Post-setup authority closure
PT PMA Power of Attorney Revocation and Handover After Setup
After incorporation, broad setup authority should be reviewed, revoked or narrowed, notified, removed from systems and closed with a verified document and credential handover.
A PT PMA should not leave a broad setup power of attorney active after the authorised incorporation work is complete. First inventory the instrument's grantor, attorney, scope, substitution rights, term, governing language, notarisation and every act already performed under it. Then obtain Indonesian legal advice on the effective revocation method, deliver provable notice to the attorney and relevant notary, provider, bank or authority where needed, remove related portal and email access, recover originals and filed data, and confirm pending submissions and deadlines. Revocation on paper does not by itself recover credentials or alert a third party that still relies on an earlier copy. Conversely, changing passwords does not terminate legal authority. Close both layers through a signed handover and residual-authority certificate, and issue a new narrow power only for any specifically identified unfinished task.
Four layers of authority closure
Treat legal authority, third-party reliance, digital access and physical custody as separate workstreams that must all reach closure.
Instrument
Scope and revocation
Read the signed power, substitutions, term and formal termination requirements.
Notice
Attorney and relying parties
Deliver evidence of revocation to people and institutions using the authority.
Access
Email and portal control
Reset recovery, remove users and preserve submissions before access changes.
Custody
Originals and open matters
Recover documents, receipts, registers and a dated pending-action list.
Evidence basis: Law No. 40 of 2007 on Limited Liability Companies · Official OSS guidance library
Key takeaways
- Review the actual signed power; do not rely on the provider's description of it.
- Preserve a schedule of acts completed under the authority before revocation.
- Use legally effective notice and retain proof of delivery.
- Close digital access and document custody in parallel with legal authority.
- Replace broad authority with a narrow, time-limited task power only when necessary.
Map the old power before revocation
Identify scope, substitutes, completed acts, relying parties, accounts and originals from the signed instrument.
A setup power may cover notarial signing, AHU or OSS submissions, tax registration, address services or document collection. Compare it with the original remote-setup authority plan and mark which purpose has ended. A clause allowing substitution requires particular attention because another person may hold delegated authority.
The company should avoid backdating a revocation or pretending earlier lawful acts never occurred. Preserve the historical chain, then establish a clear cut-off for future instructions. If an unauthorised or disputed act is discovered, obtain legal advice on the specific correction and notification instead of making a blanket portal change.
Map the signed authority and every act already taken
A reliable revocation starts with the document, not a generic template. Identify the legal and operational footprint before closing it.
Signed copy unavailable
the company has only an unsigned draft or translated summary The evidence that matters is executed original or certified copy, notarisation and language version. obtain and compare the controlling instrument If that control is skipped, the company revokes authority different from what was granted.
Scope described broadly
The warning sign appears when the power authorises all setup acts without a deliverable or end date. Verify it with clause-by-clause authority matrix and completed-task list. The responsible person should identify which powers remain capable of use; otherwise, residual authority survives the commercial engagement.
Substitution not traced
Treat the attorney may delegate but no list of substitutes exists as a decision gate, not an administrative detail. Keep delegation instruments, notary and provider records and submission users in the transaction file, then identify and notify every known delegate. This reduces the chance that a substitute continues acting after the principal relationship ends.
Acts not reconciled
A reliable check starts with submission history, notarial files, receipts and provider work log. It should resolve whether deeds or filings were made but the company cannot connect them to the power. Where the records do not reconcile, approve a historical act register; proceeding without that step can mean later corrections dispute legitimate or unauthorised acts indiscriminately.
Make revocation effective in law and visible to relying parties
The appropriate form and notice depend on the instrument and act. Obtain current Indonesian advice and create a dated evidence trail.
Email-only cancellation
The warning sign appears when a casual message is sent despite formal notice or notarial needs. Verify it with revocation advice, signed instrument and delivery evidence. The responsible person should use the required form and service method; otherwise, the attorney or third party disputes effective notice.
Relying party not told
Treat a notary, bank, provider or authority still holds the prior power as a decision gate, not an administrative detail. Keep reliance-party list and acknowledgement of notice in the transaction file, then notify each relevant party and request record update. This reduces the chance that a third party accepts an instruction under the old authority.
No cut-off timestamp
A reliable check starts with effective date and time, open cases and written transition instruction. It should resolve whether pending and future instructions cannot be separated. Where the records do not reconcile, state the cut-off and treatment of pending acts; proceeding without that step can mean both old and new representatives act on the same matter.
New power too broad
the replacement repeats all authority for one unfinished filing The evidence that matters is task, system, document, deadline and no-substitution requirement. issue a narrow time-limited instrument If that control is skipped, the closure recreates the original exposure.
Coordinate notice and access closure
Plan legal revocation, third-party notice, credential transfer and document recovery around one cut-off.
Close access, custody and pending work after revocation
Legal revocation and operational handover should be tested together. The company must be able to continue without the former attorney.
Portal history lost
Treat passwords are reset before applications and notices are exported as a decision gate, not an administrative detail. Keep OSS, tax, email and other submission archives in the transaction file, then preserve the full status before removing access. This reduces the chance that the company cannot reconstruct pending obligations.
Recovery channel unchanged
A reliable check starts with account settings, domain control and authorised-user resolution. It should resolve whether the former provider remains the recovery email or phone. Where the records do not reconcile, transfer primary recovery to the company; proceeding without that step can mean the old attorney can regain access.
Originals incomplete
deeds, resolutions, registers, receipts or shareholder documents are missing The evidence that matters is signed handover inventory and custody record. recover or lawfully replace each item If that control is skipped, bank, tax and amendment work is delayed.
Residual authority untested
The warning sign appears when the company assumes closure without checking users, mandates and open submissions. Verify it with post-closure access test and residual-authority certificate. The responsible person should verify every institution and system at the cut-off; otherwise, authority or access survives unnoticed.
Corporate and OSS records relevant to authority closure
The Company Law and effective corporate documents establish company authority, while official OSS records show filings and users that may need operational closure. The signed power remains the starting document.
- Law No. 40 of 2007 on Limited Liability Companies : The Company Law, as amended, defines the roles and accountability of shareholders, directors and commissioners. Authority should be traced to the deed, shareholder or board decisions and valid delegations.
- Official OSS guidance library : The OSS portal publishes current procedural guides for new applications, changes and transition cases. A successful screen or downloaded NIB does not by itself prove that every activity-level requirement is fulfilled.
- OSS business-data change guide : The official guide distinguishes changes to entity data, location data, addresses, investment plans and business licensing. The correct route depends on the field and the status of the existing licence.
- Government Regulation No. 28 of 2025 : The current risk-based licensing framework covers basic requirements, business licences, supporting licences, OSS administration, supervision and sanctions; it revoked Government Regulation No. 5 of 2021.
Revocation form, timing and third-party effect depend on the wording, governing law, formalities and acts involved. This workflow does not replace Indonesian legal advice, particularly where an attorney disputes notice or a transaction has already been executed.
Close setup authority from a residual-power certificate
The certificate should list the revoked instrument, effective cut-off, notices and acknowledgements, known substitutes, completed acts, pending matters, active accounts, removed users, recovered originals and any new narrow authority. A director should approve the evidence after independent access testing.
Do not archive the setup file until no person can exercise or appear to exercise the old authority through an unnotified document, live mandate, portal user, recovery channel or retained original.
Certify that no residual power remains
Test systems, mandates, pending cases and custody after the handover is signed.
Frequently asked questions
Does a setup power of attorney end automatically after incorporation?
Only if its terms or applicable law produce that result. Review the signed instrument, scope and term; do not assume commercial completion automatically ends legal authority.
Is changing the OSS password enough to revoke the power?
No. Password control addresses digital access, while revocation addresses legal authority. Complete both and notify relevant relying parties where needed.
Should the revocation be notarised?
The required form depends on the original instrument, use and applicable law. Obtain Indonesian legal advice and follow the formal and notice method needed for effective revocation.
What happens to acts already signed under the power?
Preserve and review them individually. Revocation generally addresses future authority; it should not be backdated to erase historical acts. Seek advice for any disputed transaction.
Can a new provider receive another power of attorney?
Yes when a real task requires it, but use a narrow instrument identifying the act, documents, system, deadline, substitution rule and termination. Avoid recreating an unlimited setup mandate.
