BANK AUTHORITY
PT PMA Bank Mandate Mismatch: Director Authority, Resolutions, and Tokens
A decision-led briefing on director authority and bank mandate mismatches, for foreign investors who need evidence they can verify before acting in Indonesia.
A director shown in AHU may still lack a usable bank mandate, while an old signatory may retain practical access after a corporate change. Corporate and bank records must be closed together. The safe sequence is to confirm the exact facts, identify the authority or institution that decides each stage, collect evidence in the form that recipient accepts, and assign corrections before money or authority moves. Founders should preserve the source data, official output, access credentials, payment trail, and change history so the company can demonstrate the basis for its decision later. The decision record should name the responsible owner and the evidence accepted for each unresolved condition.
Key takeaways
- A director shown in AHU may still lack a usable bank mandate, while an old signatory may retain practical access after a corporate change.
- Build the bank-mandate reconciliation from current official requirements and recipient-accepted evidence.
- Treat the bank-mandate reconciliation as incomplete until its corporate, regulatory, payment, and operating records agree.
- Keep official outputs, source data, payments, credentials, and unresolved conditions under company control.
Translate director authority into a bank-accepted mandate
Corporate authority and bank authority must be reconciled, not assumed. A bank can review the deed, AHU profile, board composition, resolutions, specimen signatures, UBOs, tax data, business purpose, and individual KYC before deciding who may open or operate the account. The current BCA corporate current-account requirements , for example, describe corporate representatives, powers of attorney, individual-customer data, and supporting documents; another bank may apply a different process. For the bank-mandate reconciliation, the immediate acceptance point is to identify accepted representatives against the documented current deed, AHU data, and board resolution.
Prepare a mandate matrix for account opening, transfers, beneficiaries, foreign exchange, loans, cards, cash-management platforms, token custody, limit changes, and closure. Compare single and joint signing, transaction limits, maker-checker roles, temporary powers, and revocation. The final bank forms and system setup should match the approved corporate resolution, and access should be tested before the company receives customer money or makes a material payment. Within the bank-mandate reconciliation file, the responsible officer should preserve signing rules, limits, maker-checker, and tokens as evidence for the decision to configure account access.
Verify the director authority and bank mandate mismatches before the next commitment
Turn the current facts, official checks, accepted evidence, open conditions, and responsible owners into one dated decision file.
Trace signing power from the deed to the specific transaction
A director's title does not answer every authority question. Start with the Indonesian Company Law , the articles of association, current AHU record, shareholders' or board resolutions, reserved matters, transaction thresholds, joint-signature rules, conflicts, and any lender, license, or shareholder-agreement condition. Then identify the legal act: an ordinary contract, property commitment, financing, guarantee, bank instruction, employment action, notarial deed, tax filing, OSS declaration, or delegated power can require different evidence. For the bank-mandate reconciliation, the immediate acceptance point is to match the transaction against the documented board or shareholder resolution and limits.
Prepare an authority certificate for material transactions that states the company, current directors, relevant constitutional clause, approval body, resolution date, signatory combination, financial limit, validity, and exclusions. Compare it with the counterparty's original or independently verified corporate documents. A specimen signature, business card, email, or possession of a company stamp is not enough. Where authority is delegated, inspect the power of attorney, authentication, substitution right, expiry, revocation, and whether the principal retained the power to grant it. Within the bank-mandate reconciliation file, the responsible officer should preserve signer, joint rules, and power of attorney as evidence for the decision to verify before commitment.
Authority chain
Constitution. Deed, AHU record, and reserved matters; use current corporate evidence.
Approval. Board or shareholder resolution and limits; match the transaction.
Execution. Signer, joint rules, and power of attorney; verify before commitment.
Sequence the director change across corporate and operating systems
A director change begins with eligibility, consent, the correct shareholder decision, notarial documentation, and submission through the current AHU framework under Minister of Law Regulation 49 of 2025 . The effective corporate date, AHU acceptance, and third-party recognition should be recorded separately. The outgoing director should not continue to sign merely because a bank, tax, or OSS profile has not yet been updated. For the bank-mandate reconciliation, the immediate acceptance point is to end obsolete access against the documented authority, credentials, assets, and notices.
Map every dependent record before the meeting: AHU, OSS responsible person and contacts, NIB and licenses, tax account, bank mandates and tokens, payroll, immigration and manpower approvals, contracts, e-signatures, email, government portals, insurance, litigation authority, accounting approvals, and physical assets. Use a controlled overlap where lawful, but assign a cut-off time for each power. Obtain handover certificates, revoke unused powers of attorney, and keep evidence that counterparties and institutions received the change. Within the bank-mandate reconciliation file, the responsible officer should preserve eligibility, consent, resolution, and deed as evidence for the decision to document the effective basis.
Director-change sequence
| Control | Evidence | Decision |
|---|---|---|
| Approve | Eligibility, consent, resolution, and deed | Document the effective basis |
| Update | AHU, OSS, tax, bank, licenses, and immigration | Track each institution |
| Cut over | Authority, credentials, assets, and notices | End obsolete access |
Resolve the open conditions in the bank-mandate reconciliation
Reconcile the corporate, regulatory, document, payment, and operating dependencies that can change the result for this company.
Prepare for the bank's independent KYC and account decision
A corporate bank account is not issued automatically because the PT PMA has an AHU approval, NPWP, or NIB. The bank independently assesses the company, beneficial owners, shareholders, directors, signatories, business purpose, licenses, address, contracts, expected transactions, currencies, source of funds and wealth, tax residence, sanctions and risk factors, and original-document or presence requirements. Criteria can differ by bank and branch. For the bank-mandate reconciliation, the immediate acceptance point is to use final outputs against the documented deed, AHU, tax, NIB, licenses, and address.
Build one KYC file that reconciles the executed deed, AHU corporate output , tax data, OSS licenses, UBO report, ownership chart, passports, corporate-shareholder documents, address evidence, business plan, contracts, and funding narrative. Ask the chosen bank for current requirements in writing, but preserve a fallback institution and visit plan. Before the first remittance, approve signatory combinations, online access, token custody, payment limits, beneficiary controls, accounting evidence, and how paid-up capital will be described and used. Within the bank-mandate reconciliation file, the responsible officer should preserve UBO, shareholders, directors, and signatories as evidence for the decision to complete KYC.
Closing conditions should include the bank KYC refresh after a shareholder change because bank recognition follows its own evidence and approval process.
Bank onboarding
Company
Deed, AHU, tax, NIB, licenses, and address
Use final outputsPeople
UBO, shareholders, directors, and signatories
Complete KYCAccount
Access, limits, funding, and evidence
Control before depositTake control of documents, credentials, and open obligations
A registration engagement is not complete until the company can operate without dependence on the provider's personal accounts or device. Handover should cover final documents, source data, credentials, registered email and phone details, authentication methods, originals, payment receipts, filing history, and unresolved obligations. Access should be tested by an authorized company officer. For the bank-mandate reconciliation, the immediate acceptance point is to transfer and test control against the documented OSS, tax, email, phone, and authentication.
Remote matters need an especially clear revocation and recovery plan. Reconcile the deed, AHU approval, tax record, NIB, licenses, shareholder register, beneficial-owner data, and bank application before acceptance. Record who holds each original, how each credential can be recovered, and when any power of attorney or temporary access must end. Within the bank-mandate reconciliation file, the responsible officer should preserve conditions, renewals, and corrections as evidence for the decision to assign owner and due date.
Align the corporate resolution, bank forms, system roles, and token custody
The approval decision for the bank-mandate reconciliation should name the selected route, responsible company officer, accepted source data, supporting documents, official outputs, payment limits, unresolved conditions, and the event that permits the next commitment. For director authority and bank mandate mismatches, a conditional result should remain a visible gate rather than being absorbed into a broad statement that setup is complete.
The founders or board should sign a short bank-mandate reconciliation mandate that records the current facts, authority, required corrections, evidence location, system and credential owners, review date, and first transaction that the company intends to perform. The working file should connect legal identity, ownership, governance, activity, capital, premises, licensing, tax, banking, immigration, and real conduct wherever those facts are relevant. Recheck current official and institution-specific requirements immediately before filing, funding, signing, employing, or operating.
Put the approved bank-mandate reconciliation under company control
Record the final route, authority, source documents, access, payment limits, handover, review date, and next operating trigger.
Frequently asked questions
What should be confirmed before approving the bank-mandate reconciliation?
Confirm the current official position, recipient-specific requirements, authority, source documents, and unresolved conditions for director authority and bank mandate mismatches. Record the approval and evidence before the company signs, pays, files, or operates.
Can founders use personal payments for company expenses?
Emergency payments need documented authority, business purpose, evidence, accounting treatment, tax review, and reimbursement; routine mixing weakens the company trail. For this bank-mandate reconciliation, record how that answer applies to director authority and bank mandate mismatches and preserve the evidence used.
Should equity and shareholder loans share one ledger account?
No. Their legal rights, approvals, bank narrative, tax, repayment, and reporting differ and should be classified from receipt. For this bank-mandate reconciliation, record how that answer applies to director authority and bank mandate mismatches and preserve the evidence used.
What evidence should support a monthly close?
Retain contracts, invoices, receipts, bank statements, payroll, tax calculations, payment evidence, filed returns, ledger reconciliation, approvals, and correction history. For this bank-mandate reconciliation, record how that answer applies to director authority and bank mandate mismatches and preserve the evidence used.
Can a bank or tax adviser guarantee acceptance?
No. Advisers can prepare and review evidence, while banks and authorities make independent decisions under their current procedures. For this bank-mandate reconciliation, record how that answer applies to director authority and bank mandate mismatches and preserve the evidence used.
Regulatory notes, official references, and review basis
Requirements affecting director authority and bank mandate mismatches were checked against the linked official or institution-specific materials on August 10, 2026. The responsible company officer should reconfirm the rule, system status, recipient requirements, and transitional conditions that apply on the actual filing, payment, signing, or operating date for the bank-mandate reconciliation.
- BCA corporate current-account requirements
- Indonesian Company Law — Law No. 40 of 2007 on Limited Liability Companies; Government of Indonesia; enacted, promulgated, and effective 16 August 2007; current with amendments as checked 10 August 2026.
- Minister of Law Regulation 49 of 2025 — Minister of Law Regulation No. 49 of 2025 on PT establishment, amendment, and dissolution procedures; Ministry of Law; established 11 December 2025, promulgated and effective 17 December 2025; in force as checked 10 August 2026.
- AHU corporate output