New rules for tax representatives in Indonesia.
Indonesia has tightened the rules for taxpayer representatives with Minister of Finance Regulation No. 44 of 2026 (MoF 44), which took effect on 6 July 2026 and revokes MoF No. 229/2014. The regulation sets out who can act as a taxpayer proxy (Kuasa di Bidang Perpajakan) and how representatives exercise a taxpayer’s rights and meet their tax obligations.
MoF 44 defines who can act as a representative, the competency and registration each category involves and the transitional arrangements that apply until the end of 2026. It also introduces eligibility conditions for former Ministry of Finance personnel and clarifies how a Special Power of Attorney operates.
Who can act as a taxpayer representative?
Article 2 paragraph (2) of MoF 44 confirms that taxpayers can appoint a representative through a Special Power of Attorney (Surat Kuasa Khusus or SKK). Unlike the previous regulation, MoF 44 names three categories of person who can take on this role.
| Eligible person | Description |
|---|---|
| Tax consultant | An individual holding a valid tax consultant licence issued by the Ministry of Finance. |
| Other party | An individual other than a tax consultant or family member who holds the required tax competency and a valid Certificate of Registration (Surat Keterangan Terdaftar or SKT). |
| Family member | The spouse or a person related to the taxpayer by blood or marriage up to the second degree. |
Competency and registration requirements
One of the main changes in MoF 44 is a more structured set of competency requirements, which vary by the category of representative appointed. The regulation aims to confirm that anyone representing a taxpayer before the Indonesian Tax Office holds adequate tax knowledge and is recognised within the Directorate General of Taxes (DGT) administrative system.
| Category | Competency requirement | Administrative requirement |
|---|---|---|
| Tax consultant | Holds a valid tax consultant licence issued by the Ministry of Finance. | The licence is submitted or electronically integrated with the DGT system. |
| Other party | Holds a valid Certificate of Registration (SKT). | The SKT is submitted or electronically integrated with the DGT system. |
| Family member | Exempt from competency requirements. | Provides a copy of the Family Card if listed on the same card, or a Family Relationship Statement if registered under different cards. |
MoF 44 also restricts eligibility. A tax consultant or other party cannot act as a representative where the relevant licence or SKT has been suspended or revoked by the competent authority. Taxpayers can therefore verify the status of an appointed representative before granting a Special Power of Attorney.
Additional requirements for former Ministry of Finance personnel
MoF 44 introduces separate eligibility conditions for former Ministry of Finance personnel who want to act as representatives under the other party category. These conditions address potential conflicts of interest and support confidence in the tax administration system.
Retired civil servants
Former Ministry of Finance civil servants who have retired on reaching retirement age can act as representatives where they meet both of the following conditions:
- they were never subject to severe disciplinary sanctions during their service
- they have completed a five-year cooling-off period, calculated from the date of retirement
Civil servants who resigned before retirement age
Former civil servants who resigned before the mandatory retirement age qualify where they meet the following conditions:
- They were honourably discharged from the civil service.
- They were never subject to severe disciplinary sanctions during their service.
- They have completed a five-year cooling-off period, calculated from the effective termination date stated in the official termination decree.
Former government employees under employment agreements (PPPK)
Individuals who previously served as government employees under employment agreements (Pegawai Pemerintah dengan Perjanjian Kerja, PPPK) within the Ministry of Finance can also act as representatives where they meet the following conditions:
- They were never subject to severe disciplinary sanctions or dishonourably dismissed during their employment.
- They have completed a five-year cooling-off period, calculated from either the expiry date of their employment agreement or the effective termination date specified in the employment termination letter.
Registration with the DGT
Tax consultants and other parties are registered in the DGT administrative system before they can act as representatives. The registration requirement differs by category.
| Category | Registration requirement |
|---|---|
| Tax consultant | Submission or electronic integration of a valid tax consultant licence into the DGT system. |
| Other party | Submission or electronic integration of a valid Certificate of Registration (SKT) into the DGT system. |
Until this registration is complete, the DGT does not recognise the representative for the purpose of exercising taxpayer rights or fulfilling tax obligations.
The Special Power of Attorney
A representative can act on behalf of a taxpayer only after receiving a Special Power of Attorney (SKK) issued by the taxpayer. An electronic SKK is submitted through the Taxpayer Portal (Portal Wajib Pajak), while a paper-based SKK goes directly to the relevant Tax Office. Where the authority covers electronic fulfilment of tax obligations, the taxpayer also grants the representative access to the Taxpayer Portal.
To be valid, the SKK contains at least the following:
- The name, Tax Identification Number (NPWP) and signature of the taxpayer granting the authority
- The name, NPWP and signature of the appointed representative
- The representative’s status as a licensed tax consultant, other party or family member
- A clear description of the tax rights or obligations being delegated
- The validity period of the SKK
The SKK is also affixed with stamp duty under the prevailing Stamp Duty Law. Where the representative is a family member, it is supported by evidence of the family relationship, such as a copy of the Family Card (Kartu Keluarga) or an equivalent document.
The appointment of a representative ends on any of the following events:
- The validity period stated in the SKK expires
- The taxpayer revokes the appointment
- The representative’s tax consultant licence or SKT is suspended or revoked
- The representative is convicted of a tax-related or other criminal offence
Any Taxpayer Portal access granted to the representative also ends at that point.
To revoke an appointment, a taxpayer prepares a revocation letter in electronic or paper form and submits it to the DGT through the Taxpayer Portal or the relevant Tax Office. The revocation takes effect when the DGT receives the letter and does not apply retroactively.
Assignment letters
As under the previous regulation, a representative can appoint an employee or another individual to submit or collect tax documents to or from the DGT by issuing an Assignment Letter (Surat Penunjukan). MoF 44 adds an administrative step: the appointed person presents the Assignment Letter to the relevant DGT officer each time they submit or collect tax documents relating to the delegated rights or obligations.
Transitional provisions
MoF 44 includes transitional provisions to ease the move to the new requirements. Any Special Power of Attorney submitted before 6 July 2026 remains valid.
The regulation also allows individuals other than licensed tax consultants to continue acting as representatives until 31 December 2026 where they hold either:
- A tax brevet certificate
- A formal diploma in taxation of at least Diploma III level from an A-accredited public or private higher education institution
In these cases, the taxpayer submits a paper-based SKK, together with documentation evidencing the individual’s qualification, to the DGT through the relevant Tax Office. The appointment stays valid until the delegated tax rights or obligations have been fully carried out.
Conclusion
MoF 44 reshapes tax representation in Indonesia by defining who can act for a taxpayer, setting competency and registration requirements for each category and adding conditions for former Ministry of Finance personnel. It also formalises how the Special Power of Attorney and Assignment Letter operate and gives holders of a tax brevet certificate or qualifying diploma until 31 December 2026 to transition.
For taxpayers, the practical questions are whether an existing representative meets the new competency and registration criteria and whether current authorisations need updating before the transitional window closes. Advice from a tax specialist can help confirm that appointments remain valid and that the supporting documentation is in order.
