PMK 28/2026: Indonesia Updates Its Accelerated Tax Refund Framework

The Indonesian Government has introduced Minister of Finance Regulation No. 28 of 2026 concerning accelerated tax refunds (“PMK 28/2026”). The regulation came into effect on 1 May 2026 and replaces the previous framework under PMK 39/2018, as last amended by PMK 119/2024.

Through PMK 28/2026, the government seeks to establish a tax refund mechanism that is not only faster, but also more structured and accountable. In addition to strengthening legal certainty, the regulation places greater emphasis on data validation, compliance monitoring, and the digitalisation of tax administration.

Although accelerated refunds continue to be processed without a full tax audit, the Directorate General of Taxes (“DGT”) is now given broader authority to conduct more detailed verification and research prior to the issuance of refunds.

Main Focus of the New Regulation

In general, PMK 28/2026 introduces several key adjustments to the accelerated tax refund mechanism, including:

• refinement of taxpayer eligibility requirements
• strengthening of formal and material verification by the DGT
• clearer procedures and processing timelines
• digitalisation of refund applications through the Coretax system
• enhanced post-refund supervision mechanisms

These changes indicate a more risk-based and compliance-oriented approach in the administration of accelerated tax refunds.

Clearer Taxpayer Eligibility Criteria

PMK 28/2026 maintains the existing three categories of taxpayers eligible for accelerated refunds. However, each category is now accompanied by more detailed compliance indicators.

Taxpayers with Certain Criteria

This category is intended for taxpayers with a strong compliance track record. Key requirements include timely tax return submissions, no outstanding tax liabilities, unqualified audit opinions (WTP) for three consecutive years, and no tax-related criminal conviction within the past five years.

The regulation also introduces additional clarifications regarding compliance measurement. For example, monthly tax return filing compliance is now assessed more strictly. In addition, financial statements must not result from restatements caused by errors or manipulation, and fiscal corrections arising from tax audits must not exceed 5%.

Through these provisions, the government aims to ensure that accelerated refund facilities are granted only to taxpayers with consistent compliance records.

Taxpayers with Certain Requirements

This category generally applies to taxpayers with smaller business scales and relatively low-risk tax profiles.

Eligible taxpayers include:

• individual taxpayers with non-business income
• individual business taxpayers with overpayment claims up to IDR 100 million
• corporate taxpayers with annual turnover up to IDR 50 billion and overpayment claims up to IDR 1 billion
• VAT-registered businesses with taxable deliveries up to IDR 4.2 billion and VAT overpayment claims up to IDR 1 billion

This framework is intended to simplify the refund process for small and medium-sized taxpayers with relatively straightforward tax administration profiles.

Low-Risk VAT-Registered Businesses

PMK 28/2026 also expands the scope of low-risk VAT-registered businesses (“PKP Berisiko Rendah”). In addition to publicly listed companies and state-owned enterprises, the category now includes primary customs partners, Authorized Economic Operators (AEO), manufacturing companies, pharmaceutical wholesalers, and medical device distributors.

To qualify under this category, taxpayers must satisfy several additional requirements, including compliance in submitting monthly VAT returns over the past 12 months, no ongoing tax audit or investigation, and no history of tax-related criminal offences within the last five years.

The broader scope reflects the government’s intention to facilitate faster refunds for businesses considered administratively reliable.

Greater Digitalisation Through Coretax

One of the more significant developments under PMK 28/2026 is the stronger integration of digital systems into the refund application process.

Applications are now submitted through the Coretax platform, allowing the process to become more integrated and properly documented. For certain taxpayers, refund requests can be made simply by completing the refund section within the tax return.

In addition, taxpayers may still submit separate applications for additional overpayment claims if necessary.

This digitalisation is expected to reduce manual processes, accelerate data verification, and improve overall administrative efficiency within the tax system.

More Detailed Verification by the DGT

PMK 28/2026 also provides clearer guidelines regarding the scope of verification conducted by the DGT before refunds are granted.

Under formal verification, the DGT will assess whether taxpayers continue to satisfy the required administrative criteria, including filing and payment compliance. The DGT will also verify whether the taxpayer is currently subject to tax audit or investigation.

Meanwhile, material verification focuses on the substance of the refund claim itself. In this stage, the DGT may review:

• the accuracy of tax calculations
• the validity of withholding tax documents and tax payment evidence
• the validity of input VAT recorded within the DGT system
• the consistency between business activities and the refund claim submitted

This demonstrates that although accelerated refunds do not involve a full audit, the verification process remains comprehensive.

Refund Timelines Remain Unchanged

PMK 28/2026 reaffirms the statutory timelines for accelerated tax refunds based on taxpayer categories.

For taxpayers with certain criteria, income tax refunds must be processed within a maximum of three months, while VAT refunds must be completed within one month. For taxpayers with certain requirements, refunds for individual taxpayers must be processed within 15 working days, while corporate taxpayers and VAT refunds remain subject to a one-month processing period.

Meanwhile, VAT refunds for low-risk VAT-registered businesses continue to be processed within one month.

Importantly, if the DGT fails to issue a decision within the prescribed timeframe, the refund application will be deemed automatically approved.

Refunds May Still Be Reassessed

Although refunds may already have been disbursed, PMK 28/2026 confirms that the DGT retains the authority to conduct further examination afterwards. If inconsistencies or non-compliance are identified, previously granted refunds may still be corrected and subject to further tax enforcement measures.

In addition, taxpayer eligibility status may be revoked if taxpayers fail to submit tax returns on time, incur tax arrears, experience issues in their financial reporting, or become involved in tax-related criminal matters.

As such, accelerated refunds under PMK 28/2026 remain firmly tied to ongoing taxpayer compliance and supervision.

结论

PMK 28/2026 represents another important step in the government’s effort to modernise Indonesia’s accelerated tax refund framework through stronger digital integration, enhanced compliance standards, and more structured verification procedures.

While the regulation continues to provide faster refund mechanisms for compliant taxpayers, it also reinforces the importance of accurate reporting, reliable documentation, and consistent administrative compliance.

Going forward, taxpayers will need to ensure that their tax administration processes, reporting quality, and supporting documentation are properly maintained in order to continue benefiting from accelerated refund facilities.

Reanda Bernardi’s Perspective

The introduction of PMK 28/2026 highlights the increasing importance of strong administrative compliance within Indonesia’s tax system. Companies should ensure that their tax reporting, supporting documentation, and internal administrative procedures align with the latest regulatory standards to maintain eligibility for accelerated tax refunds.

As Indonesia’s tax administration becomes increasingly digitalised and data-driven, effective compliance management will play an important role not only in minimising risks, but also in supporting smoother and more efficient business operations.