Implementation of the Substantive Verification for Changes to Company Data – A New Regime of Scrutiny

What Changed?

Previously, changes to company’s data (board composition, share transfers, shareholder details) on the registration records were done by the Notary independently through the Legal Entity Administration System (SABH), without verification from the Directorate General of General Legal Administration (“Ditjen AHU”). While convenient, the self-declaration system has caused issues:

• Share transfers without the acknowledgement of other shareholders;
• Discrepancies between the documents submitted by the Notary and the original deeds; and/or
• Submitted documents containing formal defects such as unsigned or undated.

Now, effective 27 October 2025, self-declaration submissions are no longer applicable. Ditjen AHU officer will now conduct substantive verification.

What It Means for you?

• Processing time takes from previously 1 (one) working day to 14 (fourteen) working days.
• Each shareholder’s email confirmation is mandatory. If there is no response within 7 (seven) days, the system will automatically reject the changes.
• Incorrect email address and information? Start over.

What’s Happening Now?

• The Challenges and Roadblocks.
• Delays – We are seeing application not verified quickly.
• Glitch in the system – Approval by email is done but not reflected in the system.
• Uncertainty: What happens if the application is rejected? Do we need to sign a new deed, specifically if the circular resolution must be re-executed given the 30 (thirty) days notification requirement under the Limited Liability Company Law.
• No socialization and guidance issue yet – the practice may be subject to further changes and improvement.

Conclusion

While this new policy intended for a better verification and process of changes in the company’s data – companies must adapt and plan ahead to avoid future risk. For instance, appointment of your new board which may relates to the officer’s work permit may be delayed. Acquisition timeline may be affected and changed and adjusted with buffer – all until Ditjen AHU issues clear guidelines and the system is perfected.

For any queries, please contact:

1. vincent@lhbmlaw.com
2. info@lhbmlaw.com