The Ministry of Finance has issued the Ministry of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 108 of 2025 concerning Procedures for Access to Financial Information for Tax Purposes. The regulation reinforces Indonesia’s framework for financial information reporting and exchange in the tax sector, including cryptoasset-related information.
As stated in its recital, PMK Number 108 of 2025 was enacted following Indonesia’s commitment as a competent authority that has signed the Addendum to the Multilateral Competent Authority Agreement (MCAA) on the Automatic Exchange of Financial Account Information, as well as the MCAA on the Automatic Exchange of Information under the Cryptoasset Reporting Framework (CARF).
These agreements signify Indonesia's commitment, alongside other countries, to implement the automatic exchange of financial account information based on updates to the Common Reporting Standard (CRS) and to exchange information on relevant cryptoassets in accordance with the CARF.
Legal Basis of PMK Number 108 of 2025
PMK Number 108 of 2025 was established on December 29, 2025, and took effect on January 1, 2026. It replaces PMK Number 70/PMK.03/2017, which was amended by PMK Number 47 of 2024.
The government determined that PMK Number 70 of 2017 and its amendments were no longer adequate to address developments in international standards, particularly regarding access to financial information on cryptoassets. As a result, regulatory adjustments were deemed necessary to ensure alignment with evolving global tax transparency standards.
Structure of PMK Number 108 of 2025
PMK Number 108 of 2025 comprises 61 articles across 11 chapters, structured as follows:
- Chapter I: General Provisions
- Chapter II: Access to Financial Information for Tax Purposes
- Chapter III: Procedures for Automatic Submission of Financial Information Reports under International Agreements
- Part One: General
- Part Two: Automatic Submission of Financial Account Information
- Part Three: Automatic Submission of Relevant Cryptoasset Information
- Chapter IV: Procedures for Automatic Submission of Financial Information Reports under Domestic Tax Regulations
- Part One: General
- Part Two: Automatic Submission of Financial Account Information
- Part Three: Automatic Submission of Relevant Cryptoasset Information
- Chapter V: Procedures for Providing Information, Evidence, or Statements upon Request
- Chapter VI: Anti-Avoidance Provisions
- Chapter VII: Confidentiality Provisions
- Chapter VIII: Supervision, Guidance and Analysis, Preliminary Evidence Examination, and Investigation
- Chapter IX: Delegation of Authority
- Chapter X: Transitional Provisions
- Chapter XI: Concluding Provisions
International Standards: CRS and CARF
The issuance of PMK Number 108 of 2025 is primarily based on the amendments to the CRS and the implementation of the CARF. These two standards set global benchmarks for the automatic exchange of tax information for both conventional bank accounts and cryptoassets.
The CRS MCAA facilitates the automatic exchange of financial account information between tax authorities across jurisdictions. In contrast, the CARF MCAA provides the legal basis for exchanging information on cryptoasset transactions relevant to cross-border taxation, in line with the CARF developed by the OECD and G20.
Information Access and Regulatory Focus
PMK Number 108 of 2025 empowers the Directorate General of Taxes (DGT) to access taxpayer financial data from financial institutions and cryptoasset service providers (CASPs) that are registered as reporters under CARF.
This access covers a broad range of financial data related to tax obligations, such as cryptoasset transactions and ending balances. The regulation is intended to support Indonesia’s implementation of automatic information exchange commitments under international agreements.
Cryptoasset Reporting Obligations
Starting January 1, 2026, financial services institutions and CASPs that report under CARF are required to conduct due diligence on new cryptoasset users.
The information collected will include user or taxpayer identity, tax identification number, transaction data, and the balance at the end of the reporting period. Reports will cover one calendar year, from January 1 to December 31.
These reports must be submitted automatically to the DGT. Even in the absence of reportable data for a given year, CASPs remain required to submit a nil report.
Entity Coverage and Documentation
PMK Number 108 of 2025 applies to financial services institutions and other entities classified as financial institutions under CRS and CARF provisions.
Significantly, the reporting scope extends beyond conventional bank accounts to include specified electronic money products and central bank digital currencies that qualify as financial accounts.
CASPs must retain documentation, including valid self-certification, proof of identity, and records related to accounts or transactions, for at least five years following the reporting period.
Purpose of the Cryptoasset Tax Information Exchange
The regulation aims to address tax compliance gaps arising from limited transparency in cryptoasset transactions. By expanding access to financial information, PMK Number 108 of 2025 is expected to enhance tax compliance and strengthen tax law enforcement.
Conclusion
Since its introduction in 2014, the CRS has served as the OECD-led global standard to prevent cross-border tax avoidance and evasion through the automatic exchange of financial account information. The CARF builds on this framework by addressing the rapid growth of cryptoassets in the global economic system.
Through PMK Number 108 of 2025, Indonesia formally integrates CRS and CARF into its national legal framework, reinforcing access to and exchange of financial information for both conventional bank accounts and cryptoassets. This step is anticipated to bolster tax transparency and improve overall taxpayer compliance.
