Ministry of Law of the Republic of Indonesia through the Directorate General of General Legal Administration (AHU) has established a policy concerning the administrative designation of non-active corporations as stipulated in Circular Letter of the Director General of General Legal Administration Number AHU-AH.01-36 of 2026 dated 11 February 2026. This policy forms part of the Government’s efforts to ensure orderly legal administration and to enhance the accuracy and reliability of corporate data registered within the legal entity administration system in Indonesia.
In this regard, it is stipulated that any corporation that fails to fulfill its obligation to report updates or amendments to its administrative data, including but not limited to changes in the composition of management, within a period of at least 5 (five) years since the enactment of the Circular Letter or since 12 February 2021, shall be included in the Provisional List of Non-Active Corporations. The designation of non-active status is administrative in nature and does not automatically result in the dissolution of the legal entity; however, it reflects that the relevant corporation has failed to comply with its reporting obligations as required under the prevailing laws and regulations.
Furthermore, corporations that have been included in the Provisional List of Non-Active Corporations are still afforded the opportunity to restore their status by fulfilling their administrative obligations through the General Legal Administration system, including updating corporate data and submitting information regarding the beneficial owner. Accordingly, this policy is not merely repressive in nature but also provides a corrective mechanism for corporations to regain compliance with their legal obligations.
Therefore, all corporations are expected to continuously ensure compliance with applicable administrative obligations in order to avoid being designated as non-active, considering that such status may give rise to legal and administrative implications in the conduct of business activities as well as in legal relations with third parties. This policy further underscores the Government’s commitment to strengthening transparency, accountability, and the integrity of the legal entity administration system in Indonesia.
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Author:
Dewi Susanti