New Regulatory Framework for Tax Consultants and Taxpayer Representatives under PMK 55/2026

Introduction

On 22 July 2026, the Ministry of Finance of the Republic of Indonesia enacted Minister of Finance Regulation Number 55 of 2026 concerning Tax Consultants and Other Parties Acting as Taxpayer Representatives (“PMK 55/2026”), which came into force on 24 August 2026. PMK 55/2026 strengthens the regulatory framework concerning the professionalism, development, as well as guidance and supervision of two professional groups that serve as tax intermediaries within the national tax system, namely Tax Consultants and Other Parties Acting as Taxpayer Representatives.

PMK 55/2026 was issued to align the regulatory framework with developments in national financial sector legislation, including following the enactment of Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector, as amended by Law Number 4 of 2026, and Law Number 6 of 2023 concerning the Stipulation of Government Regulation in Lieu of Law Number 2 of 2022 concerning Job Creation. The Government also considered it necessary to expand the scope of guidance and supervision because Minister of Finance Regulation Number 111/PMK.03/2014 concerning Tax Consultants, as amended by Minister of Finance Regulation Number 175/PMK.01/2022, had previously not regulated other parties acting as taxpayer representatives. Accordingly, PMK 55/2026 replaces the previous regulatory framework by comprehensively regulating Tax Consultants and Other Parties Acting as Taxpayer Representatives.

Comparison

PMK 55/2026 revokes and replaces Minister of Finance Regulation Number 111/PMK.03/2014 concerning Tax Consultants, as amended by Minister of Finance Regulation Number 175/PMK.01/2022.

Key Provisions

• Expansion of the Scope of Guidance and Supervision

As provided in Article 2, the Minister is authorized to provide guidance, development, and/or supervision not only over Tax Consultants and Tax Consultant Offices, but also over Other Parties Acting as Taxpayer Representatives. Such authority includes, among other things, the determination and revocation of licenses, designation of the Tax Consultant Association, imposition of administrative sanctions, and issuance of Certificates of Registration.

In its implementation, some of the Minister’s authority is delegated to the Director General in the form of a mandate and delegation. Authority covering the determination of Tax Consultant Licenses through the determination of administrative sanctions in the form of revocation of Tax Consultant Licenses and Tax Consultant Office Licenses is delegated in the form of a mandate, whereas authority relating to the issuance of warnings and suspension of Tax Consultant Licenses, approval of the temporary cessation of the provision of services, changes to the name or closure of Tax Consultant Offices, determination of annual Tax Consultant examination plans, issuance of Certificates of Registration, and determination of administrative sanctions for Other Parties Acting as Taxpayer Representatives is delegated in the form of a delegation.

• Classification of Tax Consultant Licenses

Article 4 classifies Tax Consultant Licenses into three levels, namely Level A, B, and C licenses, which determine the scope of Taxpayers to whom tax services may be provided as follows:

• Form, Structure, and Ownership of Tax Consultant Offices

Article 16 establishes four forms of Tax Consultant Offices, namely sole proprietorships, civil partnerships, firms, and limited liability companies. Each form has different requirements relating to establishment, management, composition of Tax Consultants, and leadership as follows:

• New Regulation for Other Parties Acting as Taxpayer Representatives

Chapter IV provides specific regulations for Other Parties Acting as Taxpayer Representatives, applying mutatis mutandis the provisions concerning classification and licensing, competency, prohibitions, and administrative sanctions applicable to Tax Consultants. For this group, the document used is a Certificate of Registration, issued concurrently with a Competency Certificate and valid for 3 (three) years from the date of issuance, with its classification following the classification of the Competency Certificate. Other Parties are also required to provide services in accordance with the classification they hold and comply with the provisions of laws and regulations. From a supervisory perspective, the Director General may coordinate or conduct joint examinations with relevant units and/or parties, with an examination being conducted where there is information indicating an alleged violation in the process of providing services. Based on the examination results, the Director General may impose administrative sanctions and/or order the fulfillment of certain obligations. Administrative sanctions for Other Parties consist of suspension and revocation of the Certificate of Registration, which may be imposed non-sequentially, and their imposition and publication follow, mutatis mutandis, the provisions applicable to Tax Consultants.

• Strengthening of Administrative Sanctions and Public Transparency

PMK 55/2026 strengthens the provisions on administrative sanctions applicable to Tax Consultants and Tax Consultant Offices, consisting of warnings, suspension of licenses, and revocation of licenses, which may be imposed non-sequentially. A warning may be issued no more than 3 (three) times during the preceding 5 (five) years before proceeding to suspension, while suspension may likewise be imposed no more than 3 (three) times during the preceding 5 (five) years before the license is revoked. During the suspension period, Tax Consultants and/or Tax Consultant Offices are prohibited from providing services, but remain responsible for services already provided and for their obligations. A Tax Consultant or Tax Consultant Office whose license has been revoked may not submit a new license application. In addition, a Tax Consultant who is a suspect or defendant in a criminal offense in the field of taxation is subject to license suspension during the investigation and/or prosecution process, while a Tax Consultant convicted of a criminal offense in the field of taxation or another criminal offense is subject to license revocation. From a transparency perspective, warning sanctions may be published through the official website, while sanctions in the form of suspension and revocation of Tax Consultant Licenses and/or Tax Consultant Office Licenses must be announced to the public through the official website.

• Establishment of the Committee for Strengthening the Professionalism of Tax Consultants

Articles 56–59 regulate the establishment and working procedures of the Committee for Strengthening the Professionalism of Tax Consultants, established by the Minister to maintain integrity, enhance the professionalism of Tax Consultants, and improve the quality of tax services. 

Transitional Provisions

Referring to Article 60, Practice Licenses that have been issued under Minister of Finance Regulation Number 111/PMK.03/2014, as amended by Minister of Finance Regulation Number 175/PMK.01/2022, are declared to remain valid as Tax Consultant Licenses, such that existing licenses may continue to be used under PMK 55/2026. Meanwhile, applications for Practice Licenses, upgrades of Practice Licenses, and/or other Tax Consultant administrative services that are still in process continue to use the requirements under the previous regulations, but their completion is carried out based on PMK 55/2026.

In addition, Tax Consultant Associations that have been registered with the Ministry of Finance under the previous provisions are declared to remain registered under PMK 55/2026. Written reprimands, suspension of Practice Licenses, and revocation of Practice Licenses that have been determined under the previous regulations also remain valid until the relevant sanction period expires.

With respect to certification provisions, the Tax Consultant Certification Organizing Committee under the previous regulations may continue to administer certification until 31 December 2026. Tax Consultant Certificates issued under the previous provisions remain valid as Competency Certificates for a maximum period of 2 (two) years from the date of issuance and may be used as a requirement for an application for a Tax Consultant License until the Tax Consultant Association conducts the Tax Consultant professional examination. After such professional examination is conducted by the Tax Consultant Association, holders of old certificates must take the professional examination as one of the requirements for an application for a Tax Consultant License as provided in Article 5 paragraph (2).

Closing

With the issuance of PMK 55/2026, the Government has expanded and strengthened the regulatory framework applicable to Tax Consultants and Other Parties Acting as Taxpayer Representatives, not only with respect to licensing and competency, but also guidance, supervision, and enforcement of sanctions. The regulation also clarifies the structure and governance of Tax Consultant Offices and strengthens the role of Tax Consultant Associations in administering competency examinations and developing professionalism. For Tax Consultants and Tax Consultant Offices, changes in license nomenclature, increased competency development obligations, and strengthened examination and sanction publication mechanisms require attention in adapting their practices and governance. Meanwhile, for Other Parties Acting as Taxpayer Representatives, PMK 55/2026 provides a regulatory framework that was previously unavailable, including through the obligation to hold a Certificate of Registration, satisfy competency requirements, and be subject to administrative sanctions. With a transitional period that continues to recognize licenses, certifications, and processes already underway under the previous provisions, the parties have time to adjust their compliance and practices to the provisions of PMK 55/2026.