If your company has received LKPM late filing sanctions, the fastest and most effective solution is immediate compliance through the OSS system. In most cases, sanctions issued by BKPM under Peraturan BKPM No. 5/2025 are lifted automatically once overdue LKPM reports are submitted and administrative obligations are fulfilled. Formal appeals are possible, but they are secondary to compliance and should be used strategically.
As an advisory team that works daily with foreign investors and PT PMA in Indonesia, we see that understanding the sanction mechanism is the key to resolving it efficiently.
Understanding LKPM Sanctions for Late Filing
LKPM or Laporan Kegiatan Penanaman Modal is a mandatory investment activity report. When you fail to submit it on time, BKPM applies administrative sanctions in stages, not instantly.
Sanctions typically start with a written warning and escalate only if non-compliance continues. This progressive structure is designed to push businesses back into compliance rather than immediately penalize them.
The common escalation path includes:
- First written warning with a correction deadline
- Second and third written warnings
- Temporary business suspension and administrative fines
- Permit revocation for persistent violations
For foreign-owned companies, these sanctions directly affect NIB validity, business operations, and future licensing.
For a deeper explanation of financial penalties and legal consequences, our article on Penalties and Sanctions for Late or Incorrect LKPM Reporting provides additional clarity.
Immediate Resolution Steps Through OSS
In most situations, you do not need to appeal. You need to comply.
The first and most important step is filing all overdue LKPM reports through your OSS-RBA account. Once submitted, the system records compliance and triggers sanction lifting.
The practical steps are:
- Log in to your OSS account and access the LKPM reporting menu.
- Submit LKPM for every missed reporting period and business location.
- Respond formally to any BKPM warning letters within the stated deadline.
- Pay administrative fines immediately if imposed.
From our experience, business suspension sanctions are often removed automatically once the OSS system detects completed reporting and payment.
When and How to File an Appeal (Keberatan)
An appeal is relevant only if sanctions were imposed due to factors beyond your control, such as system errors or incorrect data attribution.
Although Peraturan BKPM No. 5/2025 does not detail a standalone appeal procedure, objections follow general administrative sanction principles.
You may submit a written objection to BKPM within 14 to 30 days after receiving the sanction notice. The objection should clearly state your reasons and include evidence such as OSS error logs or proof of prior submission attempts.
BKPM typically responds within 30 working days. If the response is unfavorable, escalation to higher administrative authority or court remains an option, though this is rarely necessary when compliance is completed properly.
Special Considerations for PT PMA
Foreign companies often face repeated sanctions because LKPM is incomplete across multiple NIBs or project locations. Filing for one location while missing another still counts as non-compliance.
If you operate more than one licensed activity, every registered location must be reported consistently. This is a common issue we identify during compliance reviews.
To better understand LKPM obligations specifically for foreign-owned companies, you can read our detailed guide on LKPM for PMA and Foreign Companies in Indonesia.
Preventing Future LKPM Sanctions
Once sanctions are resolved, prevention becomes the priority. LKPM deadlines are recurring, and repeated violations increase regulatory risk.
We recommend:
- Centralized tracking of reporting periods
- Regular OSS compliance audits
- Pre-submission validation of investment data
- Clear internal responsibility for LKPM reporting
These steps significantly reduce the risk of escalation and protect your business permits.
How We Support Your LKPM Compliance
As an advisory firm specializing in foreign investment compliance, we assist companies not only in filing LKPM, but also in resolving sanctions, responding to BKPM warnings, and restoring suspended business activities.
If you want to ensure your LKPM reporting is accurate, timely, and fully compliant, our Indonesia LKPM Reporting Services provide end-to-end support tailored to PT PMA and foreign investors.
Resolving LKPM sanctions is not just about fixing the past. It is about securing your business continuity in Indonesia.
Contact us now for FREE consultation and get a special offer!
Frequently Asked Questions (FAQs)
Can LKPM sanctions be removed without filing an appeal?
Yes. In most cases, sanctions are lifted automatically once overdue LKPM reports and fines are completed through OSS.
How long does BKPM take to lift sanctions after filing LKPM?
System-based sanctions often update within days, but manual verification may take longer depending on case complexity.
Do LKPM sanctions affect all business licenses?
Sanctions may affect specific NIBs or project locations. Incomplete reporting can still trigger broader operational restrictions.
Is an appeal mandatory for administrative fines?
No. Administrative fines are resolved through payment. Appeals are only relevant for disputing the basis of the sanction.
What happens if LKPM is repeatedly late?
Repeated non-compliance increases the risk of business suspension and permit revocation under BKPM regulations.
