LKPM Requirements: No New Investment This Quarter, Do You Still Need to Submit LKPM?

No New Investment This Quarter, Do You Still Need to Submit LKPM?

A company completes another quarter without opening a new location, purchasing equipment, adding capital, or expanding operations. Management concludes: “Nothing changed, so there is nothing to report.”

That assumption can create a compliance gap.

For businesses subject to investment reporting in Indonesia, LKPM Requirements do not arise only when new investment occurs. LKPM, or Laporan Kegiatan Penanaman Modal, is a periodic investment activity report. Whether a business must submit it depends on the applicable rules, business scale, project status, and exemptions, not simply on whether something changed during the quarter.

The practical question is not, “Did we invest anything new?” It is, “Are we still subject to LKPM Requirements this period?”

“Nothing Changed” Is Not an Automatic Exemption

This is the central misconception.

A business may have the same office, employees, equipment, investment value, and activities as the previous quarter. That does not automatically mean its LKPM Requirements have disappeared.

The current framework is Minister of Investment and Downstreaming/Head of BKPM Regulation No. 5 of 2025, which remains in force in 2026 and replaced BKPM Regulations Nos. 3, 4, and 5 of 2021. 

Under the current rules, LKPM reporting is periodic for businesses within applicable reporting categories. Certain exemptions apply, so each business should confirm its status. “No change” is not, by itself, a general exemption from LKPM Requirements.

LKPM Is Not Only About New Spending

Another misunderstanding is treating LKPM as relevant only when the company spends more money.

Operations simply continue.

The absence of new spending does not itself answer whether the company has LKPM Requirements. If it remains within a category required to report, the company should assess and submit its report according to its actual circumstances.

What If the Figures Are the Same?

But the solution is neither to invent new investment nor automatically skip reporting.

LKPM should reflect reality.

Businesses should review what OSS requires for their project and reporting stage, verify the information against company records, and report accurately. OSS provides LKPM processes for non-micro and small enterprises at preparation/construction and operational/commercial stages.

Complying with LKPM Requirements therefore means accurate periodic reporting, not creating artificial changes simply to make a report look different.

What If the Business Has Not Started Operating?

A PT PMA may still be preparing its site, completing licensing, waiting for construction, or arranging equipment.

Because commercial operations have not started, management may assume there is no reason to report.

That assumption should be checked.

OSS provides LKPM reporting guidance for businesses at the preparation or construction stage as well as the operational or commercial stage. Being pre-operational therefore does not automatically eliminate LKPM Requirements.

The company should determine its reporting status and project stage, then report the actual position applicable to the period.

What If Business Continues Normally?

The opposite situation is equally common.

During the quarter, there is no expansion, capital increase, or substantial change.

“Business as usual” should not be confused with “no reporting obligation.”

If the company remains subject to LKPM Requirements, a quiet quarter does not automatically suspend them. Management should continue monitoring its reporting schedule and ensure submitted information reflects the business accurately.

What If the Company Is Temporarily Inactive?

Management might assume LKPM is unnecessary because little activity occurred.

However, temporary inactivity is not necessarily the same as legally ending the company, cancelling its business licensing, or becoming exempt from LKPM Requirements.

Before Skipping LKPM, Check Your Status

Before deciding there is “nothing to report,” management should ask: Is the company active in OSS? What is its business scale? Is the project in preparation/construction or operational/commercial stage? Does an exemption apply? What did the previous LKPM show? Do current figures match supporting records?

Under Regulation No. 5 of 2025, small businesses generally report every six months, while medium and large businesses generally report quarterly. Micro businesses and certain qualifying activities financed through state or regional budgets are exempt.

Understanding these distinctions is essential to managing LKPM Requirements correctly.

Why Simply Skipping Can Create Risk

When management decides internally that “nothing changed,” the company may miss a filing that was still required.

The better approach is to determine whether the company remains subject to LKPM Requirements before deciding not to submit. Businesses should also review investment figures, workforce information, project status, and OSS data before the reporting window closes.

Most importantly, distinguish between “nothing changed” and “we are legally exempt.” They are not the same conclusion.

No New Investment Does Not Mean No Compliance

No new equipment, expansion, capital increase, or location may simply mean the company had a stable reporting period. It does not automatically mean LKPM Requirements no longer apply.

A quiet quarter can still be a reportable quarter.