compliance are over.
What You Need to Do:
1. Monitor Your Business Email Daily
If you established your PT PMA through Bali Solve or another consultant, you should have had a dedicated Gmail account set up for your business. This serves as your official communication channel with Indonesian authorities.
Critical notifications from:
the OSS Business Licensing System
BPJS Social Security
the DJP Tax Authority
the BKPM Investment Coordinating Board
are delivered to this email address. These include compliance warnings, documentation requests and regulatory updates. Usually if there's a compliance issue, authorities will send a prior warning to this email before any action is taken. That’s why it’s so important to continually check your email, so that you can take proactive steps to minimize any potential issues.
Set up daily email monitoring or forward messages to your personal account. If you receive official communication that you don’t understand or have doubts about, contact your PT PMA consultant rather than responding on your own or leaving it on the back burner.
2. Complete BPJS Registration Within 30 Days
As of this year, BPJS (Badan Penyelenggara Jaminan Sosial) registration is being actively enforced. Even if your PT PMA is inactive, you are still required to register the company with BPJS Ketenagakerjaan (Employment Social Security) within 30 days of business incorporation.
Furthermore, all companies employing Indonesian nationals must verify whether their employees are already registered with personal BPJS Health. If they are not, it becomes the company's obligation to facilitate their registration not just with BPJS Employment, but also with BPJS Health program and provide the mandatory health and social security contributions accordingly.
Failure to comply with BPJS registration requirements may result in a summons by the authorities, including the police, to provide an explanation as to why the company is not employing local workers and/or fulfilling its obligations to contribute to mandatory social security programs. This reflects the government's push to ensure all companies are contributing to local employment and social security.
Failure to register for BPJS can result in flagging during compliance reviews, so make sure you stay on top of it and register immediately after opening your PT PMA, whether it’s operational or not.
3. Submit LKPM Reports Every Quarter
A Laporan Kegiatan Penanaman Modal, otherwise known as a LKPM, is your quarterly investment activity report that communicates your business operations to BKPM (the Ministry of Investment and Downstream Activity). You need to submit one every quarter, regardless of whether your company is active, inactive or in the development phase.
All PT PMAs in Indonesia must regularly submit LKPM reports to BKPM, even with no activity, to stay compliant with investment regulations.
The deadlines are as follows:
Quarter 1: January 1-10 (covering Oct-Dec activities)
Quarter 2: April 1-10 (covering Jan-Mar activities)
Quarter 3: July 1-10 (covering Apr-Jun activities)
Quarter 4: October 1-10 (covering Jul-Sep activities)
The LKPM report must include detailed information about your workforce, business operations, and investment progress. It should also contain a summary of your business expenses from the past three months.
The consequences for not submitting your LKPM on time become more serious the longer the delay:
For the first three missed reporting periods, warning letters will be sent to your registered business email address
Continued non-compliance: business licenses frozen
Persistent violations: company operations suspended
4. Respond to Warning Letters Immediately
Although you are supposed to receive an official notice before any enforcement action is taken, there have been precedents where actions were carried out without any prior notice being given. If you get one though, make sure to respond to it immediately, and if in doubt, contact your PT PMA consultant.
Some common issues could be:
Failure to register PT PMA with BPJS social security
Engaging in activities beyond the scope of your visa
Office address verification issues
Not being able to meet the minimum investment requirements
Operating outside your registered business activities
Tax audit
The consequences of not responding to warnings could include business license freezing, KITAS deactivation and/or being deported.
5. Update Your Business Address Registration
Something that can cause a compliance issue is not updating your business address. Many businesses open doors with a virtual address. If you later establish a physical address, but don’t update your paperwork to reflect the change, it can result in issues. If the responsible authorities conduct inspections and find no business presence at registered addresses, it can result in your company being blacklisted.
If you've moved from virtual to physical location, make sure you update:
PT PMA paperwork
OSS system records
All relevant permits and licenses
Notify your bank and other relevant institutions of the address change
6. Work Toward Meeting Capital Investment Requirements
The IDR 10 billion minimum investment requirement has become an area of focus for audits. Although only a relatively small percentage of businesses face audits, the consequences for non-compliance can be severe, which means it’s important that you work towards meeting the capital investment requirements.
In case of the tax audit for your PT PMA, the tax officers will likely declare that your PT PMA is subject to pay interest tax penalty. This is because the tax office treats unpaid share capital as a loan relationship between the company and its shareholders. For example, if you've invested IDR 3 billion of required IDR 10 billion, your outstanding IDR 7 billion liability is subject to interest tax. While it can be reasoned that the uninjected capital represents a pending capital obligation rather than a loan, this interpretation may vary on a case-by-case basis, and the final decision rests with the tax authorities.
All PT PMAs in Indonesia are required to adjust their capital investment to a minimum of IDR 10 billion, as per BKPM Regulation No. 4/2021. Failure to comply may lead to serious issues.
Companies that get audited could face hefty financial penalties if capital requirements aren't met. Whilst the tax office won't commonly seek to close your business, it may impose tax obligations on unpaid capital commitments. If you don’t plan to meet the financial requirements, consider alternative legal structures and visa sponsorship options that better align with your actual activities in Indonesia.
7. Keep Accurate Financial Records and Pay Your Taxes
From the moment your company makes its first transaction, you need to start documenting your finances. All PT PMAs need to submit both monthly and annual tax reports as below:
Monthly tax obligations include:
VAT (PPN) reporting for businesses with an annual revenue over IDR 4.8 billion
PPh 21: Employee income tax withholding
PPh 23: Withholding tax on services (2%), Interest Loan/Royalties (15%)
PPh Final: Lease/dividends (10%)
Important annual deadlines:
Corporate Tax Return: Due April 30th
Personal Tax Returns for Directors: Due March 31st (includes global asset reporting)
New PT PMAs may be eligible for the PP55 tax incentive - a 0.5% income tax rate for your first three years, provided that your annual revenue stays below IDR 4.8 billion.
For hospitality businesses, additional requirements include PB1 (local hospitality tax) and WHT 25 (corporate tax rate of 11% or 22% for higher revenue brackets).
We recommend working with an accountant who is experienced in Indonesian tax regulations to make sure you understand the requirements and avoid any potential penalties or missed deadlines.
Understand Your Position as a Director:
If you're listed as the director of your PT PMA, it's important to understand that Indonesian law doesn’t allow a director to work hands-on in the business or act as the public face of operations.
As a director, you can:
Set and oversee the company’s strategic direction and ensure regulatory compliance
Make sure that taxes and salaries are paid
Manage regulatory requirements
Withdraw director’s salary and/or dividends (subject to tax)
You cannot legally carry out:
Daily operational tasks within the business
Client-facing activities
Personally market your business
As a Director:
You may apply for a 2-year Investor KITAS if your personal shareholding in the Indonesian company is at least Rp. 10,000,000,000 (Rp. 10 billion).
If your personal shareholding is below Rp. 10 billion, you can still apply for a Director’s Working KITAS - however, the scope of your permitted activities remains the same: supervision and oversight only, not operational or client-facing work.
Please make sure that you understand your role as director to avoid any issues with the authorities.
Need Help?
It’s clear that the mood has shifted to more active enforcement, with potentially serious consequences for non-compliance. As such, companies can no longer assume that minor violations won’t be taken seriously.
Although some of the measures may seem strict, the idea is that foreign investors in Indonesia should do their best to operate transparently whilst contributing to the local economy through good employment practices, fulfillment of capital commitments, compliance with reporting obligations, and efficient business operations.
Compliance is achievable if you plan properly, and have professionals to guide you.
Steps you can take today:
Check your business email and set up daily monitoring
Verify your BPJS registration status and complete if incomplete
Review your investment timeline for meeting capital requirements
Confirm your address registration matches your business location
Consider a compliance review with your PT PMA consultant
Most importantly - don't wait for a notice to act.
If you need our assistance or advice regarding meeting these requirements, contact our team at Bali Solve. We understand the current regulatory landscape in depth and can help ensure your business maintains compliance, as well as give you the peace of mind that you’re taking care of things as best as you can.
Simply message us via WhatsApp or visit our office in Pererenan to schedule an appointment today.
Written By Bali Solve Team
9th July 2025
