Minister of Finance Regulation No. 55 of 2026
The Indonesian minister of finance (MoF) has issued a new regulation, No. 55 of 2026 concerning Tax Consultants and Other Parties Acting as Taxpayers’ Attorneys (MoF Reg. 55/2026), dated July 22 2026 and effective from August 24 2026. This regulation revokes MoF Regulation No. 111/PMK.03/2014, as amended by MoF Regulation No. 175/PMK.01/2022.
MoF Reg. 55/2026 broadens the scope of regulation to cover not only tax consultants but also other parties acting as taxpayers’ attorneys. In addition, MoF Reg. 55/2026 introduces significant changes to the competency requirements, licensing framework, arrangements for tax consultant offices, supervisory mechanisms, and the provisions applicable to other parties acting as taxpayers’ attorneys.
Comparative matrix of major changes
Subject/topic | MoF Reg. 111/PMK.03/2014 in conjunction with MoF Reg. 175/PMK.01/2022 (previous provisions) | MoF Reg. 55 of 2026 (new provisions) |
Taxpayers’ attorney | Tax consultant | Tax consultant and any “other party” |
Competency requirements to become a tax consultant | General requirements: ● Indonesian citizen and domiciled in Indonesia; ● Is not bound by employment/office with the government/state and/or state-owned/regionally owned enterprises; ● Is of good conduct, as evidenced by a police clearance certificate (SKCK); ● Holds a taxpayer identification number (NPWP); ● Is a member of a registered tax consultant association; and ● Holds a tax consultant certificate. No minimum requirement of a bachelor's degree (S-1) is imposed at the licensing stage (a bachelor's/diploma-IV degree is only a prerequisite for sitting the Level B and C examinations – Article 12). Work experience requirement: ● Practical experience is only relevant for upgrading a licence; i.e., a minimum of 12 months from the date of the last practice licence decision. | General requirements: ● Indonesian citizen; has competency in taxation; has passed the tax consultant professional examination; ● Minimum education of a bachelor's degree (S-1) or equivalent; ● Has work experience corresponding to the licence classification; ● Holds a taxpayer identification number/population identification number that has been activated as a taxpayer identification number; ● Is not an employee/official of a government agency or state-owned/regionally owned enterprise; ● Has never been convicted of a criminal offence carrying a threatened penalty of five years’ imprisonment or more; ● Has never had a tax consultant licence revoked; is not under guardianship; and ● Satisfies requirements regarding family relationships with employees of the unit handling tax policy. Work experience requirement (new): ● Level B – minimum of one year, calculated cumulatively within the past three years; and ● Level C – minimum of two years, calculated cumulatively within the past three years. |
Expiry date | Has no expiry period (no renewal required). | Valid for three years from the date of issuance and is renewable by sitting a refresher examination; renewal may be filed one month before expiry at the earliest. |
Types of tax consultant services | Formulated in general terms: a tax consultant is entitled to provide consulting services in taxation within the limits of their level of expertise (Article 22) and is required to provide services in accordance with tax laws and regulations (Article 23, letter a). Details of the types of services are not regulated. | Expanded and detailed, including: ● Tax planning; ● Tax due diligence; ● Tax opinions or consultations; ● Assistance during tax audits or preliminary evidence examinations; ● Assistance during tax crime investigations; ● Assistance or representation in Tax Court disputes; ● Acting as a taxpayer’s attorney; ● Preparation of tax documents and administration; ● Other tax services in accordance with applicable laws and regulations; and ● Other services related to taxation. |
Tax consultant office | Licensing is not regulated. MoF Reg. 111/PMK.03/2014 only addresses tax consultants forming a partnership; i.e., the obligation to submit an annual report in the name of each individual consultant. | A tax consultant office is required to obtain a licence from the minister and may take the form of a sole proprietorship, civil partnership, general partnership (firma), or limited liability company, subject to requirements on the composition of founders, managers, and leadership (the leader must be a tax consultant). |
Other parties acting as taxpayers’ attorneys | Not regulated under this MoF regulation. | One of the important changes: other parties – being parties other than tax consultants and their family members – who obtain a certificate of registration and are appointed by the taxpayer as an attorney are specifically regulated. The rules adopt certain provisions applicable to tax consultants, covering classification based on competency, certificates of competence, certificates of registration, prohibitions in the provision of services, and suspension and revocation sanctions. A certificate of registration is valid for three years and ceases to be valid if the holder passes away or the holder’s certificate of competence ceases to be valid. |
Supervision of other parties | Not regulated under this MoF regulation. | The director general of taxes may conduct an examination of other parties where information indicates an alleged violation in the provision of services. The results of the examination may take the form of an administrative sanction and/or an order to fulfil certain obligations. Sanctions consist of suspension and revocation of the certificate of registration, and may be imposed non-sequentially. |
Transitional provisions | Article 31: tax consultants who already held a practice licence prior to the enactment of the regulation are required to re-register at the latest within six months; failing which, the practice licence will be revoked. The organisation of certification examinations is suspended until the P3SKP (Tax Consultant Certification Board) is established. Association registration commences six months from the effective date of the regulation. | Practice licences already issued under MoF Reg. 111/PMK.03/2014 in conjunction with MoF Reg. 175/PMK.01/2022 remain valid as tax consultant licences under MoF Reg. 55/2026 (with no re-registration obligation). Furthermore: ● Tax consultant associations already registered remain recognised; ● Sanctions imposed under the previous provisions remain valid until the sanction period ends; ● Existing tax consultant certificates may continue to be used as a certificate of competence for a maximum of two years from the date of issuance; and ● Certification by the P3SKP will be conducted up to December 31 2026 at the latest; the professional examination by the Tax Consultant Association will also be conducted up to December 31 2026. |
MoF Reg. 55/2026 fundamentally transforms the regulatory framework for the tax profession from one previously focused primarily on the licensing of individual tax consultants into a broader and more sustainable framework covering competency, professional examinations, professional development, tax consultant office governance, other parties acting as taxpayers’ attorneys, and supervision and reporting.
For tax consultants and tax consultant offices already in operation, the key changes requiring attention are:
The adjustment to the certificate of competence and professional examination mechanism;
The fulfilment of annual continuing professional education credit requirements;
Reporting obligations;
The implementation of a quality control system; and
The strengthening of compliance and conflict-of-interest requirements.
Postponement of the effective date of Article 22 withholding provisions for marketplaces
On August 5 2026, the Directorate General of Taxes (DGT) announced that the implementation of MoF Regulation No. 37 of 2025 concerning the Appointment of Other Parties as Income Tax Collectors and the Procedures for the Collection, Deposit, and Reporting of Income Tax Collected by Other Parties on Income Received or Earned by Domestic Merchants through Electronic Commerce Systems has been postponed until October 31 2026. Accordingly, the collection of Article 22 income tax (PPh 22) under the regulation will only take effect from November 1 2026.
The postponement is intended to support the government’s efforts to maintain public purchasing power amid current economic considerations, without altering the substance of the policy but solely deferring its effective date. In connection with the postponement, the previous decisions of the director general of taxes appointing marketplaces as PPh 22 collectors will be revoked and new appointments will be issued. Furthermore, any PPh 22 previously collected by marketplaces from domestic merchants under the previous appointments will be refunded by the respective marketplaces to the relevant domestic merchants. This information was conveyed by the director of tax education, services, and public relations, Inge Diana Rismawanti.
Coretax payment and tax refund procedures updated
The director general of taxes, Bimo Wijayanto, has issued Regulation No. PER-8/PJ/2026 to amend the provisions concerning tax payments and deposits, as well as refunds of tax overpayments, including the addition and adjustment of payment type codes. In addition, the issuance of this regulation is intended to implement some provisions of Article 465 of MoF Regulation No. 81 of 2024, as most recently amended by MoF Regulation No. 1 of 2026. The regulation was stipulated in Jakarta on July 28 2026 and became effective as of its stipulation date.
Comparative matrix of key provisions (articles and appendices)
Topic | PER-10/PJ/2024 (prior provisions) | PER-08/PJ/2026 (amended provisions) |
Billing code assistance service (Article 5) | The billing code creation assistance service was only created through DGT officers/employees. | Added options for billing code creation assistance via collecting agent officers and certain users (users) through a portal connected to the DGT billing system. |
Billing code validity period (Article 5) | Did not specifically include hourly duration within the article. | Explicitly clarifies that the billing code is valid for 336 hours (14 x 24 hours) since issuance. |
Billing code cancellation and creation of a new billing code (Article 5) | No stipulation on the taxpayer’s right to cancel the billing code. However, the taxpayer has the right to create a new billing code if the old billing code has expired. | Taxpayers have the right to cancel an unused or unexpired billing code. A new billing code can be created if the old billing code expires or is cancelled by the taxpayer. |
Scope of overbooking/book-entry transfer (Article 7) | Overbooking of payment types other than SPT/assessment covered income tax on transfer of land and/or building rights (PHTB) and stamp duty submission. | Expanded to cover sale and purchase binding agreement (PPJB) transactions for land and/or buildings along with amendments to issue the formal verification decision letter (SK Penelitian Formal), as well as advance payment of stamp duty. |
Non-qualifying tax refund for overbooking (Article 7) | Did not specifically provide clarification on refund request options in Article 7. | Adds Article 7, paragraphs 6 and 7: payments/deposits that do not meet overbooking criteria can apply for a refund of excess tax paid that should not be due. |
Taxpayer identity on SSP (tax payment slip) form (Appendix A) | Payer/depositor identity was filled in using NPWP. | Accommodates the input of NPWP, NIK (national identification number), or other tax identification numbers. |
NOP (tax object number) and tax object address entries on SSP (Appendix A) | Filled in for land/building transactions such as PBB, PHTB, land/building rental, and self-building activities. | Expanded to cover PPJB transactions for land and/or buildings along with their amendments. |
Validation of payment recipient on SSP (Appendix A) | Signed and validated by officers of the payment receiving office. | Adds the phrase: “officers of the Payment Receiving Office or Collecting Agent”. |
CARF self-certification requirements for crypto-asset providers
Through Announcement No. PENG-5/PJ/2026, issued on August 10 2026, the director general of taxes has clarified the obligation to obtain a valid self-certification form in implementing provisions on access to financial information for taxation purposes under the Crypto-Asset Reporting Framework (CARF). Based on Article 2, paragraph (4) of Government Regulation in Lieu of Law No. 1 of 2017 concerning Access to Financial Information for Taxation Purposes, as enacted into law under Law No. 9 of 2017, and Article 31, letter g of MoF Regulation No. 108 of 2025 (PMK-108/2025), the director general of taxes is authorised to obtain access to financial information, while crypto-asset service providers (PJAKs) reporting under the CARF are required to automatically submit financial account information reports containing relevant crypto-asset information and to conduct financial account due diligence procedures in accordance with the CARF requirements.
In conducting due diligence procedures upon the opening of a crypto-asset user account, a reporting PJAK is required to:
Obtain a valid self-certification from the prospective user as a document separate from the account opening documentation;
Verify the reasonableness and validity of such self-certification based on information obtained or maintained in connection with the account opening, including documentation collected pursuant to anti-money laundering and/or know-your-customer procedures; and
Determine the tax residence of the crypto-asset user based on the valid self-certification and the results of the reasonableness verification.
In addition, a reporting PJAK is required to maintain and retain documentation, including the valid self-certification, which must be duly signed or otherwise validly affirmed by the crypto-asset user or its duly authorised representative, dated no later than the date on which the self-certification is obtained, and contain the information required under Article 26, paragraph 2, letter c of PMK-108/2025.
As part of the financial account identification procedures, PMK-108/2025 also provides sample self-certification forms that may be used by reporting PJAKs for prospective crypto-asset users who are individuals, entities, or controlling persons, where the user is an entity other than an active entity or an excluded entity. This provision was issued by the director general of taxes.
