Simplifying International CRS
Reporting via SiPINA

The global commitment to cross-border financial transparency marks the end of unchecked banking secrecy. Following offshore tax evasion cases worldwide, nations agreed to build an automated framework known as the Automatic Exchange of Information (AEOI).

Indonesia actively participates in this initiative through Government Regulation in Lieu of Law of the Republic of Indonesia Number 1 of 2017, later enacted as Law of the Republic of Indonesia Number 9 of 2017 concerning Financial Information Access for Tax Purposes. Under this legislation, financial institutions in Indonesia are legally bound to report foreign account holder data to tax authorities as part of the country’s international commitment.

Developed by the Organisation for Economic Co-operation and Development (OECD) at the request of G20 nations and approved on July 15, 2014, the Common Reporting Standard (CRS) mandates participating jurisdictions to collect financial account data from local institutions and automatically exchange it annually with partner countries where account holders owe tax obligations. CRS defines reportable account types, reporting financial institution categories, account holder classifications, and the mandatory due diligence procedures required before reporting.

CRS Legal Basis in Indonesia

Indonesia continuously updates its domestic legal system to align with evolving global standards. Alongside Law of the Republic of Indonesia Number 9 of 2017, technical compliance is governed by:

• Minister of Finance Regulation Number 70/PMK.03/2017 concerning Technical Guidelines for Financial Information Access for Tax Purposes, as amended by Minister of Finance Regulation Number 108 of 2025.
• Director General of Taxes Regulation Number PER-04/PJ/2018 concerning Registration Procedures for Financial Institutions and Automatic Submission of Financial Information Reports, as amended by PER-7/PJ/2024.

The Directorate General of Taxes (DGT) has also signaled further regulatory updates through Announcement Number PENG-3/PJ/2025 to incorporate the OECD’s Amended CRS. Given these ongoing changes, reporting institutions must regularly review their CRS compliance procedures.

How CRS Reporting Works in Indonesia

In Indonesia, CRS reporting follows two main pathways based on the supervisory authority overseeing the institution:

1. Financial Service Institutions (Lembaga Jasa Keuangan/LJK) supervised by the Financial Services Authority (Otoritas Jasa Keuangan/OJK), such as banks, securities firms, insurance companies, and asset managers, transmit their CRS reports to the DGT via systems managed by OJK.
2. Other LJK and other entities not supervised by OJK submit data directly to the DGT via DGT’s Coretax application, succeeding the previous EOI Portal.

SiPINA as OJK’s Dedicated CRS Reporting Channel

SiPINA (Sistem Penyampaian Informasi Nasabah Asing) is an electronic platform operated by OJK that serves as the official portal for regulated financial institutions to submit international CRS reports to the DGT. Originally designed to handle Foreign Account Tax Compliance Act (FATCA) submissions, SiPINA was subsequently expanded to support CRS compliance.

Through SiPINA, OJK acts as a technical bridge between reporting institutions and tax authorities. However, ultimate legal liability for accurate and timely reporting remains solely with the individual financial institution.

Two-Step Registration Process for SiPINA

Institutions submitting CRS data through SiPINA must complete a two-stage sequential registration.

First, the institution must register as a Reporting Financial Institution (Reporting FI) with the DGT under the Director General of Taxes Regulation Number PER-04/PJ/2018.

Once registered with the DGT, the institution can apply for user account access on OJK’s SiPINA platform to initiate CRS reporting.

Technical Submission Methods in SiPINA

SiPINA provides two options for submitting CRS reports.

1. 1. XML File Upload

   This method requires generating XML files formatted according to international CRS XML Schema standards and Indonesian regulatory requirements.

    

2. Web-Input Excel

   This interface allows users, particularly institutions with a low volume of reportable accounts, to input data directly via a standardized Excel-based form without generating XML files manually.

Institutions should select their submission method based on internal IT capacity and annual reporting value.

Mandatory Due Diligence Procedures

Before generating a CRS report, financial institutions must complete thorough due diligence across all preexisting and new accounts.

The process identifies whether an account holder qualifies as a resident taxpayer of a partner jurisdiction, typically supported by a valid self-certification.

For entity account holders, institutions must properly classify the entity (e.g., Active Non-Financial Entity or Passive Non-Financial Entity). If classified as a Passive NFE, the institution must identify all controlling persons who hold tax residencies abroad. Accurate classification is paramount to ensure the integrity of data exchanged internationally.

CRS Report Structure in SiPINA

A standard CRS report submitted through SiPINA consists of two core components. The message header, the first component, contains sender identification, compiler contact details, and general metadata regarding the reporting period.

The second component is the CRS body, which details the Reporting FI, the Reporting Group, and individual Account Reports for every reportable account. This structure guarantees exchanged data remains uniform and instantly readable by tax administration systems in foreign jurisdictions.

Data Validation and Error Correction

Upon upload, SiPINA runs automated validation checks to verify file formatting and data completeness. If errors are detected, the system generates specific error codes and descriptions. 

Institutions must resolve any flagged issues and re-upload the corrected data as a formal correction report via SiPINA. Unvalidated reports are marked as non-compliant until all corrections pass validation.

Annual Submission Deadlines

The annual deadline for submitting International CRS Reports via SiPINA is August 1 for financial data recorded as of December 31 of the previous calendar year. This deadline specifically applies to financial institutions submitting through the OJK portal.

Because late or incomplete filings carry administrative penalties, institutions are advised to prepare datasets well in advance to accommodate validation cycles and potential corrections before the cutoff.

Preparing for the Amended CRS

CRS compliance requirements continue to evolve. In 2022, the OECD released the Amended CRS to broaden reporting scope, incorporating specified e-money products and central bank digital currencies, while fortifying account identification rules and controlling person disclosure duties.

The Amended CRS also resolves reporting overlaps between CRS and the Crypto-Asset Reporting Framework (CARF), which governs crypto-asset information exchange.

The DGT outlined these upcoming adjustments in Announcement Number PENG-3/PJ/2025 ahead of full domestic implementation. Financial institutions should evaluate their software systems and internal controls early to comply with the updated CRS rules.

Participating CRS Jurisdictions

The CRS network spans over 100 jurisdictions worldwide under the auspices of the Global Forum on Transparency and Exchange of Information for Tax Purposes. More than 80 signatories have endorsed the CRS Multilateral Competent Authority Agreement (CRS MCAA), forming the legal bedrock for automated financial exchanges.

The table below illustrates participating jurisdictions by region. This is not an exhaustive list, as the number of participating jurisdictions and active bilateral exchange relationships with Indonesia may change over time. The latest information on CRS participation and exchange relationships is available on the OECD’s AEOI portal.

Fulfilling CRS duties extends beyond simple administrative compliance. It reinforces Indonesia’s position within global financial transparency. Automated data sharing significantly restricts avenues for cross-border tax evasion and non-compliance.

Institutions facing delays or non-compliance risk administrative penalties and serious reputational damage. The information exchanged under the CRS is a vital tool for tax authorities worldwide to verify compliance among taxpayers holding offshore assets.

As the DGT prepares to enforce the Amended CRS, financial institutions should audit their current capabilities, refine due diligence workflows, and ensure operations teams thoroughly understand every phase of SiPINA reporting.

Legal References

• Government Regulation in Lieu of Law of the Republic of Indonesia Number 1 of 2017, later enacted as Law of the Republic of Indonesia Number 9 of 2017 concerning Financial Information Access for Tax Purposes.
• Minister of Finance Regulation Number 70/PMK.03/2017 concerning Technical Guidelines for Financial Information Access for Tax Purposes, as amended by Minister of Finance Regulation Number 108 of 2025.
• Director General of Taxes Regulation Number PER-04/PJ/2018 concerning Registration Procedures for Financial Institutions and Automatic Submission of Financial Information Reports, as amended by PER-7/PJ/2024.
• Announcement Number PENG-3/PJ/2025 concerning Amendments to the Common Reporting Standard Regarding the Implementation of Provisions on Access to Financial Information for Tax Purposes.

Also Read:

PFII Bill Passed, Government Prepares Tax Incentives to Attract Foreign Investment
Purbaya Affirms No Rate Hikes, Focus on Tax Base Expansion
Article 26 Withholding Tax on Foreign Taxpayers