Indonesia has changed the rules for who may formally represent a taxpayer before the Directorate General of Taxes (DJP). The change does not mean that every employee handling routine tax administration suddenly needs a certificate. It matters when someone is appointed as a Kuasa Wajib Pajak through a Surat Kuasa Khusus to exercise specified tax rights or obligations on the taxpayer's behalf.
PMK 44/2026 was enacted on 22 June 2026 and took effect on 7 July 2026. It revoked PMK 229/PMK.03/2014 and now recognises three categories of proxy: Konsultan Pajak, Pihak Lain, and Keluarga.
What changes for company staff?
The old regulation expressly listed a taxpayer's employee as a possible proxy. PMK 44/2026 removes that stand-alone category. An employee may still be appointed, but as Pihak Lain and subject to the applicable competency and registration requirements.
Companies should distinguish three roles:
- Staff doing internal preparation, reconciliation, or document collection are not automatically a Kuasa Wajib Pajak.
- A person named in a Surat Kuasa Khusus to perform a specified tax action is a formal proxy and must satisfy the proxy rules.
- A director or qualifying manager acting as the corporate taxpayer's statutory wakil under Article 32 of the KUP Law has a different legal role from an appointed proxy.
The legal authority granted matters more than the person's job title.
Transition through 31 December 2026
Article 16 gives non-consultants a transition route until 31 December 2026. A person may still be appointed as a proxy if they hold either a tax brevet certificate or at least a Diploma III tax qualification issued by a public or private higher-education institution with A accreditation.
The taxpayer must use a paper Surat Kuasa Khusus, attach a copy of the qualifying certificate or diploma, and submit it directly through the relevant KPP or KP2KP for administration in the DJP system. The power remains valid until the specific tax matter it covers is completed.
A Surat Kuasa Khusus already submitted to DJP before PMK 44/2026 took effect also remains usable for its specified matter.
From 1 January 2027
DJP's official explanation states that from 1 January 2027, Pihak Lain must have an SKT registered in the DJP system to act as a taxpayer proxy. Companies relying on an employee, in-house accountant, independent adviser, or another non-consultant for formal representation should prepare before the transition ends.
A qualifying family member does not need a tax-consultant licence or SKT, but still needs a Surat Kuasa Khusus and evidence of the family relationship. The taxpayer also remains responsible for the tax rights and obligations entrusted to any proxy.
What companies should do now
- Map who only prepares tax work and who formally acts before DJP.
- Review each Surat Kuasa Khusus, including its scope, validity, and submission status.
- Classify each representative correctly as wakil, Konsultan Pajak, Pihak Lain, or Keluarga.
- If using the 2026 transition, check the brevet or qualifying diploma and submit the required paper documents.
- If a non-consultant will continue as proxy in 2027, verify the SKT pathway before year-end.
- Keep a register of powers, portal access, revocations, and assigned tax matters.
The risk is not that all internal tax work must be outsourced. It is that a company may confuse internal assistance with formal authority and discover the gap when a filing, objection, audit response, or other action requires recognised representation.
Bali Zero view
Treat PMK 44/2026 as an authority-and-evidence review, not a reason for panic. Companies can preserve continuity by identifying formal proxies, checking their credentials, and preparing for the 2027 SKT requirement without unnecessarily replacing competent internal staff.
Official sources
Bali Zero
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