PMK 28/2026: Indonesia’s Accelerated Tax Refund Rules Have Changed, and Most Companies Don’t Know Their Status Has Reset

Somewhere between Rp361 trillion in accelerated tax refunds, a letter from the Corruption Eradication Commission flagging systemic abuse, and the Directorate General of Taxes’ own acknowledgment that the old rules “could no longer accommodate current needs,” the Ministry of Finance decided the accelerated refund framework needed a structural rebuild rather than another amendment. The result was PMK No. 28 of 2026, issued 29 April 2026, effective 1 May 2026.

The regulation replaces in full the previous framework that had been amended three times since 2018 without fully resolving the underlying problem: companies that did not deserve accelerated refund treatment were obtaining it, and the verification mechanism was not catching them. PMK 28/2026 addresses this by tightening the eligibility criteria, adding new grounds for status revocation, cutting the refund ceiling for several taxpayer categories, and, critically, declaring that every existing taxpayer status obtained under the old rules is void and must be reapplied for under the new framework.

That last point is the one that has the most immediate operational relevance for companies that already hold a qualifying designation. The reset is not prospective. It happened on 1 May 2026.

The Three Tracks and What Changed in Each

Indonesia’s accelerated tax refund mechanism (pengembalian pendahuluan kelebihan pembayaran pajak) has always operated through three categories of qualifying taxpayers. PMK 28/2026 preserves this three-track structure but materially adjusts the rules within each track.

Track 1: Wajib Pajak Kriteria Tertentu (Pasal 17C UU KUP) 

This is the highest-tier designation, reserved for taxpayers with a long, clean compliance record. Under the old framework, the audit opinion requirement for the audited financial statements that supported this designation was simply “unqualified opinion (WTP)” attached to the annual income tax return for three consecutive years. PMK 28/2026 tightens this in six specific directions, all of which must be satisfied simultaneously.

Track 2: Wajib Pajak Persyaratan Tertentu (Pasal 17D UU KUP) 

This track covers taxpayers with smaller operations, defined by revenue and overpayment thresholds. The thresholds have been narrowed. For corporate taxpayers, the previous framework simply capped the refundable overpayment at Rp1 billion without a revenue condition. PMK 28/2026 adds a revenue cap: the company must have annual revenue between above zero and Rp50 billion. Companies with revenue exceeding that ceiling are no longer eligible for this track.

Track 3: Pengusaha Kena Pajak Berisiko Rendah (Pasal 9 ayat (4c) UU PPN) 

This track covers VAT-registered businesses operating in specific categories, primarily exporters and those supplying to VAT collectors. The overpayment ceiling for PKP under the Persyaratan Tertentu category has been cut from Rp5 billion to Rp1 billion per tax period. A new minimum activity threshold has also been added: at least 80 percent of the taxpayer’s total taxable supplies and exports during the relevant tax period must come from qualifying activities.

A structural reclassification also takes effect under PMK 28/2026: PKP that previously qualified for PKP Berisiko Rendah status by virtue of falling under the Persyaratan Tertentu category are now treated as two separate tracks and can no longer use the Berisiko Rendah pathway for their VAT refund claims.

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The Six New Conditions for WP (Wajib Pajak) Kriteria Tertentu 

This is where the sharpest change sits for established PT PMA and large Indonesian corporates that have held Wajib Pajak (WP) Kriteria Tertentu status for years and used it to accelerate income tax refunds without going through a full audit.

Under the old framework, the audited financial statement requirement was satisfied by attaching a WTP (unqualified opinion) audit report to the annual SPT for three consecutive years. That bar was relatively low and, as the KPK’s correspondence with DJP documented, had been exploited through arrangements involving non-independent auditors, restatement disguised as regular adjustments, and inflated fiscal loss corrections.

PMK 28/2026 replaces that single requirement with six cumulative conditions that the financial statements and audit must satisfy:

• WTP Murni: The audit opinion must be unqualified (Wajar Tanpa Pengecualian) without any explanatory paragraph or modification. A modified unqualified opinion does not qualify.
• No restatement: The financial statements must not have been restated due to error correction or data manipulation. A signed declaration from the taxpayer is required.
• SP2DK responsiveness: If DJP issued an SP2DK inquiry letter regarding fiscal profit or loss at least three months before the application for Kriteria Tertentu status, that SP2DK must have been responded to or discussed in accordance with PMK No. 111 of 2025.
• Fiscal correction within 5%: The taxpayer must not have had a fiscal profit or loss correction exceeding 5% in any of the three most recent tax years based on finalized audit findings or agreed adjustments.
• Auditor rotation: The auditor must comply with the five-year rotation limit for audit engagement. A signed declaration from the taxpayer is required.
• Filed with SPT: All six conditions must be documented and attached to the annual income tax return.

The cumulative logic of these six conditions is deliberate. A company that has clean audit opinions but non-independent auditors fails the sixth. A company with clean audits and compliant auditors but a prior year restatement fails the second. Each condition independently causes disqualification. For PT PMA entities that outsource their annual audit without tracking these conditions, the compliance exposure is material and may not be visible until an application for Kriteria Tertentu status is reviewed and rejected.

For companies that have not yet worked through the interaction between their audit arrangements and these new DJP requirements, XPND’s framework for annual tax reporting compliance in Indonesia covers how the SP2DK response process and audit compliance obligations sit within the broader annual tax filing cycle, which is the foundation that the Kriteria Tertentu designation is now built on.

The Transition Provision That Resets Everyone

This is the point that XPND encounters most often when companies first review PMK 28/2026: they assume their existing WP Kriteria Tertentu or PKP Berisiko Rendah designation carries forward automatically. It does not.

The DJP’s own official presentation material states explicitly that Keputusan Penetapan (SK) issued under Article 17C of the KUP Law, meaning existing WP Kriteria Tertentu designations, “are declared no longer valid as of 1 May 2026.” The same reset applies to PKP Berisiko Rendah status obtained under the prior framework.

Every company that held qualifying status before PMK 28/2026 came into force must apply for designation under the new framework if it wants to continue using the accelerated refund pathway. The application must be submitted through the taxpayer portal (portal WP), no later than 10 January of the relevant tax year. For the 2026 tax year, the practical window to obtain Kriteria Tertentu status is now already partially elapsed.

One specific consequence of this reset relates to the Wajib Pajak Kriteria Tertentu designation condition involving the audit of financial statements for three consecutive years. For a company that first applied under the old rules using 2022, 2023, and 2024 audit opinions, the new framework will assess whether those three years of audit reports satisfy all six of the new WTP conditions, not just whether a WTP opinion was obtained. A company that had a qualified auditor rotation issue in 2023, for example, may find its previously valid Kriteria Tertentu basis invalidated retroactively by the new assessment criteria.

The status reset also has downstream effects on the dividend withholding tax position for PT PMA entities. A PT PMA that lost its Kriteria Tertentu status after the 1 May 2026 transition cannot use the accelerated refund mechanism for overpaid income tax while its reapplication is pending. If the company simultaneously has a treaty-rate dividend withholding claim in progress, the interaction between these two compliance tracks warrants specific attention. The P3B dividend withholding tax guide covers the treaty documentation requirements that run parallel to the refund process and where companies most commonly find that a gap in one track affects the other.

What the New Revocation Conditions Mean for Ongoing Status

Obtaining Kriteria Tertentu or PKP Berisiko Rendah status under PMK 28/2026 is not a one-time event. The regulation specifies conditions under which the status can be revoked at any point after it is granted.

For WP Kriteria Tertentu

Revocation can be triggered by any of the following:

• Late submission of an Annual Tax Return
• Late submission of a Periodic Tax Return for a particular tax type across two consecutive tax periods, or three tax periods in one calendar year, or beyond the submission deadline of the following tax period
• Existence of outstanding tax debt past its due date (unless a postponement or installment arrangement has been approved)
• An audit opinion that is not Wajar Tanpa Pengecualian (Unqualified), or a restatement of the financial statements
• An auditor who has exceeded the five-year rotation limit
• Failure to respond to an SP2DK regarding fiscal profit or loss
• A fiscal correction exceeding 5% based on finalized audit findings
• Commencement of an open criminal evidence investigation or tax crime investigation

The practical consequence of this list for a company managing its annual Kriteria Tertentu status is that the designation requires year-round compliance hygiene, not just compliance at the point of application. A late monthly VAT return in March that spans into two consecutive periods, or a late PPh 25 installment, can trigger revocation even if the company is otherwise in good standing.

For PKP Berisiko Rendah

Additional revocation conditions for this category include late submission of monthly VAT returns during the prior 12-month period. This is a new provision in PMK 28/2026 not present in the old framework and applies specifically to the PKP Berisiko Rendah track.

The Refund Cap Changes That Affect Company Cash Flow Planning

PMK 28/2026 introduced one further change that directly affects cash flow planning for companies managing recurring VAT or income tax overpayments.

The refund ceiling for PKP under the Persyaratan Tertentu track dropped from Rp5 billion per tax period to Rp1 billion per tax period. For an exporter or a company regularly selling to government collectors that had been using the Rp5 billion ceiling to manage its monthly VAT cash position, this reduction means a larger portion of monthly VAT overpayments will now sit waiting for a full audit refund (restitusi biasa) rather than the faster administrative review process (pengembalian pendahuluan).

The full audit refund process carries a statutory timeline of up to 12 months before a Tax Assessment Letter is issued. For companies with recurring monthly overpayments above Rp1 billion, this represents a structural change to working capital requirements that should be reflected in treasury projections.

The practical offset, for companies whose activities genuinely qualify for PKP Berisiko Rendah status, is that the new 80-percent qualifying activity threshold provides a clearer evidentiary basis for claiming and defending the accelerated pathway, rather than the previous system where threshold compliance was less formally structured.

What Companies Need to Do Now

The combination of the status reset, the six new WTP conditions, the narrower thresholds, and the new revocation triggers means that most companies with a prior qualifying designation need to take active steps rather than assuming continuity.

The priority sequence is:

• Confirm whether existing designations are still valid under the PMK 28/2026 framework. They are not automatically carried forward and must be assessed against the new criteria before any refund application is submitted on that basis.
• Review the most recent three years of audit reports against the six new WTP conditions. If any of the six conditions was not met, the Kriteria Tertentu basis may not be available regardless of whether the company had a prior valid designation.
• Reassess the refund ceiling for PKP under the Persyaratan Tertentu track. Companies that had planned cash flow around the Rp5 billion monthly ceiling need to adjust to Rp1 billion.
• Check SP2DK response history. Any SP2DK related to fiscal profit or loss that was not formally responded to or discussed within the PMK 111/2025 framework creates a risk that the Kriteria Tertentu application will be rejected.
• Submit the reapplication by 10 January of the relevant tax year through the taxpayer portal.

XPND’s tax compliance team supports companies through the Kriteria Tertentu and PKP Berisiko Rendah reapplication process under PMK 28/2026, covering the audit opinion review, SP2DK documentation, and portal submission through Coretax. For companies whose tax compliance records under Coretax have gaps or inconsistencies that may affect the reapplication outcome, a compliance position review before submission avoids a rejection that triggers a full audit rather than an administrative resolution.

Reach out to XPND’s tax team to assess your current designation status and reapplication eligibility under PMK 28/2026 before the next refund claim depends on a status you may no longer hold.