Summary
Indonesia's Finance Minister Purbaya Yudhi Sadewa signed Minister of Finance Regulation Number 111 of 2025 (PMK 111/2025) on the procedures for supervising taxpayer compliance. Effective 1 January 2026, the regulation reorganizes the Directorate General of Taxes (DGT) supervision framework into three layers and clarifies taxpayer rights when receiving a Request for Data and Information Explanation Letter (SP2DK).
Three Supervision Categories Under PMK 111/2025
PMK 111/2025 states that taxpayer supervision is based on the analysis of data and information held by the DGT. Supervision is grouped into three categories.
First, supervision of registered taxpayers. This covers reporting of business activity locations to obtain NITKU, business registration for VAT-able entrepreneur (PKP) status, registration of PBB-P5L (rural-urban land and building tax for plantation, forestry, mining, oil and gas, geothermal, mineral and coal sectors) tax objects, tax return (SPT) filing, tax payment and remittance, tax withholding and collection, and bookkeeping or record-keeping obligations.
Second, supervision of unregistered taxpayers. The DGT monitors NPWP registration or activation of the National Identity Number (NIK) as NPWP, NITKU reporting, PKP confirmation, PBB-P5L object registration, tax payment, and SPT filing.
Third, territorial supervision. This means monitoring economic activities and identifying taxpayers within each tax office's working area, executed through field-level economic data collection.
SP2DK Now Reaches Unregistered Taxpayers
A notable shift in PMK 111/2025: an SP2DK can now be issued to both registered and unregistered taxpayers. Article 15(1) of PMK 111/2025 authorizes the DGT to issue an SP2DK to unregistered taxpayers as part of supervision. The recipient must respond within 14 days with one of two options: fulfill the underlying tax obligation, or submit a written explanation to the DGT.
This closes a long-standing gap. Previously, SP2DK letters in practice mostly targeted registered taxpayers. Now, individuals or entities identified as economically active but not yet holding an NPWP can also be pulled into a clarification process.
Right to Extend the Response Window by Seven Days
Article 6(1) of PMK 111/2025 grants taxpayers the right to extend their SP2DK response period by up to seven days. The extension is requested through a written notice to the issuing tax office (KPP). The right was not explicitly codified before, often placing taxpayers under time pressure.
Where PMK 111/2025 Sits in the Regulatory Map
PMK 111/2025 does not stand alone. It refers to PMK 81/2024 for supervision of PBB Tax Object Notification (SPOP) filing, and to PMK 136/2024 for global minimum tax (GloBE) compliance supervision. In other words, taxpayers within scope of GloBE rules follow that specialized regime, while PMK 111/2025 serves as the general umbrella for domestic compliance.
The preamble cites the goal as providing fairness and legal certainty for supervision, and developing compliance within the self-assessment system. This is in line with the DGT's reform direction: data-driven, rather than reactive, enforcement.
What Taxpayers Should Prepare
First, registered taxpayers should keep routine administrative obligations current: report NITKU when operating branches, register as PKP when turnover crosses the threshold, maintain orderly books. Second, unregistered taxpayers with real economic activity should proactively activate NIK as NPWP before an SP2DK arrives. Third, if an SP2DK has already been received, prepare a response with full supporting documents and submit a written extension request when 14 days is not enough.
Understanding the three-layer supervision structure matters because the DGT's data, now connected to ILAP partners and OJK's SLIK, will increasingly surface mismatches.
Sources
DDTCNews. "Awasi Kepatuhan Wajib Pajak, Purbaya Rilis Aturan Baru" (6 January 2026).
DDTCNews. "Ada PMK Baru Soal Pengawasan Kepatuhan Pajak, Begini Ruang Lingkupnya" (7 January 2026).