UBO filing in Indonesia refers to the legal obligation of businesses to declare their Ultimate Beneficial Owners (UBOs)—the natural persons who ultimately own, control, or benefit from a company. This requirement is part of Indonesia’s broader commitment to prevent money laundering, corruption, terrorism financing, and tax evasion. It also aligns the country with international transparency standards laid out by the Financial Action Task Force (FATF).
UBO disclosure has been legally required in Indonesia since the enactment of Presidential Regulation No. 13 of 2018 on the Application of the Principle of Recognizing the Beneficial Owner of Corporations, which established a central UBO registry. In 2025, the introduction of Minister of Law and Human Rights Regulation No. 2 of 2025 enhanced these obligations further by setting stricter verification processes, documentation standards, and annual update duties.
UBO filing in Indonesia now forms a core part of the country’s Anti-Money Laundering (AML) framework and Know Your Customer (KYC) obligations for both corporations and reporting institutions, including banks, notaries, and lawyers.
By mandating transparency about corporate ownership, Indonesia aims to prevent anonymous shell companies from engaging in illicit activities such as corruption, illicit enrichment, or financing terrorist networks.
What Is an Ultimate Beneficial Owner (UBO)?
An Ultimate Beneficial Owner is a natural person who ultimately owns and/or controls a legal entity, either directly or indirectly.
In Indonesia, a UBO is defined under Article 1 of Presidential Regulation No. 13/2018 as a person who:
- Owns 25% or more shares or capital in a company;
- Has the right to receive 25% or more of profits;
- Has the authority to appoint or dismiss directors or senior management;
- Has significant influence or control over the decision-making process;
- Exercises control through contractual or informal arrangements.
The definition is intentionally broad to capture both direct and indirect control structures. It reflects FATF’s international standards, ensuring that even opaque ownership schemes involving nominees or layered entities are reportable.
Practical Example:
A company registered in Jakarta is owned 60% by another Singaporean holding company, which is in turn 100% owned by an individual. That individual is considered the UBO of the Indonesian entity, even though they do not appear on the company’s local registry.
UBO Filing Requirements in Indonesia
Indonesia has implemented a two-tier regulatory framework to enforce beneficial ownership disclosure:
1. Presidential Regulation No. 13 of 2018
This regulation mandates corporations to:
- Identify their UBOs;
- Report the information to the Ministry of Law and Human Rights (MOLHR);
- Keep the information up to date and accessible.
2. Minister of Law and Human Rights Regulation No. 2 of 2025
This recent update introduces:
- Mandatory annual verification of UBO information;
- Legal obligation to provide supporting documents to validate beneficial ownership claims;
- Sanctions for companies that fail to report or update data;
- Strict deadlines for reporting any change in ownership or control.
Entities Required to File
The regulation applies to a wide range of legal structures in Indonesia:
- Limited Liability Companies (Perseroan Terbatas – PT)
- Foreign Investment Companies (PMA)
- Partnerships (Firma and CV)
- Cooperatives (Koperasi)
- Foundations (Yayasan)
- Associations (Perkumpulan)
- State-Owned Enterprises (BUMN)
There are no exemptions for size or sector. Whether your entity is engaged in trade, services, finance, or non-profit activity, you are subject to UBO filing duties.
Indonesia’s Beneficial Ownership (BO) Laws and Regulations
The legal foundation of UBO regulation in Indonesia consists of the following key instruments:
Presidential Regulation No. 13/2018
- Defines beneficial ownership;
- Establishes reporting requirements for legal entities.
- Provides the Ministry of Law and Human Rights (MOLHR) with the authority to collect and manage BO data.
Ministerial Regulation No. 2/2025
- Details the verification process.
- Mandates annual updates;
- Requires original documentation and record-keeping.
Law No. 8 of 2010 on the Prevention and Eradication of Money Laundering
- Frames the national AML regime;
- Outlines responsibilities of financial institutions and designated non-financial businesses and professions (DNFBPs);
- Connects BO disclosure to KYC obligations.
These laws and regulations work in tandem to create an enforceable and transparent reporting regime.
Who Must File and Maintain the UBO Register in Indonesia?
All companies incorporated in Indonesia are required to:
- Identify all individuals who qualify as UBOs under the 25% ownership or control threshold;
- Submit detailed UBO data via the Directorate General of Legal Administrative Affairs (AHU) platform;
- Maintain internal records to support the reported data;
- Review and update the UBO register annually or upon significant changes.
The UBO register in Indonesia is not open to the public. However, the following entities have access:
- Law enforcement and tax authorities;
- Financial supervisory agencies (e.g., OJK, PPATK);
- Financial institutions conducting KYC checks;
- Reporting professionals (e.g., notaries) under certain conditions.
Documents and Information Required for UBO Filing in Indonesia
For each beneficial owner, the following must be collected and submitted:
Personal Information:
- Full name (as in ID/passport);
- Date and place of birth;
- Gender and nationality;
- Residential address;
- Taxpayer Identification Number (NPWP), if applicable.
Ownership/Control Information:
- Shareholding percentage;
- Type of control (ownership, management influence, voting rights);
- Organizational chart (for indirect ownership);
- Legal basis of ownership (e.g., notarial deed).
Supporting Documents:
- Copy of a valid ID or passport;
- Share certificate or shareholder registry;
- Deed of establishment and amendments;
- Board of Directors appointment letter (if control is via management);
- Proof of address document.
All documents must be submitted through the AHU Online portal, and originals must be retained for audit or inspection.
UBO Filing Deadlines and Timeline in Indonesia
Initial Submission:
- UBO data must be filed at the time of incorporation.
- For existing entities, the deadline to comply with the new 2025 regulations is June 30, 2025.
Periodic Updates:
- Changes in ownership, shareholding, or management control must be reported within five business days.
- Annual verification is required, even if no changes occurred.
Companies are encouraged to set internal calendar reminders and implement compliance software or professional services to ensure timely updates.
Penalties for Non-Compliance with UBO Laws in Indonesia
Penalties for failure to comply include:
- Administrative sanctions from MOLHR (e.g., rejection of corporate filings);
- Inability to process corporate amendments (e.g., capital increases);
- Suspension or revocation of business licenses (by related ministries);
- Financial penalties imposed by sectoral regulators;
- Blocking of access to financial services and contracts.
Moreover, persistent non-compliance may raise red flags with international regulators, affecting investment and expansion opportunities.
How to File a UBO/BOI Report in Indonesia (Step-by-Step)
1. Identify the UBOs
Analyze your company’s structure and identify any individual who owns or controls at least 25% or who exercises de facto control over decision-making.
2. Collect and Verify Supporting Documents
Gather identity documents, ownership proof (e.g., shareholder registers), and any legal instruments that establish control.
3. Register on the AHU Online Portal
Go to https://ahu.go.id and log in to the Legal Entity Administration System. Upload the required information and attach supporting documents.
4. Submit the Declaration
Confirm the submission and retain the official UBO certificate as part of your corporate documentation.
5. Maintain and Monitor
Review your register at least once per year and update promptly after any change in ownership, control, or contact details.
Recent Updates on UBO Regulations in Indonesia
The 2025 Ministerial Regulation introduced major shifts:
- Annual declarations are now mandatory, even if no changes have occurred
- Documents must be uploaded digitally with every UBO submission
- AHU has enhanced digital verification protocols to identify inconsistencies
- Cross-checking mechanisms are being introduced with the Tax Authority and PPATK.
Indonesia’s Ministry of Law and Human Rights is also expected to collaborate with ASEAN countries to create interoperable UBO systems across the region.
UBO Compliance Challenges for Global Businesses
Multinational businesses operating in Indonesia face challenges such as:
- Reconciling different UBO definitions and thresholds across jurisdictions;
- Ensuring language translations for official submissions;
- Navigating Indonesia’s evolving digital systems for compliance;
- Managing subsidiary data in centralized registers;
- Integrating local compliance into global governance platforms.
How Commenda Helps with UBO and Beneficial Ownership Compliance
Commenda supports companies navigating complex, multi-jurisdictional compliance landscapes.
Our platform simplifies:
- UBO identification and tracking across entities;
- Documentation collection, verification, and storage;
- Alerts for filing deadlines and regulatory changes;
- Cross-border KYC and AML alignment;
- Real-time updates and exportable reports for audits.
Stay compliant across jurisdictions with Commenda’s UBO solutions, whether you’re expanding into Southeast Asia or managing 20 entities across five continents.
Conclusion
UBO reporting in Indonesia has matured from a procedural formality to a critical piece of legal and financial compliance. With tighter timelines, annual audits, and more vigorous enforcement under the 2025 Regulation, businesses can no longer treat UBO filing as an afterthought.
By understanding the legal landscape, organizing documentation correctly, and leveraging platforms like Commenda, companies can reduce risk, build transparency, and operate with confidence in Indonesia’s increasingly regulated corporate environment.
FAQs
1. What is the UBO filing process in Indonesia?
To comply, companies must identify all individuals who qualify as beneficial owners (holding 25% or more ownership or control), gather documentation, and submit this data through the AHU Online portal. The company must also verify and update this information annually or whenever there is a change in ownership or control.
2. Who qualifies as a UBO under Indonesian law?
A UBO is any individual who directly or indirectly owns 25% or more of a company’s shares, profits, or voting rights, or who exercises significant control over decision-making processes. If no individual meets the threshold, the person who controls day-to-day management may be designated as the UBO.
3. What documents are required for UBO declaration in Indonesia?
Companies must submit copies of ID or passports, shareholder registers, shareholding proof, notarial deeds, and other legal documents that support the ownership/control relationship. A tax identification number (NPWP) is also often required for Indonesian citizens.
4. What is the UBO filing deadline in Indonesia?
For newly established companies, UBO details must be submitted at incorporation. For existing companies, the updated deadline under Regulation No. 2 of 2025 is June 30, 2025. Any changes must be reported within 30 days of occurrence.
5. What happens if a company fails to disclose UBOs in Indonesia?
Non-compliance may result in administrative sanctions, rejection of company filings, and even suspension of the business license. It may also cause delays in banking services, legal disputes, or reputational damage.
6. Is the UBO register in Indonesia public?
No. The register is confidential and maintained by the Ministry of Law and Human Rights. Access is restricted to regulators, law enforcement agencies, and institutions with specific legal authority to view the data.
7. Do cooperatives, foundations, and associations need to file UBO details?
Yes. The law applies to all corporate entities registered in Indonesia, including cooperatives, non-profit foundations, and professional associations, as long as there is a structure in place for the exercise of control or benefit.
8. How can foreign companies comply with Indonesia’s UBO laws?
Foreign companies must follow the same procedures as local entities. It is advisable to work with local legal counsel or use a platform like Commenda to ensure proper UBO registration, documentation, and ongoing compliance monitoring.
