Ministry of Trade Regulations No.25 Year 2020

On March 16, 2020 the Ministry of Trade issued new regulations relating to submissions of companies’ annual financial statements (LKTP), replacing the previous regulation about the same subject (Kepmenperindag No. 121 Year 2002).

The new regulation emphasizes that once submitted, the financial information contained in the LKTP becomes public information. Also, submissions of private companies’ LKTP now can only be done by the companies themselves (previous regulation allows the public accounting firms to submit the LKTP on behalf of the company).

Please note that all foreign companies must submit their LKTP regardless of their total assets.

The summary of important points of this regulation is as follows:
1. Companies fulfilling one of the following criteria must submit its LKTP to the Ministry of Trade:

A. Limited liability companies:

    • Being a publicly-listed company;
    • Having the business of gathering funds from the public;
    • Issues debt instruments;
    • Having total assets of at least Rp25.000.000.000;
    • Being a debtor, whose annual financial statements are obliged by the Bank to be audited.

B. Foreign companies having domiciled and undertaking business activities in Indonesia and authorized to enter into agreements,

C. State-owned enterprises (PERSERO), public companies (PERUM) and municipal enterprises (PD).

2. LKTP consists of balance sheet and statements of income, changes in equity and cash flows, and notes to financial  statements. LKTP should be prepared based on the accounting standards issued by the applicable accounting association and must be audited by registered public accountants or state auditors.

3. LKPT must be submitted by the company through the Ministry of Trade’s SIPT portal at the latest 6 months after the end of the financial year. If the portal is not available, LKTP is submitted by way of email to the Direktorat Bina Usaha dan Pelaku Distribusi, Ministry of Trade.

4. The Ministry of Trade, through the Directorate for the Directorate General will issue a receipt (called STP-LKTP) within 7 days;

5. Once submitted, the financial information contained in the LKTP becomes public information, and can be accessible by writing to the Directorate General of the Ministry of Trade.

6. STP-LKTP can be attached as a supporting document for the Public Accounting Firm in submitting a report on business activities to the minister who carries out government affairs in the financial sector.

7. Incompliance to this regulation is subject to administrative sanctions in the form of written warnings, suspension or revocation of operational license.