PMK 15/2025: Indonesia’s New Tax Audit Procedure Rules

A company under audit assembled its supporting documentation the way it always had, gathering records as the auditor’s questions came in, confident there would be time to respond properly. There was not. Under the regulation now governing every tax audit in Indonesia, the deadline to submit requested data runs out at one month, and anything submitted after that point can be legally disregarded by the auditor. Worse, thanks to a separate Supreme Court circular reinforcing the same principle, evidence excluded at the audit stage generally cannot be revived later if the case reaches Tax Court. A company that treats document collection as something to handle at its own pace is operating under rules that no longer exist.

Those rules changed on 14 February 2025, when Minister of Finance Regulation No. 15 of 2025 on Tax Audit came into force.

One Regulation Now Governs Every Type of Tax Audit

PMK 15/2025 repeals and consolidates a set of older, overlapping rules, chiefly Minister of Finance Regulation No. 17/PMK.03/2013 as last amended by No. 184/PMK.03/2015, along with the audit provisions in Article 105 of Regulation No. 18/PMK.03/2021. Rather than leaving audit procedure scattered across multiple instruments accumulated over more than a decade, the government folded standards, timeframes, taxpayer rights and obligations, auditor authority, report preparation, and re-audit rules into a single framework. The regulation also does two things that matter beyond simple consolidation. It draws a clearer line between tax audits and criminal tax procedures, reducing the overlap that previously left some cases sitting in an ambiguous space between the two, and it expands the audit framework’s scope to explicitly cover Land and Building Tax and Carbon Tax, both of which now sit inside the same procedural rulebook as standard income and value added tax audits.

Three Audit Types Replaced Two, and the Difference Is Not Cosmetic

Comprehensive, Focused, and Specific Audits for Compliance Testing

Before PMK 15/2025, an audit was classified as either a field audit, carrying an assessment period of six months extendable by two to six more, for a maximum of twelve months total, or an office audit, running four months plus a two month extension for a six month maximum. That binary classification is gone. For audits aimed at testing compliance, Article 6(2) of PMK 15/2025 introduces three categories instead, each with its own testing period running from the audit notification letter to the findings letter: a comprehensive audit, examining every item across a full tax return, capped at five months; a focused audit, narrowing to one or several specific items the tax authority has flagged, capped at three months; and a specific audit, targeting particular data points or obligations through a simplified process, capped at one month. Article 4(1) sets out 14 distinct criteria that can trigger a compliance testing audit under one of these three categories, ranging from a refund claim to selection based on compliance risk scoring.

One extension worth flagging specifically for multinational manufacturing groups: under Article 6(5), the testing period for a company that is part of a corporate group, or one showing indications of transfer pricing arrangements or engineered financial transactions, can be extended by up to four additional months beyond the standard cap. A focused audit built around related party pricing is therefore realistically a seven month exposure once that extension is accounted for, not the three months the base classification implies.

Audits for Other Purposes Run on a Different Clock Entirely

A separate track exists for audits conducted for reasons other than routine compliance testing, covering law enforcement referrals and other statutory purposes under Article 4(3)’s second set of 25 criteria. These audits are generally administrative rather than a full review of every tax obligation, and Article 6(8) caps the total period at four months from the issuance of the audit notification letter, the Surat Pemberitahuan Pemeriksaan or SP2, through to completion of the final audit report. A company that receives an SP2 needs to identify immediately which track and which specific classification applies, since the assessment period, the document burden, and the realistic preparation timeline all differ meaningfully between them.

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The One Month Document Deadline That Can Decide a Case Before It Starts

This is the provision with the most immediate practical consequence, and it is also the one companies most consistently underestimate. Under Article 12(2), a taxpayer has a maximum of one month from an auditor’s written request to provide the data, records, and documentation demanded. Miss that window, and Article 12(4) entitles the auditor to treat the missing material as if it had never been submitted at all, regardless of whether it eventually surfaces later in the process. The regulation does build in some warning before that deadline bites. Under Article 12(5), an auditor must issue up to two written reminders while the window is still open, one two weeks after the request and a second at three weeks, giving a company genuine notice before the one month mark passes.

There is also a narrower exception worth knowing, since it softens what would otherwise be an absolute cutoff. Under Article 12(11), where the requested material is genuinely held by a third party and the taxpayer has not yet managed to obtain it, that specific category of document can still be submitted any time up until the minutes of the Pembahasan Akhir Hasil Pemeriksaan, the final discussion, are signed, well beyond the standard one month window. That exception does not extend to documents already in the company’s own possession. It exists specifically for material genuinely outside the taxpayer’s immediate control.

That risk compounds further once a case moves beyond the audit itself. Supreme Court Circular Letter No. 2 of 2024 tightened evidentiary rules specifically for tax disputes, confirming that evidence not submitted during the original audit generally cannot be introduced later in Tax Court or on further appeal to the Supreme Court. The practical effect is that the one month audit deadline is not just an administrative formality. It functions as the effective deadline for a company’s entire evidentiary position, audit stage and appeal stage combined, for any document the company already holds itself. Companies that maintain the kind of continuously organized bookkeeping covered in a separate guide to bookkeeping requirements for PT entities in Indonesia are in a fundamentally stronger position here than companies that only begin assembling records once an SP2 arrives, since reconstructing a full evidentiary package inside thirty days is rarely realistic if the underlying records were not already in reasonable order. For transfer pricing specifically, where documentation standards are exacting and time consuming to prepare properly, the same one month clock applies to the company’s own records, a pressure point covered in more depth in a dedicated look at Indonesia’s transfer pricing documentation requirements.

Pembahasan Temuan Sementara Is a Right, Not a Courtesy

Alongside the tightened document deadline, PMK 15/2025 introduces a genuinely new procedural protection running in the taxpayer’s favor. Under Article 17, the Pembahasan Temuan Sementara, a mandatory discussion of preliminary audit findings, has to take place no later than one month before the end of the testing period, giving the taxpayer a formal opportunity to respond to the auditor’s initial conclusions before they harden into a final position. During this discussion, a taxpayer can present books, records, data, and other information, including electronic data, and can formally submit any third party sourced documents still outstanding under the Article 12(11) exception described above, as well as bring witnesses, experts, or other third parties by formal appointment.

This is a meaningful shift from the older framework, where a company often first learned an auditor’s full reasoning only when the formal findings letter, the Surat Pemberitahuan Hasil Pemeriksaan, arrived, with a comparatively short response window that PMK 15/2025 has also since adjusted. Treating the Pembahasan Temuan Sementara as optional, or sending an underprepared representative to it, forfeits one of the only structured opportunities to correct a misreading of the facts before it becomes materially harder to reverse. Making sure the person representing a company at this stage is properly credentialed matters here too, a requirement now tied to the framework covered in XPND’s breakdown of tax representative rules under PMK 44/2026.

What This Means for a Company’s Audit Readiness Posture

Bringing the classification system, the document deadline, and the preliminary findings discussion together, a few adjustments matter more than a general sense of caution once PMK 15/2025 is the operative framework.

• Identify immediately, on receipt of an SP2, whether the audit is a compliance testing audit under one of the three new categories or an other purpose audit running on Article 6’s four month clock
• Calendar the one month document deadline the day the SP2 arrives, not the day a specific request letter follows, since the response window is genuinely short relative to what most in-house teams are used to preparing under
• Treat ongoing bookkeeping and transfer pricing documentation as audit preparation that happens continuously, not as a task that starts once an SP2 is received
• Prepare substantively for the Pembahasan Temuan Sementara stage, including deciding in advance what documents, data, and explanations will be presented, rather than treating it as a formality to attend
• Confirm that whoever represents the company during the audit holds the credentials PMK 44/2026 now requires, since representation gaps create their own separate exposure layered on top of the audit itself

None of these steps require anything exotic. What they require is treating the one month clock as real from the moment it starts, since PMK 15/2025 gives a company very little room to catch up once that window has closed.

XPND’s tax compliance team works with foreign owned companies to build the kind of continuously audit ready documentation posture PMK 15/2025 now effectively demands, so that a one month deadline is a formality to meet rather than a scramble to survive. A regulation built around consolidation and legal certainty still shifts real risk onto the taxpayer, and the shift is not in the tax rate. It is in how much time a company actually has to prove its position once the clock starts running.