Inactive Corporations and Beneficial Owner Reports
Circular AHU-AH.01-36/2026 gives inactive status to limited liability companies, foundations and associations that have not updated data for 5 years, and restates beneficial owner reporting.
Key points
- An update means at least reappointing or changing the management.
- A corporation that has already reported its beneficial owner must still complete the questionnaire when data changes.
The Director General of General Legal Administration issued Circular AHU-AH.01-36 of 2026 on 11 February 2026. It covers limited liability companies, foundations and associations.
The circular gives its background. Many corporations have not updated their data since establishment, and beneficial owner reports, required since 2019, have not risen significantly.
How inactive status works
A corporation that has not notified an update or change in the past 5 years goes on a temporary list. The list is published in newspapers, on the agency’s website and on social media.
If data is still not updated 6 months after that notice, the corporation goes on a permanent list and is marked “Inactive” in the system and on its profile. Press reports say the temporary list was announced on 4 May 2026 and the permanent list on 4 November 2026.
An update means at least reappointing or changing the management. The circular warns that managers whose term has ended no longer have authority to act for the corporation, and their acts may be treated as invalid and bring personal liability.
The “Inactive” mark is removed after the update enters the system.
Beneficial owners
Part B restates the duty to report beneficial owners through bo.ahu.go.id. When filing, the corporation must complete the questionnaire under Minister of Law Regulation 2 of 2025.
A corporation that has already reported must still complete it, when amending its articles or data, or when updating beneficial owner information.
A corporation that fails to report, or gives false information, may face a warning, blacklisting, or blocked access to the agency’s system.
A check for business groups
A group with many subsidiaries should list each entity with the end date of its management’s term and the date of its last data change. Deeds extending management that have not been notified to the system need attention.
Annual report filing through SABH depends on the same access, and is covered in Company Annual Report Filing Through SABH.
Frequently asked questions
Does inactive status mean the company is dissolved?
The circular describes it as a special mark in organising the database. The mark is removed after the administrative update is made.
Our company is blocked. Where do we start?
Part A point 8 asks for the block to be lifted first, by reporting the beneficial owner if that is the cause, or meeting the conditions of Minister of Law Regulation 21/2025, then updating the data.