Statutory Audit Requirements in Indonesia: Who Must Be Audited
Statutory audit requirements in Indonesia: the six grounds in Article 68 of the Company Law, the IDR 50 billion threshold, and when the audit has to be finished.
- UU No. 40 Tahun 2007 (the Company Law) — in force 16 August 2007. Article 68(1), the six grounds and the IDR 50 billion figure; Article 68(2), the effect on the annual meeting; Article 68(3), how the report reaches the meeting; Article 68(4)–(5), the newspaper announcement; Article 68(6), the power to lower the figure by government regulation; Article 66(1), six months from year end; the elucidation of Article 67(1), the annual report containing the audited statements. Article 68 has not been amended
- UU No. 5 Tahun 2011 on Public Accountants — in force 3 May 2011. Article 1, what a public accountant and a KAP are; Article 3(1)(a) and (2), audit as an assurance service only a public accountant may give; Article 28, independence and conflicts of interest
- UU No. 6 Tahun 1983 on tax administration (KUP), as amended by UU No. 28 Tahun 2007 — in force 1 January 2008. Article 4(4) and 4(4b), the financial statements filed with the annual return, and the audited version where one exists
- PMK No. 81 Tahun 2024 — in force 31 December 2024. Article 165(3)–(4), the statements attached to the annual return; Article 169(2), four months for a corporate return; Articles 174(1) and 175(1)(e), the two-month extension and the public accountant's letter
- Peraturan Menteri Investasi dan Hilirisasi/Kepala BKPM No. 5 Tahun 2025 — in force 2 October 2025. Article 285(3), what an LKPM contains
- Permendag No. 26 Tahun 2025 — in force 30 June 2025. Article 1(c), revoking Permendag No. 25 Tahun 2020 on annual company financial statements
- Permenkum No. 49 Tahun 2025 — in force 17 December 2025. Article 16(2)–(3), the notarial deed and the 30-day filing of the annual report approval
The statutory audit requirements in Indonesia rest on a single article of the Company Law, and the test is short. A PT — a Perseroan Terbatas, Indonesia’s limited liability company — must have its financial statements audited by a public accountant once its assets or turnover reach IDR 50 billion, and in a handful of other cases that concern banks, insurers and funds, companies that have borrowed from the public, and listed or state-owned companies (Company Law, UU No. 40 of 2007, Article 68(1)). Below that, and outside those cases, an audit is a choice rather than a duty. Being foreign-owned is not itself a ground.
When a statutory audit in Indonesia is required
The directors must hand the financial statements to a public accountant for audit where the company (Article 68(1)):
- collects or manages money from the public — a bank, an insurer or an investment fund
- issues debt to the public, such as bonds
- is a listed company
- is a persero, a state-owned company
- has assets and/or turnover of at least IDR 50,000,000,000
- is required to be audited by some other regulation
Any one ground is enough. For an ordinary private company, foreign-owned or local, the first four do not apply and only the fifth is in question. That is the whole test, and it is the same test whoever owns the shares.
Read the fifth ground carefully
The Law says aset dan/atau jumlah peredaran usaha — assets and/or turnover. Either one on its own is enough, so a company holding IDR 10 billion of assets and turning over IDR 60 billion in the year is caught on turnover alone. The Law does not go on to define how the two are measured, so a company near the line should settle the reading before the year closes rather than argue it afterwards.
What does not require an audit
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A foreign-owned company must be audited because it is foreign-owned.
What the law saysNothing in the investment rules requires it. The current regulation, Permeninves/BKPM 5/2025, asks for no audit of an ordinary PT PMA — a foreign-owned limited company — and the quarterly investment report (LKPM) covers investment realisation, employment, production, licence conditions and obstacles, not financial statements (Article 285(3)).
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Audited accounts have to be filed with the Ministry of Trade.
What the law saysThat separate filing was revoked on 30 June 2025 (Permendag 26/2025, Article 1(c)), and nothing was put in its place. One filing fewer.
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The tax office requires an audit.
What the law saysIt does not. The annual return carries financial statements either way (KUP, Article 4(4)). Where the statements happen to be audited, it is the audited set that goes with the return (KUP, Article 4(4b); PMK 81/2024, Article 165(4)).
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The audit will not be finished by the tax deadline.
What the law saysThe return can be extended by up to two months, with a statement from the public accountant that the audit is not yet complete (PMK 81/2024, Articles 174(1) and 175(1)(e)). The extension notice goes in before the original deadline, so it belongs in the plan.
So a PT PMA is measured by the same Article 68 test as any other PT. What the quarterly report does need is covered in LKPM reporting mistakes to avoid.
Fitting the audit into the year
A required audit is not a year-end task standing on its own. It sits inside a timetable that two other deadlines already fix.
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The financial year closes
31 December for most companies. Everything below runs from it.
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The statements are audited
The annual report must carry the audited statements (elucidation of Article 67(1)).
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The corporate tax return is filed
30 April for a calendar year, with the audited statements attached (PMK 81/2024, Articles 169(2), 165(4)).
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The annual meeting approves the accounts
Without the required audit it cannot ratify them (Articles 66(1), 68(2), 69(1)).
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The approval is filed
The approval goes into a notarial deed, filed with the Ministry of Law (Permenkum 49/2025, Article 16).
The binding date for most companies is therefore the tax return in April, not the meeting in June. Planning backwards from it is the difference between an audit that fits the year and one that holds up everything after it — the annual general meeting, the deed, and the filing that follows. Both of the dates it has to fit are on the compliance calendar, alongside the monthly withholding tax filings.
Who may sign the report
An audit is an assurance service, and only a licensed public accountant — akuntan publik — may give one, practising through a licensed public accounting firm, a KAP (Kantor Akuntan Publik) (UU No. 5 of 2011, Articles 1, 3(1)(a) and 3(2)).
The same law requires the auditor to stay independent and free of conflicts of interest (Article 28). In practice the firm that keeps a company’s books does not audit them for the same year. That is worth knowing early, because it shapes how the year is arranged rather than what happens at the end of it.
On external audit engagements MAM performs the audit work, and the report is signed by a licensed KAP. Where we also do your bookkeeping, we explain the separation before you engage us for both.
When a company chooses to be audited
Plenty of companies below the threshold are audited anyway, because somebody with leverage has asked: a bank before extending or renewing facilities, an investor before committing, a parent company consolidating group accounts, or a buyer’s advisers reading the accounts years later in due diligence.
None of that is a legal requirement. It is worth being clear which of the two you are dealing with — a duty under Article 68, or a request from someone you want to say yes to — because the answer changes how much of the year it affects.
Questions people ask
Is the IDR 50 billion measured on assets or on turnover?
Is a statutory audit the same as a tax audit?
Do the accounts have to be announced in a newspaper?
What about banks, insurers, funds and listed companies?
Has the IDR 50 billion figure changed?
What this means for you
Take your last set of figures and look at two numbers: total assets, and turnover for the year. If either is at or near IDR 50 billion, an audit is compulsory and the timetable starts at your year end. If both are comfortably below it and nobody has asked for one, there is no statutory audit to arrange, and the annual meeting and the tax return proceed on unaudited accounts.
If you are somewhere in between — growing quickly, or with a lender starting to ask questions — that is the year to decide early, while the records can still be put in order month by month.