What is SP2DK
SP2DK stands for Surat Permintaan Penjelasan atas Data dan/atau Keterangan: a formal letter issued by Indonesia's Directorate General of Taxes (DGT) asking a taxpayer to clarify specific data or information the DGT holds but does not see reflected in the taxpayer's filings.
An SP2DK is not a sanction. It is a compliance-building tool inside the self-assessment system, giving the taxpayer a chance to respond before the DGT decides whether to escalate to an audit.
The DGT draws data from several streams: information exchange with ILAP partners (agencies, institutions, associations, and other parties), OJK's SLIK financial information system, counterparty e-Faktur (electronic tax invoice) data, and field-level territorial supervision.
Legal Basis
The post-reform foundation for SP2DK sits in Minister of Finance Regulation No. 111 of 2025 on the Procedures for Supervising Taxpayer Compliance. Key articles:
- Article 6(1): the taxpayer's right to extend the response window by up to seven days through written notice to the KPP.
- Article 15(1): the DGT's authority to issue an SP2DK to unregistered taxpayers.
Taxpayers within scope of the global minimum tax (GloBE) follow PMK 136/2024. Supervision of PBB Tax Object Notification (SPOP) filings follows PMK 81/2024. PMK 111/2025 is the general umbrella outside these two specialized regimes.
Law No. 6 of 1983 on General Provisions and Tax Procedures (UU KUP), most recently amended by Law No. 7 of 2021 (HPP Law), remains the parent of every formal taxpayer obligation that an SP2DK can test.
Supervision Categories and SP2DK
PMK 111/2025 splits compliance supervision into three categories with direct implications for SP2DK.
Registered Taxpayer Supervision
SP2DK targets formal obligations already in scope: SPT filing, payment, withholding, collection, bookkeeping, NITKU reporting, and PKP confirmation. A common trigger is bank turnover materially higher than income reported in the SPT.
Unregistered Taxpayer Supervision
This is the most significant shift under PMK 111/2025. The DGT can now issue an SP2DK to individuals or entities identified as economically active but without an NPWP, or who have not activated their NIK as NPWP. The goal is to nudge voluntary registration before escalation.
Territorial Supervision
Territorial supervision is pre-emptive. The DGT collects economic data in each working area and cross-references it with internal records. The outputs often become triggers for SP2DK on the first two categories.
Mechanism: How the DGT Issues an SP2DK
The process usually runs as follows:
- The DGT receives or analyzes data from ILAP, e-Faktur, SLIK, or territorial supervision.
- An Account Representative or Supervision Officer at the KPP investigates: external data is compared against internal taxpayer records.
- If a mismatch is found, the KPP issues an SP2DK that describes the data in question and states the response deadline.
- The SP2DK is delivered to the taxpayer's registered address or through electronic channels including Coretax.
How to Respond to an SP2DK
Once received, the taxpayer has 14 days and two response options:
Option 1: Fulfill the Obligation
If the DGT's data is correct, the taxpayer can simply act: pay the tax due, file an amended SPT, or register an NPWP. This closes the SP2DK without an audit.
Option 2: Submit a Written Explanation
If the data lacks context or requires clarification, the taxpayer prepares a written response with supporting evidence and submits it to the issuing KPP, either manually or through Coretax.
How to Request an Extension
Article 6(1) of PMK 111/2025 entitles the taxpayer to extend the response window by up to seven days. The process: submit a written extension notice to the issuing KPP before the original 14 days expire. Total time becomes 21 days.
Filing the Response via Coretax
Now that Coretax DGT is fully operational, SP2DK responses can be submitted digitally. The flow:
- Sign in to Coretax with NPWP or NIK and an electronic certificate (sertel) from a registered PSrE such as Privy, VIDA, Vinotek, or Xignature.
- Open the Supervision menu, then Received SP2DK List.
- Select the SP2DK, upload supporting documents, and enter the explanation.
- Sign electronically and submit. A receipt appears on the dashboard.
Taxpayers not yet active on Coretax can deliver written responses to the issuing KPP or send them by registered mail.
Case Examples
Case 1: SP2DK Over Turnover Mismatch
A laundry-business owner receives an SP2DK because the DGT's data shows 2025 cash deposits totaling Rp650 million, while the MSME Final PPh SPT only reports Rp380 million in turnover. After internal review, the owner finds that Rp270 million came from a family loan and e-commerce refunds, not turnover. A written response with transfer evidence and the loan contract is submitted via Coretax. The SP2DK closes without further action.
Case 2: SP2DK to an Unregistered Taxpayer
A freelance graphic designer receives an SP2DK at her ID card address because the DGT's data shows regular foreign-platform payments exceeding Rp80 million per year, while she has no NPWP. She chooses Option 1: activate her NIK as NPWP via Coretax, then file the 2025 individual annual return with the TK/0 personal allowance. The SP2DK closes.