New Regulation on Risk-Based Taxpayer Compliance Supervision

PMK-111/2025

The Ministry of Finance of the Republic of Indonesia has issued Minister of Finance Regulation Number 111 of 2025 (“PMK-111”) concerning Supervision of Taxpayer Compliance. This regulation serves as the principal legal basis for the DGT in conducting taxpayer compliance supervision outside the scope of formal tax audits, and also provides a clear guideline on the timeline for responding to Requests for Explanation of Data and/or Information (SP2DK). PMK-111 is intended to strengthen voluntary compliance within Indonesia’s self-assessment system by providing a structured and standardized supervision framework.

PMK-111 defines the scope of compliance supervision to include supervision of registered taxpayers, supervision of unregistered taxpayers, and territorial supervision. The regulation applies to a broad range of taxes administered by the DGT, including Income Tax, Value Added Tax, Luxury Goods Sales Tax, Stamp Duty, Land and Building Tax, Sales Tax, Carbon Tax, as well as other taxes in accordance with prevailing laws and regulations. As such, the regulation significantly expands the reach of administrative compliance monitoring across multiple tax types.

Under the regulation, taxpayers are required to submit a response to an SP2DK within 14 days. Taxpayers may request an extension of up to 7 additional days after the original deadline by submitting a written notice of extension to the relevant Tax Office. Explanations may be submitted through various media, including the Taxpayer Account, postal or courier services, direct submission during a field visit, submission to the issuing Tax Office or its supervised service units, and online media such as video conferences.

PMK-111 also authorizes the DGT to conduct data collection activities as part of compliance supervision, which may include observation of economic activities, interviews, geotagging of parcels or business locations, and image capture through on-site methods. Where an SP2DK process has been concluded, the DGT will issue a Notification Letter on the Progress of the Implementation of the Request for Explanation of Data and/or Information (SP3 P2DK). This regulation came into effect on 1 January 2026.