A New Era of Taxpayer Compliance Monitoring

The close of 2025 marks a pivotal milestone for the Ministry of Finance, particularly the Directorate General of Taxes (DGT). In December 2025, the government issued Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 111 of 2025 concerning the Taxpayer Compliance Monitoring. This regulation formally ushers in a new phase of tax supervision in Indonesia.

Before this regulation was introduced, taxpayer compliance monitoring was governed by lower-level instruments, such as the Director General of Taxes Regulations and Circular Letters, including SE05/PJ/2022, which outlined the monitoring of taxpayer compliance.

By elevating the legal basis to the level of a PMK, the government emphasizes the strategic importance of compliance monitoring within Indonesia’s self-assessment tax system. The regulation aims to strengthen compliance with tax laws while supporting more consistent and accountable supervisory practices.

Scope of PMK Number 111 of 2025

PMK Number 111 of 2025 comprises 30 articles organized into six chapters, covering the following areas:

1. Chapter 1: General Provisions
2. Chapter 2: Authority, Objectives, Scope, and Forms of Compliance Monitoring
3. Chapter 3: Monitoring Procedures
4. Chapter 4: Assignment of Account Representatives and/or DGT Officers
5. Chapter 5: Document Format
6. Chapter 6: Concluding Provisions

This framework suggests a more structured and measurable approach to taxpayer compliance monitoring.

Types of Taxpayer Compliance Monitoring

PMK Number 111 of 2025 classifies taxpayer compliance monitoring into three main types:

1. Monitoring of Registered Taxpayers

   This includes supervision of:

   1. tax return filings;
   2. land and building tax returns;
   3. tax payments;
   4. tax withholding and collection;
   5. bookkeeping practices; and

   6. other relevant tax aspects.

       

2. Monitoring of Unregistered Taxpayers

   This involves supervision of:

   1. tax identification number (nomor pokok wajib pajak/NPWP) registration;
   2. business reporting to confirm taxable entrepreneur (pengusaha kena pajak/PKP) status;
   3. registration of land and building tax objects;
   4. tax payments and deductions; and

   5. other tax oversight.

       

3. Regional Supervision

   This focuses on monitoring economic activities within specific jurisdictions and identifying taxpayers operating in each work area.

Forms of Taxpayer Compliance Monitoring

PMK Number 111 of 2025 sets out ten forms of compliance monitoring, including:

1. requests for explanation of data and/or information (surat permintaan penjelasan data dan/atau keterangan/SP2DK);
2. discussions with taxpayers;
3. invitations to attend meetings at the DGT, either offline or online;
4. field visits;
5. issuance of nudge letters;
6. issuance of warning letters;
7. requests for transfer pricing documentation;
8. collection of regional economic data;
9. issuance of supervision letters; and
10. supplementary monitoring activities in accordance with tax regulations.

Taxpayer Obligations During the Monitoring Process

In the course of compliance monitoring, taxpayers are required to:

1. provide responses to SP2DK;
2. attend meetings when formally invited by the DGT; and
3. allow the DGT to conduct visits, where applicable.

Responses to an SP2DK must be submitted within 14 working days of issuance or delivery. Taxpayers may request a time extension of up to seven additional working days after the deadline.

Invitations for Discussion by the DGT

If a taxpayer's response is deemed inaccurate, incomplete, or not submitted at all, the DGT may invite the taxpayer for offline or online discussions.

Such discussions can lead to 17 possible follow-up actions, including:

1. closure of the SP2DK;
2. data adjustments made ex officio;
3. revocation of an NPWP;
4. confirmation or revocation of PKP status; and
5. other administrative measures.

Nudge Letter and Warning Letter Issuance

Beyond SP2DK, compliance monitoring of registered taxpayers may also be conducted through nudge letters, which serve as reminders to encourage voluntary compliance. These letters may relate to:

1. PKP confirmation;
2. tax payments;
3. tax return filings;
4. current-year tax installments;
5. utilization of tax services and/or incentives; and
6. fulfillment of formal tax obligations.

Furthermore, where taxpayers fail to submit tax returns or meet their obligations by the prescribed deadlines, the DGT may issue warning letters. These warnings may lead to further actions, including discussions, field visits, or additional supervisory measures.

This marks the beginning of a new era in taxpayer compliance monitoring. If you need assistance with any tax issues, Ideatax is here to help.

Also Read:

https://ideatax.id/articles/annual-individual-income-tax-return-filing-via-coretax

https://ideatax.id/articles/decoding-the-new-delta-spt

https://ideatax.id/articles/pmk-1122025-updates-to-the-tax-treaty-implementation-procedures