PMK 28 Tahun 2026 (PMK 28/2026) is the Minister of Finance Regulation that governs preliminary refunds of tax overpayments (pengembalian pendahuluan) and VAT refunds in Indonesia. It took effect on 1 May 2026, fully replaces PMK 39/PMK.03/2018 and its three amendments, and tightens eligibility for faster tax refunds in Indonesia (restitusi pajak dipercepat) under Articles 17C and 17D of the KUP Law and Article 9(4c) of the VAT Law.
Key changes in one view:
- Previous Taxpayer with Certain Criteria status ended on 1 May 2026.
- An Unqualified Opinion (WTP) alone is no longer enough: six cumulative financial statement requirements now apply.
- Taxpayers must have no late tax payments in the last five years.
- The VAT overpayment cap for PKP with Certain Requirements falls from Rp5 billion to Rp1 billion per tax period.
- PKP can no longer qualify as Low-Risk PKP through the Certain Requirements route.
- Low-Risk PKP need 12 months of on-time Periodic VAT Returns (SPT Masa PPN).
What Is PMK 28/2026 and Why Was It Issued?
PMK 28/2026 is a complete replacement of Indonesia’s preliminary tax refund framework, not an amendment. It revokes PMK 39/PMK.03/2018 and all three of its amendments: PMK 117/PMK.03/2019, PMK 209/PMK.03/2021, and PMK 119 of 2024.
The regulation has two stated aims:
- Accuracy and legal certainty in how preliminary refunds of tax overpayments are granted.
- A response to the Corruption Eradication Commission (KPK RI), which recommended that refund policy weigh a Taxpayer’s substantive compliance track record and potential for fraud, not only formal compliance.
Important: Because PMK 28/2026 replaces the old rules entirely, every Taxpayer and Taxable Entrepreneur (PKP) that holds a designation status under the previous regulations must review the new provisions, which have applied since 1 May 2026.
Taxpayers with Certain Criteria (Article 17C KUP): What Changed?
PMK 28/2026 significantly tightens the criteria for designation as a Taxpayer with Certain Criteria (Wajib Pajak Kriteria Tertentu). Timely filing of tax returns remains a core requirement and is unchanged. The payment history and financial statement requirements are now much stricter.
Tax payment history
To qualify, a Taxpayer must meet both conditions:
- No tax arrears as of 31 December of the preceding year, except arrears for which approval to pay in installments or to defer payment has been granted, or which have expired under the statute of limitations.
- No late payments in the last five years for all types of taxes, including installments.
DGT decision deadline
The Directorate General of Taxes (DGT) must issue a designation decision or a notice of rejection within 30 working days, replacing the previous period of one calendar month. If the DGT does not respond within this period, the application is deemed granted.
Six financial statement requirements
An Unqualified Opinion (Wajar Tanpa Pengecualian, WTP) for three consecutive years is no longer sufficient on its own. All six of the following requirements must now be met cumulatively:
- Pure WTP opinion: the opinion must be a pure Unqualified Opinion without an explanatory paragraph.
- No restatement: the financial statements are not a restatement resulting from the correction of errors or data manipulation, as evidenced by a statement letter from the Taxpayer.
- SP2DK responded to: where a Request for Explanation of Data and/or Information (SP2DK) on fiscal profit/loss was issued at least three months before the designation date, the SP2DK has been responded to or discussed in accordance with PMK-111.
- Correction below 5%: there is no fiscal profit/loss correction exceeding 5% based on tax audit results for the last three tax years that are final and binding or have been agreed to by the Taxpayer.
- Auditor rotation: the public accountant complies with the five-year rotation limit for audit services, as evidenced by a statement letter from the Taxpayer.
- Attached to the return: the financial statements are attached to the Annual Income Tax Return (SPT Tahunan PPh).
Taxpayers with Certain Requirements (Article 17D KUP): New Refund Thresholds
Under PMK 28/2026, the refund cap for VAT-registered Taxable Entrepreneurs (PKP) with Certain Requirements falls from Rp5 billion to Rp1 billion per tax period, and a new delivery limit of Rp0 to Rp4.2 billion per tax period applies. Corporate Taxpayers keep the Rp1 billion cap but must now also have business turnover of Rp0 to Rp50 billion.
Separation of routes: PMK 28/2026 separates PKP with Certain Requirements from Low-Risk PKP. Previously, a PKP that met the Certain Requirements could also be categorized as a Low-Risk PKP. This is no longer possible. A PKP must use the route that matches its own characteristics and criteria.
Low-Risk PKP (Article 9(4c) VAT Law): Who Qualifies for a Faster VAT Refund?
PMK 28/2026 keeps eight categories of Low-Risk PKP (PKP Berisiko Rendah) eligible for a preliminary VAT refund (restitusi PPN). It removes the category “PKP that meets the Taxpayer with Certain Requirements criteria”, and adds an 80% certain-activities threshold.
The eight Low-Risk PKP categories
- Public companies whose shares are traded on the Indonesia Stock Exchange.
- State-Owned Enterprises (BUMN) and Regional-Owned Enterprises (BUMD).
- Customs Main Partners (Mitra Utama Kepabeanan).
- Authorized Economic Operators (AEO).
- Manufacturers or producers that have production facilities.
- Pharmaceutical Wholesalers (PBF) holding a pharmaceutical distribution certificate and a Good Drug Distribution Practice (CDOB) Certificate.
- Medical Device Distributors holding a distribution certificate and a Good Medical Device Distribution Practice (CDAKB) Certificate.
- Subsidiaries of BUMN in which BUMN holds more than 50% of the shares, as listed in the consolidated financial statements of the parent BUMN.
What is no longer allowed
A PKP can no longer obtain Low-Risk status based only on overpayment or business turnover thresholds, because the category “PKP that meets the Taxpayer with Certain Requirements criteria” has been removed.
New compliance requirements
PMK 28/2026 reinstates the requirement for timely filing of Periodic VAT Returns (SPT Masa PPN). A single late filing may be grounds for rejecting the application or revoking Low-Risk PKP status. The PKP must also:
- Have no late filing of Periodic VAT Returns in the last 12 months; and
- Not be undergoing a tax audit for the tax period being applied for.
The 80% certain-activities threshold
A Low-Risk PKP must show that at least 80% of the total value of deliveries of Taxable Goods/Taxable Services (BKP/JKP) and exports of BKP/JKP in the Tax Period applied for are qualifying certain activities. Deliveries granted a VAT exemption facility and deliveries not subject to VAT are excluded from the calculation. This threshold also applies to the Tax Period at the end of the financial year.
What Should Taxpayers and PKP Do Now?
Taxpayers and PKP should check their status and eligibility under PMK 28/2026 as soon as possible. The actions depend on which refund route you use.
Conclusion: A Stricter Path to Faster Tax Refunds in Indonesia
PMK 28/2026 is a substantive policy change, not just a recodification. It tightens Taxpayer with Certain Criteria designation through six WTP financial statement requirements, reinstates the VAT overpayment cap for PKP with an added turnover threshold, reinstates the on-time Periodic VAT Return requirement for Low-Risk PKP, and quantifies the 80% certain-activities threshold explicitly for the first time.
The tightening follows the Corruption Eradication Commission (Komisi Pemberantasan Korupsi) of Indonesia recommendation and the DGT’s aim to give accelerated tax refunds only to Taxpayers with a strong formal and substantive compliance track record. It also signals that the DGT will increasingly use the Coretax system to validate overpayment claims before refunds are made.
