The Ministry of Investment and Downstreaming / Investment Coordinating Board (Badan Koordinasi Penanaman Modal or BKPM) has issued the Policy on the Submission of Investment Activity Reports, dated 23 September 2026, which reaffirms the requirements for the submission of Investment Activity Reports (Laporan Kegiatan Penanaman Modal or LKPM), including the provisions governing amendments thereto.
The LKPM is a report on the progress of investment realization and the fulfillment of investment obligations submitted by each business actor in Indonesia through the OSS system. In general, LKPM must be submitted for each business activity (both main and supporting activities) and for each business location. The LKPM reporting process consists of two stages: preparation and reporting. Based on the verification of the LKPM by the relevant officials, the OSS system will issue the business actor’s compliance profile.
The changes to the LKPM requirements are as follows:
| Aspect | BKPM Regulation No. 5 of 2021 | BKPM Regulation No. 5 of 2025 |
| Exemptions | Exemptions apply to certain sectors, including the upstream oil and gas sector, banks, non-bank financial institutions, insurance companies, and other specified sectors | Exemptions apply to micro-scale businesses (IDR 1-5 billion of capital) and activities financed through the State Budget (APBN) and/or Regional Budgets (APBD). |
| Period of Submission | Reporting is required on a quarterly or semi-annual basis, with the reporting deadline falling on the 10th day of each reporting period | The reporting deadline is extended to the 15th day of each reporting period (15 April, 15 July, 15 October, and 15 January) |
| Component | Investment realization Manpower realization Company obligation | Change of component: compliance with the fulfilment of basic requirements, Business Licensing (PB) and/or Business Licensing to Support Business Activities (PB UMKU) |
| Assessment / Review | Assessment / review of LKPM is not available | Assessment / review of LKPM is available |
Guidance to ensure accurate and correct LKPM Reporting
- Ensure that there are no errors in reporting the investment realization value (i.e., the reported value is reasonable). For example, for the trading sector, the investment realization exceeds IDR 50 billion, or the business has commenced operations but an additional investment realization of IDR 1 trillion is reported.
- Ensure that there are no typographical errors in the figures or number of zeros entered into the system.
- Investment realization values reported in the LKPM should not include decimal points.
- Re-check the report if there is an increase in the number of foreign workers, as this may indicate an increase in investment. Please provide an explanatory note accordingly.
- If the business has commenced production, there should generally be a corresponding realization of workers.
- The investment realization value does not have to exactly match the Investment Plan. The realization reported should be based on the business actor’s asset records.
- If there are multiple KBLI codes at the same location, allocate the investment realization proportionally to avoid potential indications of duplicate data. For activities where the investment value cannot reasonably be allocated, report the realization under only one Business Activity Number (Nomor Kegiatan Usaha or NKU) and enter zero under the other NKUs.
- For LKPM during the Production Stage, do not report realization of working capital expenditures, such as rent, employee salaries, electricity, gas, etc., as these constitute operating expenses.
- For LKPM during the Construction Stage, the additional investment realization value must not be reported as zero for four consecutive reporting periods.
- For LKPM during the Production Stage, if there is any additional investment realization, provide a detailed breakdown in the realization notes column.
Additional Provisions on LKPM Reporting
If a business actor fails to submit an LKPM within the applicable reporting period and the reporting period has been closed, the LKPM may be submitted in the subsequent reporting period on a cumulative basis for the same calendar year.
With respect to the completion of LKPM data, if a business actor intends to correct or amend data from an LKPM that has been approved in a previous reporting period, such correction or amendment may be made by adjusting the total accumulated realization through the “Change Total Accumulated Investment Realization” function.
A business actor must ensure that LKPM reporting covers all project data that has been issued and listed in the attachment to the Business Identification Number (Nomor Induk Berusaha or NIB). This is necessary to avoid sanctions arising from the business actor being deemed not to have properly fulfilled its LKPM reporting obligations. If there are activities that have not yet commenced operations, the business actor may revoke the relevant business licensing on a non-liquidation basis to avoid sanctions. The business actor may subsequently re-apply for the relevant licensing once the activities have commenced operations, provided that such activities remain recorded in the company’s deed of establishment and/or amendments thereto.
Sanctions for Non-Compliance
- Written Warning
A written warning is imposed on business actors that commit minor violations, including:
- failing to submit an LKPM for 2 (two) consecutive reporting periods;
- submitting an LKPM for the first time without any additional investment realization for 4 (four) consecutive reporting periods; or
- submitting an LKPM without any additional investment realization for 4 (four) consecutive reporting periods during the Preparation (Construction) Stage of LKPM reporting.
- Temporary Suspension
A temporary suspension is imposed if a business actor fails to comply with the obligations arising from a minor violation sanction (Written Warning)
- Revocation of Business Licensing and/or Business Activities
Revocation of business licensing and/or business activities is imposed if a business actor fails to comply with the obligations arising from a moderate violation sanction (Temporary Suspension)
An administrative sanction in the form of a Written Warning or Temporary Suspension may lapse if the business actor submits the required LKPM in the subsequent reporting period. However, a sanction in the form of revocation of business licensing and/or business activities cannot lapse once it has been imposed.
Disclaimer: This report is solely for general information only and never constitutes as legal or tax advice. The user shall further consult with any qualified advisor before referring to any or entire part of this report. Any available copyrights are reserved.
For further information, please contact:
MetaLAW, Legal Consultant, Jakarta, Indonesia
general@metalaw.id
