In carrying out their tax rights and fulfilling their tax obligations, taxpayers may appoint a representative to act on their behalf before the Direktorat Jenderal Pajak (DJP). In response to the continuous development of Indonesia’s tax administration system and the growing need for greater legal certainty, the Government has issued PMK No. 44 of 2026 concerning the Requirements for Becoming a Tax Representative and the Procedures for Exercising Tax Rights and Fulfilling Tax Obligations by Tax Representatives.
This regulation aims to enhance legal certainty, fairness, equal treatment, and administrative efficiency for both taxpayers and their representatives.
I. ELIGIBLE TAX REPRESENTATIVES
PMK No. 44 of 2026 provides that taxpayers may appoint a representative to exercise their tax rights and fulfill their tax obligations in accordance with the prevailing tax laws and regulations. Such appointment must be made through a Special Power of Attorney, which may be executed either electronically or in paper form.
The following parties may be appointed as a tax representative:
- Licensed Tax Consultants;
- Other Qualified Individuals who satisfy the prescribed requirements; or
- Family members, including a spouse or relatives by blood or marriage up to the second degree.
This provision offers taxpayers greater flexibility in selecting a representative while ensuring that the appointed individual satisfies the qualifications stipulated under the regulation.
II. REQUIREMENTS FOR BECOMING A TAX REPRESENTATIVE
One of the key features introduced under PMK No. 44 of 2026 is the clarification of the competency requirements applicable to tax representatives. For Licensed Tax Consultants, professional competency must be provided by a valid Tax Consultant License. If a Tax Consultant is subject to a suspension or revocation of their Tax Consultant License, they cannot be appointed as an authorized representative.
Meanwhile, Other Qualified Individuals are required to hold a valid Certificate of Registration as proof of their technical competency in taxation. In addition, both Licensed Tax Consultants and Other Qualified Individuals must be registered within the Directorate General of Taxes’ administrative system and may not be appointed as authorized representatives if they are subject to a suspension or revocation of their Certificate of Registration.
The regulation also provides a clearer definition of Other Qualified Individuals, referring to persons other than Licensed Tax Consultants and eligible family members who possess the required technical expertise in taxation and hold a valid Certificate of Registration, enabling them to act as taxpayers’ representatives.
III. COOLING OFF PERIOD
To preserve professional independence and prevent potential conflicts of interest, PMK No. 44 of 2026 introduces a five-year cooling-off period for certain individuals before they may serve as tax representatives.
This provision applies to retired civil servants of the Ministry of Finance effective from the retirement date stated in the retirement decision letter, former Ministry of Finance civil servants who resigned before reaching the mandatory retirement age effective as of the date of honorable dismissal as a civil servant, as specified in the honorable dismissal decision letter, and former Government Employees under Employment Agreements (PPPK) within the Ministry of Finance effective as of the employment end date specified in the employment agreement. The introduction of this cooling-off period is intended to safeguard impartiality, maintain public confidence, and reinforce the integrity of Indonesia’s tax administration system.
IV. ADMINISTRATIVE REQUIREMENTS FOR SURAT KUASA KHUSUS
As the legal basis authorizing a representative to act on behalf of a taxpayer, a Special Power of Attorney must contain information regarding the principal, the appointed representative, the scope of authority granted, the relevant type of tax, and the applicable tax period.
PMK No. 44 of 2026 also sets out the procedures for revoking a Special Power of Attorney, the circumstances under which the authorization expires, and the prescribed administrative format to ensure legal certainty in the exercise of tax representation.
V. TRANSITIONAL PROVISIONS
A Special Power of Attorney granted by a Taxpayer to an authorized representative and submitted to the Direktorat Jenderal Pajak (DJP) before the effective date of Minister of Finance Regulation No. 44 of 2026 shall remain valid for the purpose of exercising the Taxpayer’s rights and/or fulfilling certain tax obligations in accordance with the terms of such Special Power of Attorney.
A person other than a Tax Consultant who holds a tax brevet certificate or a formal education degree in taxation issued by a public higher education institution with Accreditation Grade A, at least at the Diploma III level, may still be appointed as an authorized representative until 31 December 2026.
VI. CONCLUSION
The issuance of PMK No. 44 of 2026 represents the Government’s commitment to strengthening the governance of tax representation by providing clearer rules regarding eligible representatives, competency requirements, and the administrative procedures governing the appointment and termination of tax representatives.
By understanding and complying with these new provisions, taxpayers can appoint qualified representatives who meet the applicable regulatory requirements, thereby ensuring that the exercise of tax rights and the fulfillment of tax obligations are carried out effectively, in an orderly manner, and with greater legal certainty for all parties involved.
Peraturan ini diundangkan pada tanggal 6 Juli 2026 dan mulai berlaku pada tanggal diundangkan.
For Tax Service Assistance, please contact:
Rani Widianti
T. (+6221) 2222-0200
E. rani.widianti@shinewing.id
Alvina Oktavia
Associate
T. (+6221) 2222-0200
E. alvina.oktavia@shinewing.id
