When Must a PT PMA Have Its Financial Statements Audited in Indonesia?

A PT PMA must have its financial statements audited by a public accountant when it meets a trigger under Article 68 of Indonesia’s Company Law, including assets or annual turnover of at least IDR 50 billion, certain public-interest activities, or another applicable legal requirement. Foreign ownership alone does not require an audit. A smaller, privately held PT PMA may prepare unaudited statements if no other law or binding requirement calls for an external audit.

What Indonesian Company Law Says About Mandatory Audits

A PT PMA is an Indonesian limited liability company with foreign investment. Its ownership structure matters for investment licensing, but the general audit test comes from the rules governing limited liability companies. Article 68 of Law No. 40 of 2007, as subsequently amended, identifies when directors must submit company financial statements to a public accountant for audit.

The IDR 50 Billion Asset or Turnover Test

Article 68(1)(e) uses two separate measures: assets and annual turnover (peredaran usaha). If either reaches at least IDR 50 billion, the statutory audit trigger is met. The law uses “and/or,” so a company does not have to exceed both measures. The threshold is inclusive: exactly IDR 50 billion qualifies under the wording of the provision.

Do not substitute paid-up capital, the investment amount declared in OSS, or a proposed investment plan for the two measures in Article 68. Review the relevant accounting records for the financial period and document how the company established its assets and turnover. Our guide to preparing FY2026 financial statements for a PT PMA covers the underlying year-end reconciliations.

Other Mandatory Audit Triggers

Under Article 68(1), a financial statement audit is also required when the company:

• Collects or manages public funds, subject to the nature of its activities and sector rules.
• Issues debt instruments to the public.
• Is a public company (Perseroan Terbuka).
• Is a state-owned persero.
• Falls under another law or regulation that requires an audit.

The law’s explanatory text names banks, insurance businesses, and mutual funds as examples of entities handling public funds. Sector-specific obligations require their own review. For instance, the Financial Services Authority’s Regulation No. 14/POJK.04/2022 governs periodic financial reporting by issuers and public companies. A privately held PT PMA should not assume that rule applies to it merely because it has a foreign shareholder.

How to Decide Whether Your PT PMA Needs an Audit

Start with the financial figures, then test the company’s activities and other obligations. This matrix separates common outcomes without treating company size as the only deciding factor.

A bank, shareholder agreement, investor, or group reporting policy may also demand independently audited statements. Those obligations may be commercially binding without changing the Article 68 test. Check the contract separately and record whether the audit is required by law, a regulator, or a private agreement.

Audited Statements, Unaudited Statements, and Tax Audits Are Different

An external financial statement audit is an examination by an authorized public accountant, leading to an independent auditor’s report on the financial statements. It is distinct from bookkeeping, monthly management reporting, and management’s responsibility for preparing accurate accounts.

The Directorate General of Taxes (DJP) explained in its April 2026 guidance on corporate financial reporting that companies subject to mandatory financial statement audits should attach the audit result to their annual corporate tax return. Companies without an audit obligation can use internal, unaudited statements for that return. They still need books and supporting records. Our guide to PT PMA tax obligations explains how those records support corporate tax and withholding filings.

A DJP tax audit is a separate examination by the tax authority. An independent auditor’s opinion does not replace DJP’s powers, and a tax examination notice does not automatically mean the company must commission an external financial statement audit under Article 68.

Does the Accounting Standard Determine the Audit Requirement?

No. The accounting framework determines how the company recognizes, measures, and presents transactions. The need for an independent audit is assessed under applicable company and sector rules, alongside any contractual obligations.

Article 66 of the Company Law requires financial statements in the annual report to follow financial accounting standards. The Indonesian Institute of Accountants (IAI) states that SAK Indonesia for Private Entities became effective on 1 January 2025 for qualifying private entities without public accountability that prepare general-purpose financial statements. Eligibility for that framework must be checked; it cannot be assumed solely from a PT PMA’s foreign ownership or small workforce.

Before engaging an auditor, have the finance team and the proposed public accountant agree on the reporting framework and the scope of the financial statements. A late change in accounting policies can affect comparative figures, disclosures, and the documents needed for review.

Prepare These Records Before Engaging a Public Accountant

If the audit is required, directors should organize the evidence while FY2026 transactions are still easy to trace. A practical handover file contains:

1. Corporate documents. The deed, articles of association, current director and commissioner details, shareholder register, and the financial year-end approved for the company.
2. Trial balance and statements. The year-end trial balance, comparative figures, draft financial statements, accounting policies, and notes.
3. Cash and bank evidence. Bank statements, reconciliations, loan confirmations, and an explanation of outstanding differences.
4. Revenue and cost support. Contracts, invoices, payment records, receivable and payable aging, and year-end cut-off schedules.
5. Assets and liabilities. The fixed asset register, depreciation schedules, inventory records where relevant, provisions, and supporting calculations for material estimates.
6. Group transactions. Related-party agreements, balances, confirmations, and intercompany reconciliations where a foreign parent or affiliate is involved.
7. Tax records and review trail. Filed returns, withholding and VAT records where applicable, reconciliations, proposed adjustments, and a log of management approvals.

The Ministry of Finance’s Financial Profession Development Center (PPPK) publishes information about registered public accountants and public accounting firms. Check that the person signing the audit report is authorized, and confirm the engagement’s scope and fee in writing. An external audit fee is not the same as the fee for routine bookkeeping.

Also Read: Director and Commissioner Requirements for PMA Companies in Indonesia

Coordinate the FY2026 Audit With the 2027 Filing Calendar

For a PT PMA whose financial year ends on 31 December 2026, the accounting close happens after that date. Directors then need enough time for audit fieldwork where required, the commissioners’ review, and shareholder consideration. The annual RUPS takes place within six months of year-end under Article 78 of the Company Law, making 30 June 2027 the ordinary meeting deadline for this example.

Article 68(3) requires the auditor’s report to reach the RUPS through the directors. Article 69 places approval of the annual report, including ratification of the financial statements, with shareholders. Our guide to annual RUPS requirements for PT PMA covers the meeting, approval, and notarial records without duplicating the audit assessment here.

Ministry of Law Regulation No. 49 of 2025 adds a separate handoff: the annual report approval must be recorded in a notarial deed, and directors must submit it through a notary via SABH within 30 calendar days after the deed is signed. That submission clock is tied to the deed, not to the date the auditor finishes fieldwork.

For a calendar-year corporate taxpayer, DJP’s general rule places the FY2026 corporate income tax return deadline on 30 April 2027. An audit still in progress does not automatically extend that deadline. DJP’s April 2026 guidance explains that eligible taxpayers can notify an extension of up to two months under applicable procedures and supply supporting documents, including a public accountant’s statement when an audit has not finished. Review the conditions before relying on an extension.

Our Coretax compliance checklist for foreign-owned companies addresses the tax handoff. For a broader view of reporting dates, consult our PT PMA compliance calendar. The audit, annual RUPS, Coretax return, and LKPM reporting remain different obligations, even when they draw from the same financial records.

What Happens If a Required Audit Is Skipped?

Article 68(2) of the Company Law states that when the audit requirement under Article 68(1) is not met, the financial statements are not ratified by the RUPS. This is a direct governance consequence. The provision should not be paraphrased as an automatic cancellation of the PT PMA’s NIB or business licence.

There is also a separate administrative risk if the company fails to complete the annual report submission required by Ministry of Law Regulation No. 49 of 2025. Articles 17 and 18 provide for a written warning and, if the obligation remains unmet for 30 calendar days after the relevant SABH warning, possible access blocking. Those rules concern the annual report submission process; they are not a universal fine for every unaudited financial statement.

When an external audit is not mandatory, keep the written assessment and continue with appropriate financial reporting, tax filing, and company approvals. If a bank or shareholder nevertheless requires audited statements, obtain the agreed report before treating that contractual obligation as complete.

Choose the Right Audit and Reporting Support

A useful engagement starts by deciding what work the company needs: monthly bookkeeping, preparation of financial statements, an independent KAP audit, or assistance coordinating the records for tax and shareholder approvals. These are related tasks, but each has its own deliverables and responsibilities.

InvestinAsia is the Indonesia market entry arm of vOffice Group, which has operated since 2003. As explained on our About Us page, our delivery model draws on 380+ legal, tax, and business specialists across the group. This is group-wide capacity, not a claim that InvestinAsia alone employs those specialists. Corporate legal and licensing work in Indonesia is supported by vOffice and IZIN.co.id.

For financial reporting, the distinction matters: group-backed accounting and compliance support can help organize your records, but an external audit opinion must come from a properly authorized, independent public accountant. The InvestinAsia Accounting and Tax Reporting Services page lists financial statement preparation, bookkeeping, tax reporting, and a Financial Audit (KAP) option by consultation. Confirm the separate audit engagement’s scope, independence, timetable, and deliverables before proceeding.