Regulation Watch · Business Licensing · Indonesia
AHU Can Mark Companies Inactive After Five Years Without Updates
AHU Circular AHU-AH.01-36/2026 places corporations with no administrative update during the preceding five years on a provisional inactive list and makes the status permanent if the data is not updated within six months after notification.
- Published
- Circular issued on 11 February 2026; the official AHU inactive-corporation announcement was published on 19 May 2026. As a circular, it was not promulgated in the State Gazette.
- Effective
- 11 February 2026
- Updated
- 12 September 2026
Who is affected
Indonesian limited-liability companies, including PT PMA companies, foundations, associations, their shareholders, directors, commissioners, governing bodies, beneficial owners, notaries, lenders, investors, buyers, and counterparties relying on current AHU records.
Practical impact
A PT, foundation, or association that made no administrative update or change in the five years preceding 11 February 2026 can enter AHU's provisional inactive-corporation list. If it still does not update its data within six months after the public notification, AHU can place it on the permanent inactive list and display an inactive status in the AHU system and corporate profile. The circular creates an administrative AHU status rather than an automatic dissolution, but it can expose expired management appointments, obstruct corporate changes where access is blocked, and create serious due-diligence and transaction concerns.
Late discovery: Director General of General Legal Administration Circular AHU-AH.01-36/2026 was issued on 11 February 2026, and AHU published its inactive-corporation announcement on 19 May 2026. It remains immediately actionable because the six-month cure window linked to the public notification points to a working deadline of 19 November 2026 for corporations covered by that notice.
The trigger is administrative inactivity. A PT, foundation, or association with no update or change notified in the five years before the circular was signed can be placed on the provisional inactive list. If no update follows within six months after notification, AHU can move the corporation to the permanent list and display the inactive marker in its system and profile. A compliant update removes the marker and the entity from the permanent list.
This review is not satisfied merely because the business still trades, has an NIB, files tax returns, or uses its bank account. The relevant question is whether AHU data is current, including management appointments. The circular warns that management whose appointment period has ended may lack authority to act for the corporation, creating validity and personal-liability risk for later transactions.
The cure route also connects directly to beneficial-ownership compliance. Every corporation must report its actual beneficial owner and complete the required questionnaire. A corporation that is both inactive and blocked must first resolve the applicable beneficial-ownership failure and/or the separate AHU block-opening conditions, then file the corporate update. PT PMA companies should complete this check before a share transfer, investment round, director change, licence action, financing, property transaction, or major contract.
Required action
- Check the company's current AHU profile and the provisional inactive list using its exact registered name, then retain evidence of the result.
- Audit the last five years of AHU filings against the deed, shareholder register, registered address, articles, and the appointment periods of directors and commissioners.
- If a management term has expired or corporate data is stale, arrange the required valid corporate decision and notarial filing promptly instead of submitting a cosmetic change solely to reset the record.
- Confirm that the actual beneficial owners are correctly reported, complete the required beneficial-ownership questionnaire, and update supporting data before filing an AHU change.
- If AHU access is blocked, first cure the beneficial-ownership failure and/or satisfy the block-opening requirements under Permenkum 21/2025, then complete the corporate-data update.
- For an acquisition, investment, financing, lease, licence, or major contract, make a current AHU profile and the authority of the signing management part of the closing checks.