LKPM Reconciliation for PT PMA: Projects and Investment

LKPM Reconciliation for PT PMA in Bali: Investment, Assets and OSS Data

Key topics: LKPM reconciliation for PT PMA by project against the asset register and OSS data, with a focus on tracing actual investment.

For the complete framework, read PT PMA Tax Obligations: A Transaction Based Guide.

For the next step, read Quarterly LKPM for PT PMA: Preventing Double Counting of Cumulative Investment (Indonesian).

Support is available through business tax consultation.

LKPM reconciliation for PT PMA in Bali should not begin by copying a single figure from the general ledger or bank account into OSS. LKPM is an investment activity report for each project. Its figures must be traceable to actual investment, employment, business activities and business licensing data.

For a PT PMA developing hotels, villas, property, offices, machinery or equipment, or operating several projects in Bali, the main issue is usually more than calculating investment value. The company must ensure that OSS data, the asset register and the accounts describe the same transactions.

LKPM Reconciliation for PT PMA Requires More Than Copying Accounting Figures

The applicable reporting framework is Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025, which is in force and repeals Minister of Investment/Head of BKPM Regulations Nos. 3, 4 and 5 of 2021.

The licensing framework has also changed. Government Regulation No. 28 of 2025 took effect on 5 June 2025 and repealed Government Regulation No. 5 of 2021 on risk based business licensing.

Internal worksheets that still use older formats or legal references therefore need to be reviewed before use.

Start with the Project and Business Activity Number in OSS

Begin reconciliation with the project recorded in OSS, rather than the company’s total assets.

For each activity, list:

Business Identification Number (NIB)
Business Activity Number (Nomor Kegiatan Usaha or NKU)
Indonesian Standard Industrial Classification (KBLI)
project location
activity stage
planned investment recorded in OSS
actual investment previously reported
additional investment for the current period
cumulative investment
workforce

This project approach matters when one PT PMA has several KBLI classifications or locations in Bali. Assets belonging to project A should not be combined with project B merely to make total LKPM investment equal total company assets.

Separate Additional Investment from Cumulative Investment

For the preparation stage, the official instructions in Annex XXVII distinguish investment added in the reporting quarter, including previously unreported investment from earlier periods, from the cumulative amount since the first LKPM.

These two figures must not be confused.

If an asset was already reported in Quarter II, the same value must not be entered again as additional investment in Quarter III. It remains part of cumulative investment, but it is not a new addition in the current period.

Who Files LKPM and When?

Article 286 of the regulation requires medium and large businesses to file quarterly and small businesses every six months, subject to the applicable scope and exemptions.

For medium and large businesses, the Quarter III deadline is 15 October of the relevant year.

For the 2026 period, an official government announcement confirmed that Quarter III 2026 LKPM filing through OSS ran from 1 to 15 October 2026.

Thus, on the source article’s reference date of 5 October 2026, companies subject to quarterly reporting were within the Quarter III filing window. That historical window has now closed; check the applicable reporting period before preparing a new submission.

Which Data Needs to Be Reconciled?

LKPM contains more than investment figures. Regulation No. 5 of 2025 also covers employment, production of goods or services, basic requirements and licensing, business obligations and difficulties encountered.

Within the company, the data can be drawn from several sources:

LKPM data	Internal sources to examine
Actual investment	Asset register, general ledger, invoices, contracts and acquisition evidence
Project location	OSS, NIB, project documents and asset records
Workforce	HR data and payroll records
Activity stage	Actual project conditions and OSS data
Production or activities	Operational reports appropriate to the business
Business difficulties	Project records and implementation conditions

The aim is not to make every document show an identical figure. It is to ensure that each LKPM amount has a consistent explanation and supporting evidence.

Reconcile Fixed Assets with Actual Investment

A common mistake is to use cash paid during the quarter as the investment figure without examining the assets actually acquired.

For preparation stage assets, the LKPM instructions use original acquisition cost, including associated acquisition costs, for fixed capital investment.

Prepare a worksheet with at least these columns:

asset name
project/Business Activity Number
acquisition date
acquisition cost
invoice or contract number
general ledger account
amount previously reported
additional amount for the current period
reconciliation status

Do not equate book value after depreciation with actual investment without a proper basis. LKPM serves an investment reporting purpose, while financial statements have a different accounting function.

The Preparation and Operational Stages Are Different

For medium and large businesses, the rules distinguish preparation stage LKPM for activities that are not yet operational or conducting commercial transactions from operational or commercial stage LKPM for activities ready for, or already conducting, commercial operations.

This distinction matters because a company constructing a hotel does not have the same investment pattern as a hotel already in operation.

During construction, attention may centre on land, buildings, machinery, equipment and project assets. Once operations begin, additional investment, production or service activities, workforce and licensing status must be considered according to the company’s actual circumstances.

Do not change the stage merely to make LKPM figures appear consistent with the accounts. Ensure that the business status in OSS reflects reality.

Example LKPM Reconciliation Worksheet

The following is a simple example for one PT PMA project. The “xxx” entries are placeholders for the company’s actual figures.

Component	OSS/LKPM data	General ledger/asset register	Difference	Action
Land and site preparation	xxx	xxx	xxx	Trace the documents
Buildings/renovations	xxx	xxx	xxx	Match invoices and projects
Machinery/equipment	xxx	xxx	xxx	Match the asset register
Other fixed assets	xxx	xxx	xxx	Check classification
Cumulative investment	xxx	xxx	xxx	Match earlier reports
Workforce	xxx	xxx	xxx	Match HR data

This worksheet is not an official OSS form. Its purpose is to prevent the company from entering figures without a supporting trail.

Common Reasons LKPM Data Does Not Match

Before submission, check for these conditions:

the same asset reported twice in two quarters
an advance payment treated as the entire investment value without analysis
assets from another project entered under the wrong Business Activity Number
cumulative investment inconsistent with the preceding LKPM
new assets added to the register but not mapped to a project
project locations in OSS differing from asset records
workforce numbers inconsistent with HR records
a project already operating without review of its reporting stage
company information changes not yet updated in OSS
reported figures based solely on the bank balance

If a difference exists, do not immediately alter the accounts to match OSS. First determine which source is incorrect or has not been updated.

Documents to Prepare

For LKPM reconciliation for PT PMA in Bali, prepare at least:

NIB and OSS data
a list of Business Activity Numbers
KBLI classifications and project locations
LKPM from previous periods
the fixed asset register
general ledgers for asset and project accounts
purchase invoices and contracts
payment evidence
relevant land or building documents
construction or project reports
workforce data
operational reports if the company is already commercial
a list of business licensing changes

If the company has several projects, use separate worksheets for each activity and location before combining them for company level control.

When Is Reconciliation Support Needed?

A deeper reconciliation is relevant when financial statement asset values cannot be explained against previous LKPM, the company has several projects or KBLI classifications, the location or business stage changes, or the reporting period for additional investment is unclear.

In these circumstances, accounting support can focus on preparing asset registers, mapping accounts, reconciling transactions and creating worksheets so the data used for LKPM has a consistent basis.

Accounting assistance does not replace decisions or verification by OSS or the investment authorities.

Conclusion

LKPM reconciliation for PT PMA in Bali should begin with projects and OSS data, then trace these to investment evidence and the accounts.

Medium and large businesses file quarterly. The Quarter III 2026 filing window ran until 15 October 2026.

Use the sequence OSS/Business Activity Number → asset register → general ledger → acquisition evidence → quarterly additional investment → cumulative LKPM investment → workforce and activity status.

This reconciliation helps reduce double counting, allocation to the wrong project and differences discovered only after submission.

Does Your LKPM Data Differ from the Asset Register and Accounts?

If a PT PMA has several Bali projects, new assets, ongoing construction or differences between earlier LKPM and the general ledger, reconcile the records before finalising the next period’s figures.

Usman Tax provides accounting support to organise asset registers, transaction mapping and reconciliation worksheets. Discuss the relevant needs through tax consultation.

To continue the review, read about PT PMA tax calendars and document control so the documents and next steps address the issue under discussion.

Read Also: Business Tax Administration in Bali: Records, Reporting and Document Controls

Prepare relevant documents before discussing your needs through tax consultation with Usman Tax.

If investment reporting data differs from company documents or business activities, read about checking NIB documents and business details in OSS (Indonesian) through Jasa Legal ID to prepare for administrative coordination.

FAQ LKPM Reconciliation for PT PMA

When Was Quarter III 2026 LKPM Due for PT PMA?

For medium and large businesses, Quarter III LKPM is due by 15 October. For 2026, the government announced an OSS filing window of 1–15 October 2026.

Is LKPM the Same as a Tax Return?

No. LKPM reports investment activities through OSS. Accounting data can support reconciliation, but LKPM has a different purpose from a tax return.

Does LKPM Investment Equal Total Balance Sheet Assets?

Not automatically. Read the figures by project, activity stage, reporting period and LKPM instructions. Use the asset register and general ledger as reconciliation evidence rather than copying them without mapping.

What Is the Difference Between Additional and Cumulative Investment?

Additional investment covers investment in the reporting period and earlier investment not yet reported, as permitted by the instructions. Cumulative investment is the total since the first LKPM up to the latest period.

Does Every PT PMA File LKPM Quarterly?

Frequency depends, among other things, on business scale and the applicable exemptions. Regulation No. 5 of 2025 prescribes quarterly reports for medium and large businesses and six monthly reports for small businesses.

Does LKPM Include Workforce Data?

Yes. LKPM covers actual investment, employment, production of goods or services, licensing, obligations and business difficulties, among other information.

Can Usman Tax Guarantee OSS Acceptance?

No such guarantee is offered. On this page, Usman Tax provides accounting and data reconciliation support. Decisions, verification and report status remain with the system and competent authorities.

Sources and References

Status of Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025 — JDIH BKPM
Official regulation and LKPM forms, including Article 286 and Annex XXVII — JDIH BKPM
Government Regulation on Risk Based Business Licensing — JDIH BPK
Quarter III 2026 LKPM Filing Period — Banyumas DPMPTSP