Objectives of the Enactment of MoF Regulation 108/2025
On 31 December 2025, Ministry of Finance (“MoF”) Regulation No. 108 of 2025 on the Technical Guidelines for Access to Financial Information for Tax Purposes (“MoF Regulation 108/2025”) was enacted as one of the follow-up measures to the execution of the Addendum to the Multilateral Authority Agreement on Automatic Exchange of Financial Account Information (“Multilateral Authority Agreement”), in which the Indonesian government details the framework for Automatic Exchange of Information (“AEOI”) and Common Reporting Standard (“CRS”).
AEOI dan CRS in Indonesia
AEOI itself refers to the obligation to the exchange of information conducted at predetermined times, on a periodic, systematic, and continuous basis, concerning financial information related to taxation.
In itself, such AEOI would have to be reported in accordance to the CRS standard as established by the Organisation for Economic Co-operation and Development (OECD), in which sets out the reporting standards and financial account identification procedures as referenced in or governed by international agreements, for use in the implementation of AEOI on financial account information among countries or participating jurisdictions.
To this end, please note that certain financial institutions and other CRS entities carrying out activities as deposit institutions, custodian institutions, certain insurance companies, and/or investment entities as further governed under MoF Regulation 108/2025, would be required to carry out such CRS reporting. By mandating them to comply with this procedure, financial activities conducted thereunder would be monitored in a more steady and transparent manner, which inherently allows for the government to combat tax evasion and incentivize more compliance to taxpayers.
Updating the List of Participating Jurisdictions and Destination Jurisdictions
MoF Regulation 108/2025 attributes authority to the Directorate General of Taxation (“Tax Authority”) to make public announcements, which shall include information on: (i) the list of AEOI-CRS participating jurisdictions; (ii) the list of AEOI-CRS Destination Jurisdictions; (iii) the list of AEOI-CARF Participating Jurisdictions; (iv) the list of AEOI-CARF Destination Jurisdictions; (v) the list of types of non-reporting financial institutions classified as Financial Services Institutions, other Financial Services Institutions, and/or other entities; (vi) the list of types of excluded financial accounts; and (vii) information relating to financial account identification procedures and reporting submissions.
In relation to the above, as of 20 January 2026, Tax Authority has issued Announcement No. Peng-1/PJ/2026 on the List of Participating Jurisdictions and Destination Jurisdictions for the Purpose of the Automatic Exchange of Financial Account Information (Automatic Exchange of Financial Account Information/“AEOI-CRS”) for 2026 (the “Announcement”), as an update to Announcement No. Peng-1/PJ/2025 of 2025. The Announcement provides information on two matters, namely:
- AEOI-CRS Participating Jurisdictions:
AEOI-CRS Participating Jurisdictions refers to foreign jurisdictions that are bound with the Indonesian Government under international agreements to conduct AEOI-CRS. In terms of numbers, the Appendix to the Announcement states that there are now a total of 117 AEOI-CRS Participating Jurisdictions, providing an increase of 2 participants from the previous year; and
- AEOI-CRS Destination Jurisdiction:
AEOI-CRS Destination Jurisdictions refer to AEOI-CRS Participating Jurisdictions that serve as the destinations for the Indonesian Government in fulfilling its obligation to automatically exchange financial account information. In terms of numbers, the Appendix to the Announcement states that there are total of 92 AEOI-CRS Destination Jurisdictions, providing an increase of 3 other jurisdictions from the previous year.
Based on the foregoing, this trend shows an increase of AEOI-CRS Participating Jurisdictions and AEOI-CRS Destination Jurisdictions allows for a more reciprocal relationship and aids the Indonesian Government (and subsequently, other international governments) in achieving more transparency and better efficiency in combatting tax evasion.
Conclusion
MoF Regulation 108/2025 strengthens Indonesia’s implementation of the exchange of financial account or AEOI, in line with international commitments under the OECD’s CRS. It authorizes the Tax Authority to publish official lists of Participating and Destination Jurisdictions, list of jurisdictions, and other technical matters related to financial account reporting.
Through the Announcement, Indonesia has now confirmed that there are 117 AEOI-CRS Participating Jurisdictions and 92 AEOI-CRS Destination Jurisdictions. This framework reflects a reciprocal mechanism whereby Participating Jurisdictions are those that exchange financial account information with the Indonesian Government, while Destination Jurisdictions are the destinations to which Indonesian Government transmits such information. Overall, given that the trend in having more countries act as Participating Jurisdictions and Destination Jurisdictions, allows for Indonesia to enhance legal certainty, transparency, and compliance with global tax information exchange standards.
For Further Information, Please Contact:
MetaLAW, Legal Consultant, Jakarta, Indonesia
general@metalaw.id
