Summary
Kring Pajak, the contact center of Indonesia's Directorate General of Taxes (DJP), confirmed on Wednesday, 20 May 2026 that VAT-registered entrepreneurs (Pengusaha Kena Pajak or PKP) may issue aggregated tax invoices (faktur pajak digunggung) when buyers qualify as end consumers. The clarification responded to a healthcare service operator asking whether end-user customers qualified for the simplified format.
Technical rules for aggregated tax invoices sit in Articles 51 through 55 of Director General of Taxes Regulation Number PER-11/PJ/2025. PKP whose transactions do not meet end-consumer characteristics must still issue full per-transaction tax invoices under the regular mechanism.
Core of the Clarification
Through an official social media post on Wednesday, 20 May 2026, Kring Pajak stated: if the buyer is an end consumer meeting the criteria in Article 51 paragraph (2) of PER-11/PJ/2025, then the PKP may report the tax invoice on an aggregated basis. The statement closes confusion among business operators dealing directly with end users.
Conversely, if buyers do not meet end-consumer criteria, PKP must issue a complete tax invoice for each sale. Format and content rules for regular tax invoices follow the general standard applicable to non-retail PKP.
Legal Roots of Aggregated Tax Invoices
The term faktur pajak digunggung does not appear explicitly in the VAT Law (Undang-Undang Pajak Pertambahan Nilai). The concept emerged as a replacement for the simplified tax invoice that was abolished by Law Number 42 of 2009 amending the VAT Law for the third time.
Before the abolition, Article 13 paragraph (7) of Law Number 18 of 2000 allowed PKP to issue simplified tax invoices for taxable goods (BKP) or taxable services (JKP) delivered directly to end consumers, or to buyers whose name, address, or NPWP could not be identified.
Although the term was removed, Article 14 paragraph (1) of the Law on General Provisions and Procedures of Taxation (UU KUP) continues to allow Retail PKP (PKP Pedagang Eceran or PKP PE) to issue tax invoices without buyer identity, name, or signature. This practice is now known as faktur pajak digunggung.
Who Counts as an End Consumer
Article 51 paragraph (2) of PER-11/PJ/2025 defines end consumers as buyers who consume the BKP or JKP directly, do not use the items for further business activity, and typically do not require full tax invoices for input-tax crediting.
Examples of end consumers include clinic or hospital patients paying medical services personally, retail buyers in mini-markets, restaurant customers, or buyers of household consumption goods. PKP serving such end consumers may use aggregated tax invoices.
Operational Implications for PKP
Aggregated tax invoices are reported in the periodic VAT return (SPT Masa PPN) without per-transaction breakdown. PKP only needs to report the total delivery value and collected VAT on a single reporting line. The mechanism cuts administrative time for high-volume operators such as mini-markets, clinics, restaurants, and retail shops.
That said, PKP must still keep internal supporting documents. If DJP later assesses that a buyer was not actually an end consumer, the PKP risks being required to issue retroactive tax invoices plus administrative penalties under Article 14 of UU KUP.
Practical Checklist
PKP should take three steps before adopting aggregated tax invoices. First, identify the buyer profile: end consumer, or another taxpayer needing the invoice for input-tax crediting. Second, document every transaction through a cashier system or internal record that can be audited. Third, read Articles 51 through 55 of PER-11/PJ/2025 in full to ensure formal compliance.
Kring Pajak provides official consultation channels through telephone and social media for PKP needing case-by-case clarification.
Sources
- Articles 51 through 55 of PER-11/PJ/2025 on Tax Invoice Issuance Procedures.
- Article 14 paragraph (1) of the Law on General Provisions and Procedures of Taxation.
- Official Kring Pajak statement via social media, 20 May 2026.