To enhance the governance of corporate legal data and safeguard the rights of shareholders involved in internal disputes, the Minister of Law has issued Regulation No. 21 of 2025 on the Blocking and Unblocking of Access to Limited Liability Companies in the Legal Entity Administration System (Sistem Administrasi Badan Hukum or “AHU System”). This new regulation came into force on 10 June 2025 and introduces important changes to the procedures for restricting and restoring access to company data.
One of the most notable developments under this regulation is the expansion of parties eligible to request data access blocking. Requests may now be submitted not only by current shareholders or groups of shareholders, but also by former shareholders under specific conditions. These include individuals or entities listed in the AHU system within the past three years, or those involved in only one transaction prior to the latest share transfer. This represents a significant departure from the previous regulatory framework, which restricted such requests to shareholder or group of shareholders holding more than 50% or at least 10% of the company’s paid-up capital, and allowed former shareholders to apply only if there had been no more than one intervening transfer or if they had been deregistered from the system for less than two years. As with the prior regulation, applications may also be submitted by authorised government institutions.
Another key change introduced under the new regulation is the removal of the temporary unblocking mechanism, which previously allowed the Ministry of Law to temporarily restore access in situations where a company needed to make certain changes to ensure the continuity of its business operation. In addition, the Minister of Law no longer has unilateral authority to initiate a data block, even in cases of suspected non-compliance with the law or violations of good governance principles. This shift signals a move toward a more transparent, request-based administrative approach.
During the transition to the new regulatory regime, the Ministry will continue to accept manual submissions for a period of six months from the effective date. Thereafter, all requests must be submitted electronically through the AHU system.
Overall, this regulation is expected to reinforce legal certainty and shareholder protection by preventing unauthorized alterations to company records during periods of internal conflict or litigation. It underscores the government’s broader commitment to strengthening transparency, digitalization, and accountability in Indonesia’s corporate governance environment.