Funding PT PMA Paid-Up Capital from Overseas: Timing, Remittance, and Evidence
A controlled route from foreign shareholder approval to the Indonesian company account, ledger, permitted use, and evidence file.
Foreign shareholders should fund PT PMA paid-up capital through a traceable, approved, and correctly described route that allows the Indonesian company, bank, accountant, and regulator to connect the remittance to the shares recorded in the deed. The general baseline under BKPM Regulation No. 5 of 2025 is IDR 2.5 billion in issued and paid-up capital per foreign investment company unless a higher rule applies. Funding mechanics still need to account for incorporation timing, account opening, currency conversion, sender identity, and the evidence accepted by the notary and bank.
Do not send money to an agent’s ordinary operating account merely because an invoice calls it “capital.” First approve the contribution, confirm the receiving route and purpose wording, and prepare the bank KYC pack. A PT PMA capital and setup review should also distinguish equity from shareholder loans, fees, reimbursements, and future project funding.
Approve
Subscription, payer, amount, currency, purpose, and authority.
Onboard
Company, UBO, signatory, source-of-funds, and business KYC.
Remit
Traceable bank transfer with controlled reference and FX record.
Record and use
Equity entry, evidence file, and permitted operating deployment.
Key takeaways
- Approve the share subscription, amount, payer, currency, and purpose before the remittance.
- Coordinate incorporation evidence and bank onboarding because a new company may not have an active account on the deed date.
- The sender, payment reference, bank documents, deed, shareholder register, and ledger should tell the same story.
- Record exchange-rate treatment and any difference between foreign currency sent and rupiah capital credited.
- Preserve evidence of permitted business use during the 12-month capital-proceeds period.
In this article
Approve the contribution before funds move
The shareholder and PT PMA records should identify the subscribing shareholder, share number or value, rupiah paid-up amount, funding currency, authorised payer, receiving account, purpose, and timing. A corporate shareholder should follow its own board, shareholder, treasury, exchange-control, and outbound-investment rules. An individual should document capacity and source of funds appropriate to the bank’s review.
If a group treasury company or another shareholder will pay on behalf of the subscriber, document that relationship and obtain Indonesian legal and accounting advice before transfer. Otherwise, the deed may show one shareholder while the bank statement shows an unrelated sender and the ledger records an undefined advance. Clarify whether the payment is equity, a loan, or another lawful item; do not decide after receipt.
- Final deed capital and cap table
- Shareholder or parent approval
- Authorised sender and receiving account
- Source-of-funds evidence
- Currency and exchange-rate policy
- Accounting and document owner
Coordinate legal paid-up status with practical account timing
The incorporation documents may state issued and paid-up capital before the company has completed bank onboarding. The legal evidence required at establishment and the later bank deposit trail should therefore be planned together with the notary and bank. Do not invent a deposit receipt from an account that did not exist or treat a future intention to fund as completed payment without proper advice and support.
Prepare the bank application as early as the company’s approved documents allow. Provide the deed, Ministry of Law approval, tax and OSS records, owners and UBOs, directors, premises, business model, expected transactions, and capital source. Ask how the bank wants the initial equity transfer described and which currency accounts or conversion documents will be available. Bank acceptance is institution-specific.
| Timing point | Evidence question | Control |
|---|---|---|
| Deed execution | What supports the paid-up statement? | Confirm notary-required form |
| Legal approval | Does the final capital table match? | Lock corporate records |
| Bank onboarding | Can owners, purpose, and source be verified? | Submit coherent KYC pack |
| Initial remittance | Does sender and reference match the subscription? | Retain transfer and FX evidence |
Use a remittance instruction the bank and accountant can read
The transfer instruction should identify the PT PMA, contributing shareholder, equity purpose, and relevant approval or subscription reference without using vague labels such as “consulting,” “investment service,” or “setup fee.” Confirm the beneficiary name and account directly with the bank-controlled channel. Use maker-checker controls at the shareholder and PT PMA, particularly for first-time high-value transfers.
Retain the debit advice, SWIFT or transfer message, beneficiary credit advice, account statement, conversion slip, fees, and any compliance correspondence. If the foreign currency amount converts to a rupiah value that differs from the deed amount, the accounting and corporate treatment of the difference should be agreed. Do not alter the deed number to match a fluctuating bank conversion without advice.
Sender
The subscribing shareholder or a documented authorised payer.
Beneficiary
The verified PT PMA account or another legally confirmed route.
Purpose
Paid-up capital or share subscription, not a service fee.
Evidence
Debit, message, credit, conversion, fees, and bank questions.
Book equity without mixing loans, fees, or revenue
The opening journal and shareholder subledger should connect the bank receipt to issued and paid-up shares. Reconcile the rupiah deed amount, foreign currency remittance, exchange rate, bank charges, and any excess or shortfall. A shareholder loan needs separate approval, agreement, account, interest and tax analysis where applicable; it should not be recorded as equity merely to close a reconciliation difference.
Setup invoices paid by a shareholder can be company expenses, reimbursements, advances, or capital-related transactions depending on the facts, but they are not automatically paid-up share capital. Ask the accountant to prepare an opening-balance pack with the deed, bank evidence, shareholder schedule, invoices, and classification memo. This pack supports future audit, tax, bank, and LKPM questions.
| Receipt or payment | Possible classification | Required support |
|---|---|---|
| Share subscription receipt | Paid-up equity | Deed, approval, remittance, register |
| Separate shareholder funding | Loan or advance | Agreement, approval, tax and FX support |
| Agent or notary invoice | Professional or setup cost | Contract, invoice, receipt, deliverable |
| Customer payment | Revenue or deposit | Customer contract, invoice, tax support |
Control use of paid-up capital proceeds during the first 12 months
BKPM Regulation No. 5 of 2025 restricts transfers of issued and paid-up capital proceeds from the company account for at least 12 months from payment, while allowing use for asset acquisition, building construction, and company operations. Read this as a purpose-and-evidence control, not as a demand to freeze every rupiah. Payments should be genuine company expenditures and traceable through approvals, contracts, invoices, and books.
Avoid transfers back to shareholders, unexplained intercompany sweeps, personal expenses, cash withdrawals without support, or agent-controlled onward payments. Establish payment categories, approval thresholds, related-party review, and a monthly capital-use reconciliation. If the company needs to move funds between its own accounts, use foreign currency, place deposits, or undertake an unusual transaction, confirm treatment with the bank and adviser first.
- Approved asset, construction, or operating purpose
- Contract, invoice, and beneficiary verification
- Director and payment approval
- Bank and accounting record
- Related-party and personal-use screen
- Monthly restricted-period reconciliation
Assemble one capital evidence file for four audiences
The corporate file needs the deed, shareholder approval, register, and evidence supporting paid-up status. The bank file needs the owners, source, sender, purpose, receipt, and use. The accounting file needs the rupiah entry, FX treatment, supporting documents, and reconciliation. The investment-reporting file needs the relationship between funding, assets or operations, OSS plan, and realised investment.
Index the file by event and keep original electronic bank messages. A one-page bridge should show the subscribed amount, amount remitted, amount credited, exchange difference, payments made, closing balance, and supporting references. The capital proof guide for bank opening can be used to prepare the bank-facing portion without confusing it with the full corporate and reporting record.
Corporate
Shares, approvals, register, and paid-up support.
Bank
KYC, source, remittance, receipt, and permitted-use evidence.
Accounting
Equity ledger, FX, fees, reconciliation, and statements.
Investment reporting
Funding, project deployment, and realisation bridge.
Official references and review basis
Primary materials checked on July 25, 2026. The cited rules should be read together with the current five-digit KBLI, OSS output, and any sector-specific regulation applicable to the proposed activity.
Final decision
Overseas capital funding should be designed before the transfer. Approve the subscription, coordinate legal and bank timing, use a clear remittance purpose, preserve every bank record, book the equity correctly, and control the use of proceeds during the first 12 months.
The result is not just proof that money moved. It is a chain showing who owed the contribution, who paid, what the company received, how it was recorded, and why later payments were legitimate company use.
Frequently asked questions