What Changed: PMK 229/2014 vs PMK 44/2026 and Why It Matters for Your Company

For twelve years, the same ministerial regulation governed how companies in Indonesia could appoint someone to represent them before the tax authority. PMK No. 229 of 2014 was written for a paper-based tax world: handwritten forms, postal correspondence, in-person office queues. It predated Coretax by a decade. It said nothing about digital portal access, said nothing about formal competency credentials for non-consultants, and said nothing about family members as formal representatives.

On 6 July 2026, the Ministry of Finance replaced it entirely. PMK No. 44 of 2026 on Requirements to Become a Tax Representative and Procedures for Exercising Rights and Fulfilling Obligations took effect the same day it was promulgated. PMK 229/2014 was simultaneously revoked.

The substance of tax representation has not changed. Your company can still appoint someone else to handle its tax obligations. What has changed is who qualifies, what credentials they must hold, and how the appointment integrates with the Coretax digital platform. For any multinational enterprise operating in Indonesia through a PT PMA or other legal entity, reviewing your current representation arrangement against the new framework is not optional. There is a transition deadline that expires on 31 December 2026.

What the Two Regulations Look Like Side by Side 

The Three Categories of Representative, Redefined 

PMK 44/2026, building on the classification framework established in Government Regulation No. 50 of 2022 (PP 50/2022), recognizes three categories of tax representative. Each carries different credential requirements and different practical implications for companies appointing them.

Licensed Tax Consultants (Konsultan Pajak)

The requirements for this category are the most straightforward. A licensed tax consultant qualifies as a representative if they hold a valid Tax Consultant License (Izin Konsultan Pajak) issued by the Minister of Finance and are registered in DJP’s administrative system. A tax consultant whose license is currently suspended or revoked cannot serve as a representative during that suspension period.

This category is unchanged in its fundamental structure from PMK 229/2014, but the DJP registration requirement is now explicit and enforceable through Coretax rather than informally managed.

Other Qualified Parties (Pihak Lain)

This is the category that has changed most materially for companies relying on in-house tax specialists, accounting firm staff, or finance directors to handle their DJP representation.

Under PMK 229/2014, a company could appoint an employee or external professional who was not a licensed tax consultant, provided they had relevant experience. The regulation did not specify what credential, if any, this person needed to hold. In practice, individuals with tax brevet certificates or taxation degrees operated without formal credentialing, and the system accepted this informally.

PMK 44/2026 ends that. From 6 July 2026, anyone serving as a tax representative who is not a licensed tax consultant and not a family member must hold a Surat Keterangan Terdaftar (SKT), a formal Certificate of Registration issued by the Ministry of Finance confirming competency in Indonesian tax law. The SKT must be valid and the holder must be registered in DJP’s system. If the SKT is suspended or revoked, the individual cannot act as representative during that period.

The SKT requirement replaces the informal, experience-based model with a formalized standard. A finance director without an SKT, or an accounting firm staff member without one, is no longer legally qualified to serve as a Pihak Lain representative under the new framework.

Family Members (Keluarga)

This is the most significant expansion in PMK 44/2026 compared to the prior regulation. Under PMK 229/2014, family members were never explicitly mentioned as permitted representatives. Some companies used family members informally, but the legal basis was ambiguous.

PMK 44/2026 formally recognizes family members as a valid representative category. The definition covers a spouse, or relatives by blood or marriage up to the second degree. No tax competency credential or SKT is required from family members, though the family relationship must be documented with supporting evidence. For companies where a family member has been managing tax administration in a personal capacity, this formalization provides explicit legal clarity and protection for that arrangement.

One practical caveat applies: family representation is best suited to routine and straightforward filings. Complex audits, disputes with DJP, or specialized tax technical matters require professional expertise that the family member category does not presuppose.

Explore Our Services Tax Compliance in Indonesia

What Cannot Be Delegated and What Stays With the Taxpayer

Two provisions in PMK 44/2026 define the limits of the representative relationship in terms that differ materially from informal practice under the prior framework.

No sub-delegation. Article 8(3) of PMK 44/2026 states explicitly that a representative cannot transfer the authority received from the taxpayer to another person. Under the old regime, it was not uncommon for a named representative to informally pass work to junior colleagues or associate practitioners within the same firm. This no longer has a legal basis. The person named in the power of attorney must perform the substantive tax work themselves. A representative may designate a staff member or third party to physically deliver or receive documents from DJP, but this is a courier function, not an authority delegation. The delivery person must carry a formal letter of designation from the representative.

Taxpayer liability is absolute and non-transferable. For company directors who assumed that appointing a tax representative insulated them from personal liability for tax filing errors, PMK 44/2026 makes this explicit: the taxpayer remains fully responsible for all obligations delegated to a representative. The section below on what remained unchanged covers this in full.

Coretax Integration: The Two-Authorization Requirement

The most operationally significant technical change in PMK 44/2026 is the dual authorization structure for electronic tax representation.

Under PMK 229/2014, a written power of attorney was essentially the single document that authorized a representative to act. The digital infrastructure we have today did not exist at the time. PMK 44/2026 operates in a Coretax world, and Coretax requires its own authorization layer.

To act as a representative for a company’s electronic tax obligations, an individual now needs two distinct things:

• A Surat Kuasa Khusus (Special Power of Attorney) specifying the taxpayer’s identity, the representative’s identity and credential number, the scope of the authority being granted, and the validity period. The document must be stamped with the applicable duty stamp (meterai). It can be executed electronically through the Coretax taxpayer portal or in paper form.
• Explicit Coretax portal access (role access) granted to the representative by the taxpayer in the system. A valid power of attorney does not automatically confer portal access. Coretax access must be separately configured.

The separation between these two authorizations has practical consequences that companies have already been discovering since Coretax launched. A representative may hold a valid power of attorney but have lapsed Coretax access, making them unable to file electronically even though they are legally authorized. Conversely, a person may retain Coretax access from a prior arrangement without a current power of attorney, which creates an unauthorized access situation. For companies managing multiple subsidiaries, each entity’s Coretax access configuration must be reviewed independently.

For companies still navigating how PMK 44/2026 fits within the broader Coretax annual compliance cycle, the annual tax reporting compliance framework for Indonesia covers how the reporting calendar and filing obligations interact with representative authorization requirements across each tax period.

The Cooling-Off Period for Former Government Officials

PMK 44/2026 introduces a provision that has no equivalent in PMK 229/2014: a mandatory five-year waiting period before a former Ministry of Finance or DJP official can serve as a tax representative.

The restriction applies to former civil servants (PNS) and contract government employees (PPPK) of the Ministry of Finance who have retired, resigned, or whose contracts have ended. They must wait five years from the date of separation before they can formally represent taxpayers before tax authorities. Additional conditions apply: the individual must have a clean disciplinary record and must not have been dismissed dishonourably or sanctioned for misconduct, conflicts of interest, or improper conduct during their government service.

This provision does not prohibit former government officials from providing tax advisory services, training, or consulting work that does not involve formal representation before DJP. The restriction applies specifically to acting as the named representative in a Surat Kuasa Khusus and appearing before the tax authority in that capacity.

What Remained Unchanged

Three fundamentals of the tax representation framework carry forward from PMK 229/2014 without modification, and understanding them prevents overcorrection in how companies respond to the new regulation.

Appointing a representative is still optional. There is no statutory requirement that a company appoint a tax representative. However, your company must meet all tax obligations through Coretax, which typically requires an Indonesian-resident signatory with portal access. Most multinational enterprises use a representative to satisfy this requirement practically, even though the legal obligation to appoint one does not exist.

Multiple representatives are permitted. A company may appoint different representatives for different tax matters simultaneously: one for monthly VAT filings, another for annual corporate returns, a third specifically for audit representation. Each appointment is formalized through a separate Surat Kuasa Khusus. This flexibility remains fully available under PMK 44/2026 and is a practical tool for companies whose tax obligations span multiple periods, entity types, or DJP offices.

Taxpayer liability remains absolute. A representative acts on the company’s behalf but does not absorb its legal responsibility. The taxpayer remains fully liable for the accuracy of all filings, the timeliness of all payments, and compliance with all applicable tax regulations regardless of who was appointed to handle those obligations. This was implied under PMK 229/2014. PMK 44/2026 makes it explicit.

PMK 44/2026 also introduces formal ethical obligations for representatives that were only implied under the old framework. A representative is now explicitly required to maintain confidentiality of the taxpayer’s information, act professionally and in compliance with tax regulations, and refrain from interfering with or obstructing DJP inspections or enforcement actions. Violations of these obligations can result in sanctions under applicable regulations. For companies, this formalization provides clearer grounds to hold a representative accountable if professional conduct falls short.

The Transition Deadline: What You Need to Act On Before 31 December 2026

This is the time-sensitive element that companies using non-licensed representatives must act on now.

Article 16(1) of PMK 44/2026 provides a transition period for individuals who do not yet hold an SKT but who have one of the following alternative qualifications: a tax brevet certificate (sertifikat brevet perpajakan), or a formal education certificate in taxation at minimum Diploma III level from a nationally accredited institution (Akreditasi A). These individuals may continue to serve as tax representatives until 31 December 2026, even without an SKT.

From 1 January 2027, the SKT becomes mandatory for all Pihak Lain representatives without exception. Any company currently relying on a non-licensed representative whose only qualification is a brevet certificate or a taxation degree will need to have that representative obtain an SKT before the year-end deadline, or replace them with a licensed tax consultant or a qualified SKT-holding Pihak Lain.

The practical action items for companies before 31 December 2026:

• Audit current representation arrangements: Identify who currently holds the Surat Kuasa Khusus for each tax obligation and verify whether they are a licensed tax consultant, an SKT-holding Pihak Lain, a family member, or an individual relying on the brevet/degree transition provision
• Verify Coretax access alignment: Confirm that every active representative has both a valid power of attorney and correctly configured Coretax portal access for the relevant entity
• Initiate SKT process where needed: If any representative relies on the transition provision, determine whether they will obtain an SKT before 31 December 2026 or whether a replacement arrangement is needed
• Review sub-delegation arrangements: If any representative has been informally passing work to others, bring the arrangement into compliance with the explicit no-sub-delegation rule under Article 8(3)
• Update powers of attorney: Existing Surat Kuasa Khusus executed under PMK 229/2014 remain valid until the delegated obligation is fulfilled, but new or renewed appointments must comply with the PMK 44/2026 format, including the formal cooling-off check for any former government officials

XPND’s tax compliance team assists multinational enterprises with reviewing existing representation arrangements, verifying credential compliance, drafting PMK 44/2026-compliant Surat Kuasa Khusus documentation, and managing Coretax portal access configuration across multiple Indonesian subsidiaries. XPND’s tax consultants hold active Izin Konsultan Pajak and are registered in DJP’s system, making the representation arrangement straightforward to verify and document.

Reach out to XPND’s tax compliance team to review your current representation arrangements against the PMK 44/2026 framework before the 31 December 2026 transition deadline closes.