Who May Speak for the Taxpayer?

Not every tax return, objection, or refund claim is handled directly by a taxpayer. In many cases, taxpayers appoint an authorized representative to act on their behalf before the Directorate General of Taxes (DGT), reflecting the increasingly important role these representatives play in navigating Indonesia's evolving tax system.

For more than a decade, the appointment of authorized representatives has been governed by Minister of Finance Regulation No. 229/PMK.03/2014 concerning the Requirements and Implementation of the Rights and Obligations of a Representative (PMK 229/2014). According to the government, the earlier regulation did not adequately regulate the competency requirements applicable for taxpayer representatives or comprehensively define the position of family members acting on behalf of taxpayers.

To address these gaps, the government issued Minister of Finance Regulation No. 44 of 2026 concerning the Requirements for Becoming an Authorized Representative in Tax Matters and the Procedures for Exercising Rights and Fulfilling Tax Obligations as an Authorized Representative (PMK 44/2026). The regulation was promulgated and took effect on 6 July 2026, replacing PMK 229/2014. It aims to provide greater legal certainty while strengthening the overall governance of tax representation. At the same time, it raises the bar for who may represent a taxpayer, especially for non-consultant representatives. It also expands the formal options available to taxpayers by expressly recognizing qualified “other parties” and family members alongside licensed tax consultants.

Redefining Who May Represent Taxpayers

PMK 44/2026 classifies authorized representatives into three categories: tax consultants, other parties, and family members.

Tax consultants may continue to act as authorized representatives, provided that they hold a valid practice license. Meanwhile, other parties are required to obtain a Certificate of Registration (Surat Keterangan Terdaftar/SKT) issued by the DGT as evidence that they have fulfilled the requirements to act as authorized representatives. Family members, including spouses and relatives by blood or marriage within the degree stipulated by the regulation, such as grandparents and grandchildren, may continue to represent taxpayers without being subject to the competency requirements applicable to the other two categories.

However, PMK 44/2026 does not yet specify the procedures or requirements for obtaining an SKT. Pursuant to Article 3 paragraph (5), these provisions will be further regulated under a separate ministerial regulation governing tax consultants and other parties acting as authorized representatives. Meaning the new framework is already in place in principle, but part of the implementation mechanism is still awaiting detailed rules.

Competence Meets Integrity

PMK 44/2026 also introduces new measures aimed at strengthening the integrity of Indonesia's tax administration. One of the key changes is the introduction of specific requirements for former Ministry of Finance employees who wish to act as authorized representatives.

Under the regulation, former Ministry of Finance employees may only act as authorized representatives if they have not been subject to severe disciplinary sanctions and have completed a five-year cooling-off period following their retirement or separation from service. These requirements are intended to reduce potential conflicts of interest and prevent the misuse of information or authority acquired during their public service. In practical terms, this creates a clear ethical barrier between public service and later private representation work.

The regulation also reaffirms that authorized representatives may not delegate the authority granted to them to another person. Accordingly, the authority conferred under a Special Power of Attorney (Surat Kuasa Khusus/SKK) may only be exercised by the representative directly appointed by the taxpayer. This preserves accountability and limits the risk of authority being passed informally within firms or offices.

Limited Window to Adapt

To facilitate the transition to the new framework, PMK 44/2026 provides several transitional arrangements. SKKs submitted before the regulation came into force remain valid in accordance with the applicable provisions.

In addition, individuals who are not licensed tax consultants but hold a recognized tax brevet certificate or a qualifying tax-related academic qualification may continue to act as authorized representatives until 31 December 2026. After, the transitional privilege ends and affected representatives will need to qualify under the new framework if they wish to continue acting on behalf of the taxpayers.

The regulation also reiterates that each SKK may only appoint one representative to perform one specific tax right or fulfill one specific tax obligation, reinforcing greater clarity and accountability in the appointment of authorized representatives. The narrower scope may help prevent ambiguity, but it may also require taxpayers to issue more than one SKK if they want separate handling for different matters.

A New Direction for Tax Representation

PMK 44/2026 reflects the government's broader effort to strengthen the governance of tax representation in Indonesia, shifting the basis for appointing authorized representatives from personal relationships toward verifiable competency and integrity. This shift may improve legal certainty but also places more pressure on companies and individuals that have historically relied on internal staff or informal arrangements.

For individuals currently acting as authorized representatives without tax consultant status, the transition period until 31 December 2026 offers a limited window to obtain a tax consultant license or an SKT before the new requirements take full effect. The long-term effectiveness of this reform, however, will depend on the timely issuance of the implementing regulation governing the SKT, as well as the readiness of taxpayers and authorized representatives to adapt to the new framework. It will also depend on how smoothly the DGT applies the new rules in practice, especially for businesses that need continuity in handling dispute processes. (Shintya)