What Is SABH Verification? Company Changes in Indonesia
SABH verification explained: what the Ministry of Law checks before it records a change of directors, shareholders or articles, and the 30-day limit.
References (5)
- Permenkum No. 49 Tahun 2025 on establishing, amending and dissolving a PT — signed 11 December 2025, in force 17 December 2025, revoking Permenkumham No. 21 Tahun 2021. Article 1 definitions; Article 8 approval and notification changes; Article 9 decisions and the 30-day limits; Article 10 filing and uploads; Article 12 documents kept; Articles 13–15 examination, return and decision; Articles 17–18 access block; Article 30 filing when SABH is down
- UU No. 40 Tahun 2007 (the Company Law) — Articles 21 and 23 changes to the articles and when they take effect; Articles 50, 56 and 57 share transfers; Articles 94 and 111 directors and commissioners
- Ditjen AHU announcements: 22 October 2025 (substantive verification from 27 October 2025); December 2025 (correcting shareholders', directors' and commissioners' email and telephone details in SABH); 11 February 2026 (Circular AHU-AH.01-36 of 2026, the provisional list of inactive companies)
- Permenkum No. 2 Tahun 2025 and Perpres No. 13 Tahun 2018 — beneficial-owner documents and reporting
- Permenkum No. 32 Tahun 2025 on correcting company data in SABH — as announced by Ditjen AHU in November 2025; the regulation text itself was not read
SABH verification is the check the Ministry of Law now makes before it records a change to a company. SABH (Sistem Administrasi Badan Hukum) is the Ministry’s online company service, run by its Directorate General of General Legal Administration (AHU). Since 17 December 2025, the Ministry examines every change to the articles or company data of a PT with shareholders — a PT being a Perseroan Terbatas, Indonesia’s limited liability company — before it issues a decision or receipt. It checks consistency. The check takes up to 14 working days, and the company’s own deadline for filing is 30 days.
The rules are in Permenkum No. 49 of 2025, and article numbers below refer to it unless the Company Law is named.
What changed
AHU announced on 22 October 2025 that it would verify three kinds of change from 27 October 2025: directors and commissioners, share transfers, and changes of a shareholder’s name. That was an announcement, not a regulation. Permenkum 49/2025 then extended the examination to every change of a PT with shareholders, from 17 December 2025. At a briefing on 21 November 2025, reported by the Ministry’s regional offices, AHU gave three reasons:
- share transfers made without the other shareholders knowing
- data entered by notaries that did not match the deed
- copies of deeds with formal defects
| Until October 2025 | Since 17 December 2025 | |
|---|---|---|
| How a change is filed | The notary's electronic statement that the documents are complete | The form, plus the deed and supporting documents uploaded (Article 10(3)–(4)) |
| Is it examined? | No | Yes, before any decision or receipt (Article 13(1)) |
| Who answers for the filing | The notary's statement | The notary, who takes full responsibility for the form and uploads (Article 10(5)) |
| Beneficial-owner documents | Not among the uploads | Uploaded with it: the directors' power of attorney, statement and the owner's consent (Article 10(4)(j)) |
What the Ministry checks
The examination tests whether four things agree: the filing form, the deed of change, the minutes of the shareholders’ meeting or their written resolution, and the last record held in SABH (Article 13(2)). The notary uploads only the documents the change needs, from the list in Article 10(4):
- the minutes of the shareholders’ meeting, or their written resolution
- the deed of transfer of shares
- a recommendation from the ministry or agency that licenses the business
- proof of announcement in a newspaper
- the company’s tax number (NPWP)
- proof that capital has been paid in
- a letter confirming the company’s full address
- the decision recording a shareholder’s change of name
- the annual financial statements
- the beneficial-owner documents
How a change is registered
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The shareholders decide
At a meeting or by a binding written resolution (Article 9(1)). A change of a shareholder's name or of the company's address does not need one.
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A notarial deed, in Indonesian
Article 9(2)–(4); a board change follows Article 9(5) instead — see below.
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The notary files through SABH
The notary files the form and the uploads, with an electronic statement that they are complete (Article 10).
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AHU checks that everything agrees
AHU has up to 14 working days to finish the check (Article 13(3)).
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If it does not agree, it goes back to the notary
The notary has seven calendar days to put it right. If not, AHU rejects the filing, and the notary can file it again (Article 14).
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Decision letter or notification receipt
AHU sends it electronically to the notary, who prints it (Article 15).
A late filing of a change to the articles or company data cannot be made
A change to the articles, or to company data other than the board, that is not filed within 30 days of the deed cannot be filed (Company Law, Article 21(9); Permenkum 49/2025, Article 9(7)). The same 30-day rule applies to putting a decision into a deed where the meeting was not minuted by a notary (Article 9(3)–(4)).
When the 30 days start
Directors and commissioners
The board notifies the Ministry within 30 days (Article 9(5); Company Law, Articles 94(7) and 111(7), which count from the shareholders’ resolution). The appointment itself takes effect on the terms the shareholders set, not on registration (Company Law, Article 94(5)–(6)), but a director who is not yet recorded cannot file anything else with the Ministry (Company Law, Article 94(8)).
A reappointment at the end of a term is a change to be notified in its own right (Article 8(5)(b)) — and five years without one now has consequences, below.
Share transfers
The shares pass by deed; the directors record the transfer in the share register and notify the Ministry within 30 days of recording it (Company Law, Articles 56(1)–(3)). Permenkum 49/2025 counts its 30 days from the deed (Article 9(6)), so the safe course is to work from whichever date is earlier. The articles of association may give existing shareholders a right to buy first (Company Law, Article 57).
Until a transfer has been notified, the Ministry refuses later filings that depend on the shareholder structure (Company Law, Article 56(4)). A change of shareholder name needs no meeting; the decision recording the new name is uploaded instead (Article 10(4)(h)).
Changes to the articles
Seven kinds of change need the Minister’s approval: the company’s name, its registered city, its purposes and business activities, its duration, its authorised capital, a reduction of issued and paid-up capital, and a change between closed and public status (Article 8(3)). Every other change to the articles is notified (Article 8(4)).
The deed follows the meeting within 30 days, and the filing follows the deed within 30 days (Company Law, Article 21(5)–(9)). A change takes effect only when the approval or the receipt is issued (Company Law, Article 23) — so the examination period delays the change itself, and a transaction that depends on it has to allow for it.
What stops a change being registered
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No receipt for the company's annual tax return.
How to avoid itThe notary must hold it to register a change to company data (Article 12(1)(i)). A company whose tax number is less than a year old is exempt (Article 12(2)).
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An earlier change was never notified.
How to avoid itThe Ministry refuses filings from directors not on its register and filings that depend on an unrecorded share transfer (Company Law, Articles 56(4) and 94(8)). File the earlier change first.
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The contact details held in SABH are out of date.
How to avoid itIf the email address or telephone number held in SABH for a shareholder, director or commissioner is wrong, AHU requires the company, through its notary, to correct it before a board, share or shareholder-name change is filed (AHU announcements, December 2025).
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The company's SABH access is blocked.
How to avoid itAn unfiled approval of the annual report (Articles 17 and 18) or a beneficial-owner sanction can block it. Clear the block before planning a change.
When no change is the problem
The Ministry now notices companies that change nothing. Under Circular AHU-AH.01-36 of 2026, dated 11 February 2026, a PT that has notified no update since 12 February 2021 — not even a reappointment of its board — goes on the Ministry’s provisional list of inactive companies. It held over 700,000 companies in September 2026.
A company that sits unused still has duties, set out in what a dormant company still owes.
Questions people ask
Does SABH verification apply to a PT PMA and a local PT?
Do shareholders have to confirm a change by email within seven days?
Can a typing error in SABH be corrected?
What happens if SABH is down?
What this means for you
Treat the 30 days as the deadline to diary: the examination can be waited out, but a late filing of a change to the articles, or to company data other than the board, cannot be made. Before any change:
- have the receipt for the annual tax return to hand
- make sure every earlier change was notified
- check the contact details SABH holds for every shareholder, director and commissioner
And diary each board term’s end date, because a PT that notifies nothing for five years goes on a public list.
The recurring filings a company owes are in the compliance checklist for businesses, and the dates on the Indonesia compliance calendar. Where a company would rather not run its own filings, they are company document changes work.