# OSS investment plans and LKPM reports: what changes each quarter

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*Finance & owner reporting · published 16 July 2026 · updated 19 July 2026 · 13 min read · [canonical edition](https://beemyguest.ai/notes/oss-plan-vs-lkpm-realisation.html)*

*By [François Dalleau](/about/francois-dalleau/) · founder, villa operations, systems and owner reporting in Bali*

> **Operational reading, not a professional opinion.** This note explains how we read dated sources and operating evidence. It is not legal, tax, accounting, immigration, financial or investment advice. Confirm the facts for your property with qualified Indonesian advisers.

OSS, Indonesia's online business-licensing system, records what the company plans to build, buy or operate. LKPM, the recurring investment activity report, records what has happened during and up to the reporting period.

They should reconcile. They should not be copied into each other.

That single distinction removes much of the confusion around the large investment number recorded when a PT PMA is established. A plan is a forward-looking commitment recorded in the licensing system. A realisation report is an evidence-based update, filed for the relevant activity and location.

## What OSS and LKPM each record

Under the current investment-supervision regulation, a foreign-investment company is treated as a large enterprise and generally files LKPM quarterly. Reporting is organised by **business activity and business location**, not merely one total for the legal entity.

For each reporting unit, LKPM can cover investment realisation, labour, production or services, permits, business obligations and problems. The required fields differ between the preparation/construction stage and the operational/commercial stage.

The quarterly legal deadlines are:

| Period | Deadline |
|---|---:|
| Quarter 1 | 15 April |
| Quarter 2 | 15 July |
| Quarter 3 | 15 October |
| Quarter 4 | 15 January of the following year |

An official notice can adjust a deadline around a national holiday. Always check the current BKPM/OSS notice rather than relying only on a recurring calendar.

## Four numbers that look similar but are not interchangeable

| Number | The question it answers | Common mistake |
|---|---|---|
| OSS investment plan | What does this project intend or commit to invest? | Reporting the full plan as already realised. |
| Financing received | Where did the money come from: equity, a shareholder loan, bank debt or operations? | Treating every cash receipt as an investment asset. |
| Accounting spend / asset register | What was paid, capitalised, expensed or still payable? | Assuming the accounting label automatically determines the LKPM field. |
| LKPM investment realisation | What eligible investment has been realised for this activity and location, cumulatively and in the period? | Copying a plan, bank balance or P&L total without reconciliation. |

The company needs all four records. The answer is not to force them to be identical. It is to document why they differ.

## Why the activity and location level matters

Imagine a PT PMA has two villa projects and two KBLI activities. One central office team, one vehicle and one software subscription support all of them.

If each activity-location LKPM reports the full value of those shared items, the company may report the same realisation several times. If none reports them, its evidence may understate what supports the projects.

The regulation tells us the reporting unit: each business activity and each location. It does not give one universal allocation formula for every shared asset. The company therefore needs a documented, consistent allocation method approved by its accounting/tax reviewer. It must also avoid reporting assets owned by a client as if they were the PT PMA's own investment.

## Preparation versus operational/commercial stage

During preparation or construction, the report focuses on bringing the project into operation: eligible realised investment, employment, permits, construction/preparation progress and obstacles.

Operational/commercial reporting applies after the relevant ready-for-operation/commercial statement has been completed in OSS. It adds the operational picture: production or services, revenue-related operating information and the continued status of licences and obligations.

Two cautions matter here:

1. A company earning its first rupiah does not automatically mean every OSS project has been correctly moved to the operational phase.
2. Clicking the operational statement too early can create a record that does not match project readiness or licences.

Confirm the phase for each activity-location unit. Do not infer it only from the age of the company.

## A quarter-end workflow that can survive a review

### D-30: freeze the reporting map

List every active combination of:

- company and NIB;
- KBLI/activity;
- project and location;
- preparation or operational phase;
- responsible data owner and final reviewer.

Reconcile it against the previous quarter and record new codes, projects, locations or phase changes.

### D-20: assemble evidence

Collect, at minimum where relevant:

- prior LKPM and its approved/correction status;
- contracts, invoices and proof of payment;
- bank statements and financing ledger;
- fixed-asset register and construction-in-progress schedule;
- general ledger mapping used for LKPM;
- employee/headcount records;
- permits, standards and their current status;
- production, services or operating data;
- a list of obstacles and corrective actions.

### D-15: reconcile, do not copy

Use a dated reconciliation rather than copying a total. **Illustrative example only:** if the previously approved cumulative realisation is IDR 2.00 billion, supported eligible additions for the quarter are IDR 300 million and a documented reclassification removes IDR 50 million, the cumulative amount to review is IDR 2.25 billion.

Then reconcile additions to invoices, payments, asset records and the financing ledger. Explain timing differences, advances, unpaid items and shared-asset allocations.

### D-7: independent review

The person who prepares the schedule should not approve it alone. An independent reviewer with access to the supporting accounting and tax records should test unusual jumps, periods with no movement, duplicate assets, location errors and unexplained inconsistencies.

### Submission: retain two layers of proof

OSS issues proof that the report was submitted. The authority then verifies it and may approve it or request correction.

Therefore, "we have the receipt" is not the end of the control. Retain:

1. the submission receipt; and
2. the final approval/status, or the correction request and corrected filing.

The regulation provides for verification within three business days after receipt. Because a requested correction is due no later than the reporting deadline, filing at the final minute removes the practical correction window.

## What "no added realisation" means

Owners sometimes hear that a company will be sanctioned if it does not increase investment every quarter. That is an unsafe summary.

Article 373 identifies three triggers: no LKPM for two consecutive reporting periods; a first LKPM followed by no additional investment realisation for four consecutive periods; or preparation-stage LKPM with no additional investment realisation for four consecutive periods. Articles 374 to 376 then provide three successive written warnings, temporary suspension, an administrative fine and, if the stated conditions remain unmet, revocation of the business licence for the relevant activity.

Three points are essential:

- one missed report does **not** automatically cancel the NIB;
- "no added investment realisation" is not the same as "no revenue" or "no taxable profit";
- the application of a trigger to a mature or unusual project should be reviewed, not guessed.

## What a compliance calendar should do

A useful compliance calendar should create one LKPM obligation for each activity-location unit, show the phase, surface the legal due date and create operational reminders at D-30, D-15 and D-7.

It should also require an evidence pack and track these states:

> Data requested → evidence received → reviewed → submitted → correction requested or approved.

It should not call the company "compliant" merely because someone ticked a box. It should not file automatically. And it should not mix tax, corporate or immigration deadlines into the same calendar unless each obligation has its own current legal source and owner.

## The quarterly questions for management

1. Which activity-location units must report this quarter?
2. What phase is each unit in according to both OSS and reality?
3. What new eligible investment was realised?
4. What evidence supports it and who owns the asset?
5. Were any shared costs allocated more than once?
6. Do accounting, banking, OSS and the prior LKPM explain the same movement?
7. Do we hold both the submission receipt and the final result?

The point of LKPM is not to make the company's books look like the original OSS plan. The point is to show, quarter after quarter, an evidence-based path from the approved project to what the company has realised.

### Official sources

[Permeninves/BKPM No. 5 of 2025, official PDF](https://jdih-storage.bkpm.go.id/jdih/jdih/2025Permeninvesthil005-.pdf); [BKPM Q1 2026 LKPM announcement](https://bkpm.go.id/id/info/pengumuman/klinik-lkpm-triwulan-i-tahun-2026); [official OSS preparation-stage guide](https://oss.go.id/id/panduan/635970086345c7d71a8144e3); [official OSS operational-stage guide](https://oss.go.id/id/panduan/635970086345c7d71a8144e4).

*General educational information only. LKPM treatment depends on the company's activity, location, business scale, project phase, evidence and current OSS record. It is not a tax return or project-specific legal advice.*

Related: [PT PMA capital explained: IDR 2.5 billion, the IDR 10 billion investment plan and E28A shares](https://dalleau.ai/notes/pt-pma-capital-idr-10-billion-investment-e28a.html) · [From 55193 to 55203: what an existing villa company must change and what it should review first](/notes/kbli-2025-migration-55193-to-55203.html) · [Seven ways to receive or transfer value from a PT PMA, and how each is taxed](https://dalleau.ai/notes/how-money-leaves-pt-pma.html) · [If your Bali tourism business qualifies for the 2026 payroll-tax incentive, the benefit belongs in the employee's pay](/notes/indonesia-2026-tourism-payroll-tax-incentive.html)

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## Continue through this operating file

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