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Tax Brief: Pedoman Pengawasan Wajib Pajak dalam SE-8/PJ/2026

Tax Brief: Taxpayer Compliance Monitoring Under SE-8/PJ/2026

KUP

4 Agu 2026, 01.45 WIB

The Directorate General of Taxes (DGT) issued Circular Letter Number SE-8/PJ/2026 concerning Taxpayer Compliance Monitoring Guidelines on July 15, 2026. The circular is a technical implementation guideline for Minister of Finance Regulation Number 111 of 2025 and establishes a compliance monitoring system for the DGT headquarter, regional offices, and tax offices.

 

The updated guidance reflects the Coretax administration system roll-out, evaluation results, and stakeholder feedback. Additionally, SE-8/PJ/2026 aligns compliance monitoring with education, audits, intelligence activities, and law enforcement while providing clearer guidance on the scope of compliance reviews.

 

The circular letter issuance revoked four previous circulars: SE-14/PJ/2019, SE-11/PJ/2020, SE-05/PJ/2022, and SE-9/PJ/2023.

 

Three Pillars of Compliance Monitoring

 

SE-8/PJ/2026 organizes compliance monitoring into three main categories.

  1. Monitoring of registered taxpayers, through requests for explanation of data and/or information (permintaan penjelasan atas data dan/atau keterangan/P2DK), nudge letters, and warning letters.
  2. Monitoring of unregistered taxpayers, through P2DK procedures as part of tax extensification initiatives.
  3. Regional compliance monitoring, through data collection efforts (kegiatan pengumpulan data/KPD), including territorial KPD, analytical KPD, task-specific KPD, and non-task-specific KPD.

 

All monitoring is performed through the DGT’s supervisory system or DGT’s compliance administration system. The scope covers income tax, value-added tax (VAT), luxury-goods sales tax, stamp duty, land and building tax, sales tax, carbon tax, and other taxes administered by the DGT. Every monitoring activity must begin with the issuance of a monitoring assignment letter.

 

Setting Compliance Monitoring Priorities

 

Compliance planning is coordinated through the Taxpayer Compliance Committee at the DGT headquarter, regional offices, and tax offices. The committee is responsible for determining the priority monitoring list (daftar prioritas pengawasan/DPP), the priority tax extensification list (daftar prioritas ekstensifikasi/DPE), and the priority data collection list. These annual priority lists serve as the basis for compliance monitoring throughout the year.

 

Criteria for Strategic Taxpayers

 

The DGT distinguishes between strategic taxpayers and other taxpayers.

 

Strategic taxpayers include all taxpayers registered under the large tax offices, Jakarta regional offices, and medium tax offices. Furthermore, small tax offices may nominate taxpayers within their jurisdiction as strategic taxpayers based on several criteria, including contribution to tax revenue, non-compliance risk level, revenue potential, tax return filing compliance, and monitoring and audit history.

 

The Head of the Regional Office determines strategic taxpayer status, which remains valid for a year and may be reviewed periodically. Account representatives are assigned according to designated monitoring zones.

 

Formal and Substantive Compliance Reviews

 

Compliance monitoring of registered taxpayers is classified into formal compliance review and substantive compliance review.

  • Formal Compliance Review: Focuses on administrative compliance, including timely taxable entrepreneur (pengusaha kena pajak/PKP) registration, accurate tax payments and remittances, annual and monthly tax return filings, and compliance with Article 25 income tax installment obligations. A nominative list documenting the results will then lead to the issuance of nudge letters, tax collection letters, or warning letters.

 

  • Substantive Compliance Review: Assesses whether taxpayers comply through three types of substantive reviews:
    • Comprehensive Review: Evaluates all applicable taxes for fiscal years preceding the current year based on compliance risk management (CRM) profiles, business process analysis, financial statements, transfer pricing documentation, and field visits. This review is mandatory for strategic taxpayers and may also apply to taxpayers who present a high compliance risk, conduct related-party transactions, report tax losses, are classified as high-net-worth individuals, receive preliminary tax refunds, or generate annual revenue exceeding IDR 4.8 billion. The review must generally be completed within 22 working days, with a possible extension of up to 44 working days.
    • Limited Review: Applied to taxpayers that do not qualify for comprehensive or automated reviews. It may cover some or all tax types for either the current or previous fiscal years and must generally be completed within 10 working days.
    • Automated Review: Conducted within one working day based on verifiable tax data.

 

The circular also distinguishes between periodic payment monitoring, which covers tax obligations for the current fiscal year (through limited or automated reviews without DPP), and substantive compliance monitoring, which covers tax obligations for prior years (through comprehensive, limited, or automated reviews).

 

P2DK Procedures Under SE-8/PJ/2026

 

The Head of the Tax Office issues and electronically signs P2DK letters (SP2DK) through the DGT’s compliance administration system. They deliver SP2DKs through the taxpayer’s account, registered email, facsimile, postal/courier services, or in person. They also must complete delivery made outside the taxpayer’s account within three working days of issuance.

 

Taxpayers must respond within 14 days of receiving the SP2DK and may request a seven-day extension. They may submit responses through their account, postal/courier services, field visits, in-person meetings at the tax office, or video conferences (only the tax office is permitted to record video conferences).

 

The entire P2DK process, from the issuance of the SP2DK to the preparation of the result report (LHP2DK), must generally be completed within 44 working days from the SP2DK is delivered, with a possible extension of up to 22 additional working days. A P2DK may conclude that no indication of tax non-compliance exists, the taxpayer cannot be located or has passed away, or that an indication of a tax crime requires a preliminary evidence audit.

 

Monitoring Unregistered Taxpayers and Regional Activities

 

Tax extensification for unregistered taxpayers is carried out through the P2DK procedures using targets included in the DPE approved by the Taxpayer Compliance Committee at the DGT headquarter. SP2DK contains information relating to income, expenses, assets, liabilities, and capital and must be issued within five working days after the monitoring assignment letter is issued.

 

Regional monitoring is conducted through four categories of KDP, including territorial, analytical, task-specific, and non-task-specific. Information relating to taxpayers’ income, expenses, assets, liabilities, capital, and taxpayer profiles is recorded in the DGT’s compliance administration system, taking into account the five-year statute of limitations for tax assessments.

 

Automated Monitoring and Multi-Level Evaluation

 

SE-8/PJ/2026 introduces automated compliance monitoring conducted by the DGT headquarter through its information systems. The system can automatically generate SP2DKs, nudge letters, warning letters, and tax collection letters. Compliance monitoring will be overseen and evaluated at multiple levels by the DGT headquarter, regional offices, tax offices, the Taxpayer Compliance Committee, and internal compliance units.

 

If your company needs assistance responding to an SP2DK or understanding how SE-8/PJ/2026 affects your tax compliance, Ideatax is ready to provide professional tax advisory and support services.

 

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

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