Directors of a Limited Liability Company (Perseroan Terbatas or PT) are bound by the company's articles of association and the provisions of Law No. 40 of 2007 on Limited Liability Companies. Acts exceeding that authority are classified as ultra vires, often surfacing in commercial practice as unlawful asset transfers or encumbrances that deplete the corporate estate prior to a court declaring the company bankrupt. Indonesian bankruptcy law offers the actio pauliana mechanism under Articles 41 to 47 of Law No. 37 of 2004 to annul debtor legal acts that prejudice creditors' rights. Nevertheless, the vast majority of actio pauliana claims filed since its enactment have reportedly been rejected by Commercial Courts, mainly due to evidentiary hurdles in establishing that the transaction was non-obligatory and known to harm creditors. This article examines the position of directors' ultra vires acts as a legal basis for filing actio pauliana in PT bankruptcy and clarifies the statutory basis of directors' personal liability under company law. Employing a normative legal research methodology combining a statutory approach, case approach, and conceptual approach, the analysis reveals that ultra vires acts conceptually satisfy the actio pauliana requirement of a non-obligatory act (tidak wajib dilakukan) and trigger personal director liability under Article 97(3) of the Company Law, reinforced by the statutory presumption of knowledge in affiliated-party transactions under Article 42 of Law No. 37 of 2004. However, ultra vires status alone does not automatically establish actual creditor detriment, requiring Commercial Courts to adopt a bifurcated evidentiary approach that separates formal documentary verification of ultra vires from the substantive evaluation of financial prejudice to creditors.