The Indonesian Government continues to refine its tax refund process through Minister of Finance Regulation No. 28 of 2026 on Procedures for Preliminary Tax Refunds (PMK 28/2026). This regulation updates the requirements for taxpayers seeking expedited tax refunds under the status of Taxpayers Meeting Certain Criteria (Wajib Pajak Kriteria Tertentu).
Under this scheme, eligible taxpayers do not need to wait for a full tax audit to receive preliminary refunds for Income Tax (PPh) or Value Added Tax (VAT). For business entities, this facility helps maintain liquidity and optimize corporate cash flow.
Key Requirements to Qualify as a Taxpayer Meeting Certain Criteria
Pursuant to Article 3 of PMK 28/2026, taxpayers must meet four primary criteria to obtain this status:
- Consistent On-Time Tax Return Submissions
A primary indicator of compliance is the timely filing of Annual Tax Returns (SPT Tahunan).
Taxpayers must have filed their Annual Tax Returns on time for the last three tax years prior to designation. In addition, Monthly Tax Returns (SPT Masa) from January through November of the most recent tax year must also be fully submitted.
If filing delays occur, they are strictly capped at a maximum of three tax periods per tax type, must not occur consecutively, and cannot extend past the filing deadline of the subsequent tax period.
- Zero Tax Arrears
Taxpayers must have no outstanding tax liabilities past due at the end of the year prior to designation.
Exceptions apply to tax debts that have received official approval for payment deferral, installment arrangements, or those that have surpassed the legal collection period (daluwarsa penagihan).
Furthermore, over the past five years, taxpayers must maintain an unblemished record with no history of late payments regarding approved tax installments or settled tax debts.
- Financial Statements with an Unqualified Audit Opinion (WTP)
The Directorate General of Taxes (DGT) also evaluates the quality of financial reporting. Taxpayers must have audited financial statements for three consecutive years issued by a certified public accountant or government financial oversight body, securing an Unqualified Opinion (Wajar Tanpa Pengecualian / WTP).
These financial statements must not be restated due to error corrections or data manipulation. Additionally, any adjustments to fiscal profit or loss resulting from tax audit findings—whether agreed upon or legally binding—must not exceed 5%.
- Clear Legal Record (No Tax Crimes)
Taxpayers must demonstrate strong legal compliance. Within the past five years, the taxpayer must not have been convicted of any tax crime based on a final and binding court decision (inkracht).
How to Apply for Certain Criteria Taxpayer Status
Applications can be submitted electronically via the Taxpayer Portal (Portal Wajib Pajak) no later than January 10 each year.
If electronic filing is temporarily unavailable, manual submissions are permitted directly at the local Tax Office (KPP), or via registered mail, courier services, or official delivery services.
The DGT will review the application against all administrative criteria. A formal decision—granting or rejecting the status—must be issued within 30 business days of receiving the application.
If the DGT does not issue a decision within this timeframe, the application is automatically deemed approved by law.
Revocation of Status
Designation as a Taxpayer Meeting Certain Criteria is not permanent. The DGT may revoke this status if a taxpayer fails to maintain compliance, such as:
- Late filing of the Annual Tax Return;
- Missing monthly tax return deadlines for two consecutive periods;
- Holding overdue tax arrears; or
- Falling behind on approved tax installment payments.
Status may also be revoked if the taxpayer’s financial statements no longer receive an unqualified audit opinion, if fiscal adjustments exceed the 5% threshold, or if the taxpayer becomes subject to a preliminary evidence examination (pemeriksaan bukti permulaan) or tax crime investigation.
Formal Administrative Verification
Prior to issuing a preliminary refund, the DGT conducts a formal compliance check to verify that:
- The Certain Criteria Taxpayer status remains valid;
- Annual and monthly tax returns are up to date;
- No overdue tax debts remain unpaid;
- Tax installment or deferral plans are fully complied with;
- Financial statements maintain an unqualified opinion;
- The taxpayer is not undergoing a tax audit for the tax period requested; and
- No preliminary evidence examination or tax investigation is currently underway.
This administrative check serves as the basis for the DGT to grant or deny the expedited refund.
Processing Timeline for SKPPKP Issuance
When the verification confirms an overpayment, the DGT issues a Notice of Preliminary Tax Refund (Surat Keputusan Pengembalian Pendahuluan Kelebihan Pajak / SKPPKP).
Under PMK 28/2026, the SKPPKP must be issued within:
- 3 months for Income Tax (PPh) refund requests;
- 1 month for VAT (PPN) refund requests.
These deadlines run from the date a complete application is received. If the statutory period expires without a formal decision, the refund request is legally considered approved.
If the approved refund amount is less than the amount claimed, the taxpayer retains the right to apply for the remaining balance, provided the DGT has not initiated a full tax audit and the request is filed within the prescribed deadline.
Conclusion
PMK 28/2026 provides clear guidelines and legal certainty for businesses seeking expedited tax refunds through the Taxpayer Meeting Certain Criteria status.
To qualify and retain this benefit, companies must consistently demonstrate timely tax return filings, settled tax liabilities, unqualified financial audit opinions, and a clean tax law record. Maintaining strict administrative compliance remains essential for businesses looking to accelerate cash flow recovery through this mechanism.
