Surabaya – The East Java Provincial Chamber of Commerce and Industry (Kadin East Java) has urged the government to postpone the implementation of the requirement for Limited Liability Companies (PTs) to submit annual reports through notaries to the Legal Entity Administration System (SABH), as stipulated under Minister of Law Regulation (Permenkum) No. 49 of 2025.

The request was conveyed through an official letter, No. 2372/K/MT/V/2026, addressed to the Minister of Law of the Republic of Indonesia. Kadin East Java believes that the policy, which came into effect on June 1, 2026, could pose risks to corporate data protection, particularly for privately held companies that have traditionally been entitled to maintain the confidentiality of their business information.

Kadin East Java Chairman Adik Dwi Putranto stated that most of the information required in annual corporate reports constitutes strategic and sensitive data that should not be accessible to parties outside the company or to institutions without direct authority over such information.

“Nearly all of the information required in annual reports is confidential, ranging from corporate financial statements and directors’ data, including their compensation, to employee payroll information. When such data must be submitted through a notary and uploaded by notarial staff, concerns naturally arise regarding its security and confidentiality,” Adik said in Surabaya on Monday (June 8, 2026).

According to Adik, companies have already fulfilled their reporting obligations to the state by submitting their Annual Tax Returns (SPT) to the Directorate General of Taxes (DGT). Therefore, Kadin questions the necessity of an additional reporting requirement that must be carried out through a third party.

“Corporate financial data has essentially already been reported to the state through the taxation system. Therefore, it is necessary to clarify why the same information must be submitted again through a different channel involving external parties,” he said.

Adik added that the greatest impact of the policy would be felt by privately held companies. Unlike publicly listed companies, which are subject to public disclosure requirements, privately held companies have the right to maintain the confidentiality of their financial reports and business strategies.

“Privately held companies are not public companies and therefore have no obligation to disclose their financial information to the public. Consequently, safeguarding the confidentiality of business data must be a top priority,” Adik emphasized.

In addition to data security concerns, Adik also highlighted the potential misuse of information should corporate data fall into unauthorized hands. Information regarding a company’s financial condition, payroll structure, and internal policies carries significant strategic value and could be exploited by other parties, including competitors.

Through the letter submitted on May 4, 2026, Kadin East Java proposed three recommendations to the government.

First, to postpone the implementation of the annual report submission requirement to SABH for the 2026 reporting year until data protection systems are deemed fully prepared and secure.

Second, to conduct a review and reassessment of the regulation’s application to privately held companies, taking into account their right to maintain the confidentiality of business information.

Third, to integrate annual reporting data requirements with the tax data already held by the Directorate General of Taxes in order to avoid duplicate reporting and reduce the additional costs companies must incur each year for notarial services.

“We do not oppose the objectives of this regulation. However, we hope that distinct requirements can be established for publicly listed companies and privately held companies, so that the principles of good corporate governance can be upheld while still protecting business confidentiality,” Adik said.

As of now, Kadin East Java has not received an official response from the Ministry of Law regarding the letter. Copies of the letter were also sent to the Head of the East Java Regional Office of the Ministry of Law and the Head of the East Java I Regional Office of the Directorate General of Taxes.

“Kadin East Java hopes that the government will open a dialogue with the business community before the policy is fully implemented. In this way, the objective of improving corporate governance can be achieved without compromising the security and confidentiality of data, which are critical assets for the business sector,” Adik concluded.