PER-19/PJ/2025: Beware of Tax Invoice Access Deactivation

The Directorate General of Taxes (DGT) has issued Regulation Number PER-19/PJ/2025, which sets out the rules for deactivating access to the issuance of tax invoices for taxable entrepreneurs (pengusaha kena pajak/PKP) who fail to meet their tax obligations. This regulation is essential because it can directly disrupt business operations and affect overall tax compliance.

This regulation is grounded in Law of the Republic of Indonesia Number 8 of 1983 concerning Value-Added Tax and Luxury Goods Sales Tax, as amended by Law of the Republic of Indonesia Number 7 of 2021 concerning Harmonization of Tax Regulations, as well as Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 81 of 2024, as amended by PMK Number 54 of 2025.

What Does PER-19/PJ/2025 Regulate?

Broadly, the regulation authorizes the Director General of Taxes to deactivate a PKP’s tax invoice issuance access if the PKP fails to fulfill certain tax obligations.

PKP Access Deactivation Criteria

Tax invoice issuance access may be restricted if the PKP meets any of the following conditions:

1. Fails to withhold or collect taxes for mandatory tax types for three consecutive months.
2. Fails to submit the tax return for the fiscal year in which it is due.
3. Fails to submit the monthly VAT return for three consecutive months.
4. Fails to submit the monthly VAT return for six tax periods within one calendar year.
5. Fails to report withholding or collection slips for any applicable tax type for three consecutive months.

6. Has outstanding tax arrears of at least:

   1. IDR 250,000,000.00 (two hundred and fifty million rupiah) for taxpayers registered at a small tax office; or
   2. IDR 1,000,000,000.00 (one billion rupiah) for taxpayers registered at other types of tax offices.

   The arrears must have been formally notified and must not be under an approved installment arrangement.

PKP Clarification Process

A PKP whose issuance access has been deactivated may submit a clarification to the DGT through the tax office where they are registered. The clarification letter must include:

1. the number and date of the clarification letter or document;
2. the address, which must be the Head of the Tax Office where the taxpayer is registered;
3. the identity of the taxpayer, management, and/or responsible party;
4. an explanation of the clarification; and
5. a list of supporting documents.

Required Supporting Documents

The following documents must accompany the clarification letter:

1. Copies of withholding or collection slips for any tax obligations that should have been withheld or collected for three consecutive months;
2. Proof of submission of the income tax return;
3. Proof of submission of the monthly VAT return for three consecutive months;
4. Proof of submission of the monthly VAT return for six tax periods in one calendar year;
5. Proof of reporting withholding or collection slips for three consecutive months; and
6. Proof of payment of tax arrears or an approved installment or deferral letter.

Reactivating Access to Tax Invoice Issuance

Under PER-19/PJ/2025, the Director General of Taxes must conduct a review within five days of receiving the clarification letter from the Head of the Tax Office. The review may result in:

1. Clarification accepted, leading to the reactivation of tax invoice issuance access; or
2. Clarification rejected, if the PKP has not fulfilled all obligations or if the supporting documents are incomplete.

If the tax office does not issue a decision within five days, the clarification is deemed accepted, and the DGT must restore the PKP’s access.

Legal References

1. Law of the Republic of Indonesia Number 8 of 1983 jo. Law of the Republic of Indonesia Number 7 of 2021.
2. PMK Number 81 of 2024 jo. PMK Number 54 of 2025.
3. Director General Regulation Number PER-19/PJ/2025 concerning the Deactivation of Tax Invoice Issuance Access for Taxable Entrepreneurs Who Fail to Fulfill Their Obligations Under Tax Laws and Regulations.

To help PKP better understand the rules and what to expect, below are some frequently asked questions about tax invoice access deactivation.

1. Does deactivation happen automatically?

   Yes. The system will automatically deactivate access if the PKP meets any of the criteria listed in PER-19/PJ/2025.

2. How will a PKP know their access has been deactivated?

   Usually, PKP realizes this when they are unable to access the tax invoice issuance system. They may also receive notifications or official letters from the tax office.

3. If access is deactivated due to tax arrears, must the arrears be paid first?

   Yes. The arrears must be settled unless the PKP already has an approved installment or deferral arrangement.