PT PMA Compliance Checklist: The Tax, Accounting and LKPM Obligations Every Foreign Director Must Know

Establishing a foreign-owned limited liability company (Perseroan Terbatas Penanaman Modal Asing, or PT PMA) in Indonesia is only the first step. The moment the company receives its Deed of Establishment, a separate and ongoing set of obligations begins — tax administration, bookkeeping, monthly and annual filings, labor compliance, and investment reporting — most of which apply whether or not the company has started generating revenue. This checklist walks through the five compliance pillars every foreign director must have in place after incorporation.

1. Activate Your Coretax DJP Accounts Before You Can Invoice or File

Since January 2025, all tax administration in Indonesia runs through Coretax, the unified digital platform of the Directorate General of Taxes (Direktorat Jenderal Pajak / DJP). A newly incorporated PT PMA cannot issue tax invoices or fulfil any filing obligation until a sequence of Coretax activations has been completed.

Director’s Personal Account (Primary PIC)

The Director named as the primary responsible party in the Deed of Establishment must activate a personal Coretax portal account first. A foreign Director who already holds an Indonesian personal NPWP (Individual Tax ID) can complete this online. A Director without a local NPWP must go through a separate tax subject registration procedure before the personal account can be activated.

Corporate Taxpayer Account

Once the Director’s personal account is active, the Director can apply for and activate the company’s Corporate Taxpayer Account using the PT PMA’s own NPWP. Every subsequent tax filing and electronic transaction runs through this corporate account.

Delegating Access to a PIC

Coretax allows the Director to appoint a Person in Charge (PIC) — commonly an in-house accountant, finance officer, or external tax consultant — to manage day-to-day tax administration. A PIC can generate payment codes (Kode Billing), issue tax invoices (Faktur Pajak), and prepare draft returns using their own login credentials, but final approval and signature authority remain with the Director.

Electronic Certificate (Sertel) and DJP Authorization Code

An Electronic Certificate (Sertifikat Elektronik / Sertel) and a DJP Authorization Code are mandatory before the company can sign electronic tax returns or issue VAT invoices.

Source: DJP — pajak.go.id; Coretax — coretaxdjp.pajak.go.id

2. Set Up Bookkeeping and Financial Reporting Under PSAK

All PT PMAs must keep accounting records in line with Indonesian Financial Accounting Standards (Standar Akuntansi Keuangan / PSAK).

Bookkeeping Currency and Language

The default rule requires books to be kept in Indonesian Rupiah (IDR) and written in the Indonesian language. A PT PMA that wants to keep its books in US Dollars and English must first obtain formal written approval from the Ministry of Finance / local tax office — this is not automatic, so it should be applied for early, ideally before the first bookkeeping period closes.

Annual Financial Statements

Every PT PMA must prepare a full set of annual financial statements: an income statement, a balance sheet, and a cash flow statement.

Mandatory Financial Audit

A PT PMA must have its financial statements audited by an independent Certified Public Accountant (CPA) firm once it meets specific thresholds — most commonly, total assets or annual turnover reaching IDR 50 billion or more.

Source: Pasal 68, UU No. 40 Tahun 2007 tentang Perseroan Terbatas (UU PT)

3. Stay on Top of Monthly and Annual Tax Filings

Indonesia operates a self-assessment tax system: the company calculates, withholds, pays, and reports its own tax obligations — DJP does not send a bill. Non-compliance results in administrative fines, penalty interest, or a tax audit.

Monthly Obligations (SPT Masa)

Companies with annual gross revenue exceeding IDR 4.8 billion must register as a PKP and begin collecting VAT on their sales.

Source: UU No. 36 Tahun 2008 tentang PPh sebagaimana diubah UU No. 7 Tahun 2021 (UU HPP); PMK No. 81 Tahun 2024; PMK No. 131 Tahun 2024; PMK No. 197/PMK.03/2013 jo. PMK No. 164/2023

Annual Obligation: Corporate Income Tax Return

The Corporate Income Tax Return (SPT Tahunan PPh Badan) is due by the end of the fourth month after the fiscal year closes — typically 30 April for companies on a calendar-year fiscal period.

Source: UU No. 28 Tahun 2007 tentang Ketentuan Umum dan Tata Cara Perpajakan (UU KUP)

4. Meet Labor and HR Compliance Requirements

Indonesian labor law imposes strict rules on hiring foreign nationals, mandatory local training, and social security — all of which apply from the moment a PT PMA employs its first person. Before hiring any foreign national, the company must first obtain an approved Foreign Manpower Utilization Plan (Rencana Penggunaan Tenaga Kerja Asing / RPTKA) from the Ministry of Manpower, secure a Work KITAS for each foreign employee, and pay the Compensation Fund for the Use of Foreign Workers (Dana Kompensasi Penggunaan TKA / DKPTKA) — a fee of USD 100 per foreign worker per month, treated as non-tax state revenue. Foreign nationals are also barred from holding HR and Personnel Management positions, and any company employing them must appoint an Indonesian counterpart (Pendamping TKA) to receive skills and technology transfer.

Source: PP No. 34 Tahun 2021 tentang Penggunaan Tenaga Kerja Asing; Permenaker No. 8 Tahun 2021

Beyond the rules on hiring foreigners, every PT PMA carries broader HR obligations toward its whole workforce. Two BPJS social security programs are mandatory: BPJS Ketenagakerjaan, which covers work accident, death, old age, and pension benefits, and BPJS Kesehatan, which covers healthcare and extends to foreign workers once they have been employed in Indonesia for at least six months. Once the company employs 10 or more staff, it must also have a written Company Regulation (Peraturan Perusahaan) ratified by the Ministry of Manpower, and it must file the Mandatory Manpower Report (Wajib Lapor Ketenagakerjaan di Perusahaan / WLKP) online through the Ministry’s portal every year.

Source: Pasal 108, UU No. 13 Tahun 2003 tentang Ketenagakerjaan

5. File Your Quarterly Investment Activity Report (LKPM)

One of the most frequently missed obligations for foreign entrepreneurs is the Investment Activity Report (Laporan Kegiatan Penanaman Modal / LKPM), filed with the Ministry of Investment (BKPM) through the OSS (Online Single Submission) system.

Medium and large-scale PT PMAs must submit LKPM every three months — even if the company has not yet started commercial operations or is still in the construction or pre-operational phase.

Source: Pasal 15 huruf c, UU No. 25 Tahun 2007 tentang Penanaman Modal; Pasal 32, Peraturan BKPM No. 5 Tahun 2021

Failing to report can lead to a written warning, temporary suspension of business activity, or revocation of the company’s Business Identification Number (NIB) — effectively halting the company administratively.

Frequently Asked Questions

Does a PT PMA need to file LKPM even if it hasn’t started operating yet?

Yes. LKPM is a quarterly obligation for medium and large-scale investors from the moment the company is registered, regardless of whether it has started construction, is still pre-operational, or has begun commercial activity. (Source: Peraturan BKPM No. 5 Tahun 2021)

What happens if a PT PMA misses the SPT Tahunan Badan deadline?

Late filing triggers an administrative fine and can flag the company for closer review under DJP’s compliance risk system, since Indonesia’s self-assessment regime relies on active enforcement of deadlines rather than reminders. (Source: UU No. 28 Tahun 2007 tentang KUP)

Does every PT PMA need an audited financial statement?

No. An independent audit becomes mandatory only once a PT PMA’s assets or annual turnover reach IDR 50 billion or more, or if it falls under one of the other categories set out in the Company Law, such as a public company or a deposit-taking business. Smaller PT PMAs can prepare unaudited financial statements, though many still choose a review for investor or banking purposes. (Source: Pasal 68, UU No. 40 Tahun 2007 tentang Perseroan Terbatas)

Can GMS handle both the tax side and the labor/RPTKA side of compliance?

Yes. GMS Agency’s Tax & Accounting and Legal Services teams work together to cover Coretax administration, monthly and annual tax filings, LKPM reporting, and the RPTKA/KITAS process for foreign hires — so a foreign director does not need to coordinate separate vendors for each obligation.

Sources: UU No. 25/2007 tentang Penanaman Modal · Peraturan BKPM No. 5/2021 · UU No. 40/2007 tentang Perseroan Terbatas · UU No. 36/2008 tentang PPh sebagaimana diubah UU No. 7/2021 (UU HPP) · UU No. 8/1983 tentang PPN sebagaimana diubah UU No. 7/2021 · PMK No. 81/2024 · PMK No. 131/2024 · PMK No. 197/PMK.03/2013 jo. PMK No. 164/2023 · UU No. 28/2007 tentang KUP · PP No. 34/2021 tentang Penggunaan Tenaga Kerja Asing · Permenaker No. 8/2021 · UU No. 13/2003 tentang Ketenagakerjaan · DJP — pajak.go.id · Coretax — coretaxdjp.pajak.go.id. This guide reflects Indonesian tax, investment, and labor regulations as of September 2026. Always verify current requirements at pajak.go.id, oss.go.id, and the Ministry of Manpower portal.