REGULATION OF THE MINISTER OF LAW AND HUMAN RIGHTS OF THE REPUBLIC OF INDONESIA

NUMBER 29 OF 2022
ON
THE BLOCKING AND UNBLOCKING OF ACCESS OF LIMITED LIABILITY COMPANIES TO THE LEGAL
ENTITY ADMINISTRATION SYSTEM

BY THE GRACE OF GOD ALMIGHTY

THE MINISTER OF LAW AND HUMAN RIGHTS OF THE REPUBLIC OF INDONESIA,

Considering:
a. that in order to provide legal protection to the community, specifically in relation to shareholders of a
company in dispute, it is necessary to block or unblock the company's access to the legal entity
administration system of the Directorate General of General Legal Administration;
b. that Regulation of the Minister of Law and Human Rights Number 24 of 2012 on Procedures for the
Blocking and Unblocking of Access to the Legal Entity Administration System for Limited Liability
Companies as amended by Regulation of the Minister of Law and Human Rights Number 19 of 2017 on
Amendment to Regulation of the Minister of Law and Human Rights Number 24 of 2012 on Procedures for
the Blocking and Unblocking of Access to the Legal Entity Administration System for Limited Liability
Companies, is no longer in accordance with the needs of the community, the development of business
world, and legal developments, so that it needs to be replaced;
c. that based on the considerations as referred to in letter a and letter b, it has been deemed necessary to
establish Regulation of the Minister of Law and Human Rights on the Blocking and Unblocking of Access
of Limited Liability Company to the Legal Entity Administration System;

Observing:
1. Article 17 paragraph (3) of the 1945 Constitution of the Republic of Indonesia;
2. Law Number 40 of 2007 on Limited Liability Companies (State Gazette of the Republic of Indonesia of
2007 Number 106, Supplement to the State Gazette of the Republic of Indonesia Number 4756);
3. Law Number 39 of 2008 on State Ministries (State Gazette of the Republic of Indonesia of 2008 Number
166, Supplement to the State Gazette of the Republic of Indonesia Number 4916);
4. Regulation of the Government Number 7 of 2021 on the Ease, Protection and Empowerment of
Cooperatives and Micro-, Small- and Medium-Scale Enterprises (State Gazette of the Republic of
Indonesia of 2021 Number 17, Supplement to the State Gazette of the Republic of Indonesia Number
6619);
5. Regulation of the Government Number 8 of 2021 on Company Authorized Capital and Registration of the
Establishment, Change and Dissolution of Company that Meets the Criteria for Micro- and Small-Scale
Businesses (State Gazette of the Republic of Indonesia of 2021 Number 18, Supplement to the State
Gazette of the Republic of Indonesia Number 6620);
6. Regulation of the President Number 44 of 2015 on the Ministry of Law and Human Rights (State Gazette
of the Republic of Indonesia of 2015 Number 84);

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 7. Regulation of the Minister of Law and Human Rights Number 41 of 2021 on the Organization and Work
Procedures of the Ministry of Law and Human Rights (Official Gazette of the Republic of Indonesia of
2021 Number 1365);

HAS DECIDED:

To establish:
REGULATION OF THE MINISTER OF LAW AND HUMAN RIGHTS ON THE BLOCKING AND UNBLOCKING
OF ACCESS OF LIMITED LIABILITY COMPANIES TO THE LEGAL Y

CHAPTER I
GENERAL PROVISIONS

Article 1
Under this Regulation of the Minister, the following definitions are employed:
1. Limited Liability Company, from this point onward is referred to as Company, is a legal entity which take
the form of a capital partnership, is established based upon an agreement, and conduct business activities
using authorized capitals that are entirely divided into shares or individual legal entity that fulfill the criteria
of micro- and small-scale businesses as set out under laws and regulations on micro- and small-scale
businesses.
2. Legal Entity Administration System (Sistem Administrasi Badan Hukum), from this point onward, is
referred to as SABH, is an electronic legal entity administration service system organized by the
Directorate General of General Legal Administration.
3. Access is the activity of utilizing services regarding the Company which are available in the SABH by
Notaries and/or applicants.
4. Blocking is the act of closing a Company's Access to the SABH.
5. Unblocking is the act of reopening a Company’s Access to SABH which was previously subject to
Blocking.
6. Receiver is the Property and Heritage Agency or an individual appointed by the commercial court to
manage and settle the assets of a bankrupt debtor under the supervision of a Supervisory Judge in
accordance with the provisions of laws and regulations in the bankruptcy sector.
7. Minister is the minister who organizes government affairs in the law and human rights sector.
8. Director-General is the Director-General of General Law Administration.

CHAPTER II
ACCESS BLOCKING

Division One
General

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 Article 2
(1) Access Blocking Application shall be submitted to the Minister through the Director-General.
(2) Access Blocking Application as referred to in paragraph (1) may be submitted electronically or non-
electronically by including the reason for Access Blocking.
(3) Access Blocking Application shall be subject to fees in accordance with the provisions of laws and
regulations in the Non-Tax State Revenue sector applicable at the Ministry of Law and Human Rights.

Article 3
Access Blocking shall be conducted toward:
a. capital partnership Company; and
b. Individual company.

Division Two
Access Blocking for Capital Partnership Companies

Article 4
(1) Access Blocking for capital partnership Companies as referred to in Article 3 letter a shall consist of:
a. Complete Blocking; and
b. Blocking of changes of shareholders.
(2) Complete Blocking as referred to in paragraph (1) letter a shall result in the closure of a Company’s
Access.
(3) The blocking of changes of shareholders as referred to in paragraph (1) letter b shall result in the closure
of a Company’s Access to any changes of:
a. all shareholders; or
b. some shareholders.

Article 5
(1) Complete Blocking Application as referred to in Article 4 paragraph (1) letter a may be submitted by:
a. shareholders or joint shareholders as the owner of more than 50% (fifty percent) shares out of the
total number of issued shares;
b. shareholders or joint shareholders as the owner at least 10% (ten percent) shares out of the total
number of issued shares;
c. parties who have been listed as shareholders as referred to in letter a and letter b in the following
matters:
1. 1 (one) transaction on the change of shareholders has been conducted prior to the last
transaction on the change of shareholders; or

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 2. a maximum of 2 (two) years since being listed as shareholders in the SABH,
if there is a dispute over the transfer of shares; or
d. authorized government agency.
(2) In submitting a complete Blocking application, the applicant as referred to in paragraph (1) letter b and
letter c shall enclose:
a. that has been registered and obtained a registration number from the court registrar in civil cases
regarding share disputes or state administrative disputes; or
b. proof of out-of-court dispute settlement registration,
relating to the listing of the Company’s legal entity data in the SABH.

Article 6
(1) Application for the Blocking of changes of shareholders as referred to in Article 4 paragraph (1) letter b
may be submitted by:
a. shareholders of the Company, if the shares being submitted are their own;
b. the heirs of shareholders of the Company; or
c. authorized government agency.
(2) In submitting the application for the Blocking of changes of shareholders, the applicant as referred to in
paragraph (1) letter b shall enclose:
a. certificate of inheritance; and
b. a lawsuit that has been registered and obtained a registration number from the court registrar in civil
cases or registration of out-of-court dispute settlement regarding inheritance disputes.

Article 7
(1) In the event that a capital partnership Company or shareholder of a capital partnership Company is
declared bankrupt, the Access Blocking application as referred to in Article 4 paragraph (1) shall be
submitted by the receiver.
(2) Upon shareholders of the capital partnership Company that are declared bankrupt as referred to in
paragraph (1), the Access Blocking application may only be made toward their shares.
(3) The Access Blocking application submitted by the receiver as referred to in paragraph (1) must be
enclosed with supporting documents in the form of:
a. bankruptcy decision by the commercial court; or
b. ruling of the commercial court, if there is a replacement of receiver.

Division Three
Access Blocking for Individual Company

Article 8

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 (1) Application for the Blocking of Access for individual Company as referred to in Article 3 letter b may be
submitted by:
a. the owner;
b. parties who have been listed as owners, if there is a dispute relating to the transfer of ownership of
individual Companies; or
c. authorized government agency.
(2) In submitting the application for the Blocking of Access for individual Company, the applicant as referred to
in paragraph (1) letter b shall enclose the following documents:
a. a lawsuit that has been registered and obtained a registration number from the court registrar in civil
cases regarding disputes relating to ownership or state administrative disputes; and/or
b. registration of out-of-court dispute settlement,
relating to the listing of the Company’s legal entity data in the SABH.

Article 9
(1) In the event that an individual Company is declared bankrupt, the Access Blocking application shall be
submitted by the Receiver.
(2) The Access Blocking Application submitted by the Receiver as referred to in paragraph (1) must be
enclosed with supporting documents in the form of:
a. bankruptcy decision by the Commercial Court; or
b. ruling of the Commercial Court, if there is a replacement of Receiver.

Division Four
Approval and Rejection of Access Blocking Applications

Article 10
(1) The Minister through the Director-General may approve or reject Access Blocking applications.
(2) In the process of granting approval or rejection of Access Blocking applications, the Director-General may
summon the relevant parties to conduct clarification as material for consideration.
(3) The approval or rejection of Access Blocking applications as referred to in paragraph (1) shall be notified
in writing to the applicant and the Company.

Article 11
(1) Access Blocking applications may be made by the applicant's proxy.
(2) The application submitted by the applicant's proxy as referred to in paragraph (1) must be enclosed with a
power of attorney from the applicant.

Article 12

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 The Minister may conduct Access Blocking without any application, in the event of any discrepancy or conflict
with:
a. provisions of laws and regulations; and/or
b. general principles of good governance.

CHAPTER III
UNBLOCKING OF ACCESS

Division One
General

Article 13
(1) Toward Companies that has been subject to Access Blocking, the Unblocking of Access can be submitted.
(2) Application for the Unblocking of Access as referred to in paragraph (1) shall be submitted to the Minister
through the Director-General.
(3) The application for the Unblocking of Access as referred to in paragraph (2) may be submitted
electronically or non-electronically by including the reason for the Unblocking of Access.
(4) Applications for the Unblocking of Access shall be subject to fees in accordance with the provisions of
laws and regulations in the Non-Tax State Revenue sector applicable at the Ministry of Law and Human
Rights.

Article 14
Unblocking of Access shall be conducted toward:
a. Capital partnership Companies; and
b. Individual Companies.

Division Two
Unblocking of Access toward Capital Partnership Companies

Article 15
(1) Unblocking of Access toward capital partnership Company as referred to in Article 14 letter a shall consist
of:
a. Complete Unblocking of Access; and
b. Unblocking of Access to changes of shareholders.
(2) Complete Unblocking of Access as referred to in paragraph (1) letter a shall be conducted when the
Company:
a. is not in a state of dispute; and

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 b. is not a party in a state administrative case.
(3) Unblocking of Access to changes of shareholders as referred to in paragraph (1) letter b shall be
conducted if:
a. there are no disputes relating to the transfer of shares;
b. are not in a state administrative dispute relating to the listing of the Company's shares; and
c. not in a state of inheritance dispute.

Article 16
(1) Application for the complete Unblocking of Access as referred to in Article 15 paragraph (1) letter a may be
submitted by:
a. shareholders or joint shareholders as the owner of more than 50% (fifty percent) shares out of the
total number issued shares;
b. shareholders or joint shareholders as the owner of at least 10% (ten percent) shares out of the total
number of issued shares;
c. parties who have been listed as shareholders as referred to in letter a and letter b in the event that:
1. 1 (one) transaction on the change of shareholders has been conducted prior to the last
transaction on the change of shareholders; or
2. A maximum of 2 (two) years since being listed as shareholders in the SABH,
if there is a dispute over the transfer of share; or
d. authorized government agency.
(2) In submitting the application for the complete Unblocking of Access, the applicant as referred to in
paragraph (1) letter a shall enclose a statement letter stating that there are no Company disputes, signed
by all shareholders.
(3) In submitting an application for the complete Unblocking of Access, the applicant as referred to in
paragraph (1) letter b and letter c shall enclose:
a. declaration/agreement of reconciliation or deed of reconciliation;
b. ruling on the revocation of a case;
c. court decision that already obtain permanent legal force; or
d. ruling on out-of-court dispute settlement,
in relation to the case which becomes the basis of Access Blocking.

Article 17
(1) Application for the Unblocking of changes of shareholders as referred to in Article 15 paragraph (1) letter b
may be submitted by:
a. the Company's shareholders toward their own shares;
b. heirs of the Company’s shares; and
c. authorized government agency.

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 (2) In submitting an application for the Unblocking of changes of shareholders, the applicant as referred to in
paragraph (1) letter a shall enclose a statement letter stating that there is no dispute relating to the
transfer of shares, or state administrative disputes relating to the listing of the Company’s shares in the
SABH.
(3) In submitting the application for the Unblocking of changes of shareholders, the applicant as referred to in
paragraph (1) letter b shall enclose:
a. statement/agreement of reconciliation which has been agreed upon and signed by all heirs as
proven by a statement letter stating the inheritance or determination of heir;
b. the deed of reconciliation which contains the contents of reconciliation text and/or the judge’s
decision confirming the reconciliation agreement;
c. court ruling or decision relating to inheritance dispute; or
d. decision on out-of-court dispute settlements regarding inheritance disputes.

Article 18
(1) In the event that a capital partnership Company or shareholder of a capital partnership Company is
declared bankrupt, the application for the Unblocking of Access as referred to in Article 15 paragraph (1)
shall be submitted by the Receiver.
(2) The application for the Unblocking of Access submitted by the Receiver as referred to in paragraph (1)
must be enclosed with proof of bankruptcy assets settlement.

Division Three
Unblocking of Access toward Individual Companies

Article 19
(1) Application for the Unblocking of Access toward individual Companies as referred to in Article 14 letter b
may be submitted by:
a. owner;
b. parties who have been listed as owners, if there is a dispute relating to the transfer of ownership of
an individual Company; and
c. authorized government agency.
(2) In submitting an application for the Unblocking of Access toward individual Companies, the applicant as
referred to in paragraph (1) letter a shall enclose:
a. a copy of statement of establishment; or
b. statement of changes which was most recently listed in the SABH.
(3) In submitting an application for the Unblocking of Access toward individual Companies, the applicant as
referred to in paragraph (1) letter b must enclose:
a. statement letter stating that there is no dispute over ownership or state administrative dispute in
relation to the listing of the Company's ownership in the SABH;
b. deed of reconciliation;

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 c. ruling on the revocation of a case;
d. court decision that already obtain permanent legal force; or
e. ruling on out-of-court dispute settlement,
relating to dispute over the ownership of individual Company.

Article 20
(1) In the event that an individual Company is declared bankrupt, an application for the Unblocking of Access
shall be submitted by the Receiver.
(2) Application for the Unblocking of Access submitted by the Receiver as referred to in paragraph (1) must
be enclosed with proof of bankruptcy assets settlement.

Division Four
Temporary Unblocking of Access

Article 21
(1) In the event that there is a need for the Company to make certain changes for the sustainability of their
business, a temporary Unblocking of Access may be conducted.
(2) Application for the temporary Unblocking of Access shall be submitted to the Minister through the Director-
General.
(3) The application for the temporary Unblocking of Access as referred to in paragraph (2) must include the
reason and enclose a statement from the Notary who will conduct the Access that they will not make other
changes other than the submitted reason for the temporary Unblocking of Access.
(4) Applications for the temporary Unblocking of Company’s Access may be submitted by:
a. President director or board of directors authorized to represent the Company in accordance with the
articles of association of the Company;
b. shareholders or joint shareholders as the owner of more than 50% (fifty percent) shares out of the
total number of issued shares; or
c. authorized government agency.
(5) In the event that a Company is declared bankrupt, an application for the temporary Unblocking of Access
shall be submitted by the receiver.
(6) After implementing the temporary Unblocking of Access in accordance with the needs of the Company, the
Minister through the Director-General shall conduct the Access Blocking again.

Division Five
Approval and Rejection

Article 22
(1) The Minister through the Director-General may approve or reject the application for the Unblocking of

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 Access.
(2) In the process of granting approval or rejection of applications for the Unblocking of Access, the Director-
General may summon the relevant parties to conduct clarification as material for consideration.
(3) Approval or rejection of applications for the Unblocking of Access as referred to in paragraph (1) shall be
notified in writing to the applicant and the Company.

Article 23
(1) Application for the Unblocking of Access as referred to in Article 13 may be conducted by the applicant's
proxy.
(2) The application submitted by the applicant's proxy as referred to in paragraph (1) must be enclosed with a
power of attorney from the applicant.

Article 24
The Minister may carry out the Unblocking of Access without any application, in the event of any discrepancy or
conflict with:
a. provisions of laws and regulations; and/or
b. general principles of good governance.

CHAPTER IV
MISCELLANEOUS PROVISIONS

Article 25
(1) Requests for data information on capital partnership Company or individual Company in a blocked status
may be submitted in writing to the Director-General.
(2) The data information as referred to in paragraph (1) may be provided by the Director-General by adding
information on the blocked status.

CHAPTER V
TRANSITIONAL PROVISIONS

Article 26
Upon the effective enforcement of this Regulation of the Minister, any Company that is currently undergoing
Access Blocking prior to the enforcement of this Regulation of the Minister shall remain blocked.

CHAPTER VI
CLOSING PROVISIONS

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