On 16 July 2026, the Directorate General of Taxes (Direktorat Jenderal Pajak or “DGT”) issued Circular Letter No. SE-9/PJ/2026 on Procedures for Requesting Information and/or Evidence or Explanations in connection with the Implementation of Access to Financial Information for Tax Purposes (the “Circular Letter”). The Circular Letter serves as an implementing regulation for Minister of Finance Regulation No. 108 of 2025 on Technical Guidelines for Access to Financial Information for Tax Purposes (“MOF Regulation No. 108/2025”).
Background
The DGT is authorized to obtain financial information from financial institutions, including banks, insurance companies, securities companies and other financial services institutions, as well as from crypto-asset service providers that qualify as reporting entities under the Crypto-Asset Reporting Framework (“CARF”). Such authority may be exercised for tax purposes, both in connection with the implementation of international agreements concerning the exchange of information and in the administration and enforcement of Indonesian tax laws and regulations.
Access to financial information may generally be exercised through two mechanisms. The first is the automatic and periodic submission of reports containing financial information to the DGT, without the need for the DGT to issue a specific request in respect of each taxpayer. The second is the provision of financial information in response to a specific request issued by the DGT. The Circular Letter specifically regulates the second mechanism. It provides internal procedural guidance for DGT officials in requesting information and/or evidence or explanations (Informasi dan/atau Bukti atau Keterangan or “IBK”) from financial institutions and CARF-reporting crypto-asset service providers in connection with the exercise of the DGT’s authority to access financial information for tax purposes.
The DGT may request financial information for a broad range of tax administration and enforcement purposes. These include tax compliance monitoring, tax audits, tax collection, investigations of tax-related criminal offences, the exchange of information under applicable international arrangements, and the handling of tax disputes and other legal remedies.
Content of IBK Request
An IBK request issued by the DGT must, at a minimum, specify the basis for the request, the information and/or evidence or explanations being sought, the required format and form of submission, the reasons for the request, and the applicable deadline for compliance. These requirements are intended to ensure that each request is clearly defined and can be properly assessed and processed by the relevant financial institution or CARF-reporting crypto-asset service provider.
The requested IBK may cover a broad range of financial information relating to a financial account. This may include the identity of the account holder, the account number and any sub-account, the type of account, the account opening and/or closing date, the account balance or value, transaction records, and the location of the relevant transactions.
The Circular Letter also allows the DGT to request other relevant financial information maintained by the relevant financial institution or CARF-reporting crypto-asset service provider. As the list is non-exhaustive, the scope of an IBK request may extend beyond the specifically listed items, provided that the additional information is relevant to the applicable tax purpose and is identified in the request letter.
Access to Financial Information of Taxpayer-Related Parties
In addition to information relating directly to a taxpayer, the Circular Letter allows the DGT to request financial information concerning parties associated with the taxpayer where such information is relevant to tax compliance monitoring. These parties may include individuals forming part of the taxpayer’s family data unit, members of the management of a company, the taxpayer’s authorized representative, shareholders, beneficial owners, and any other party possessing information required to support the DGT’s monitoring of the taxpayer’s compliance.
This broader scope enables the DGT to examine financial relationships and transactions involving persons or entities connected with the taxpayer, rather than limiting its review solely to accounts held in the taxpayer’s own name. Accordingly, information concerning related parties may be requested where it is considered necessary to assess the completeness and accuracy of the taxpayer’s reporting or to identify potential tax compliance risks.
Channels for IBK Requests and Submissions
IBK requests and the corresponding submission of IBK by financial institutions and CARF-reporting crypto-asset service providers are generally carried out through electronic channels integrated with the DGT’s administration system. These channels include Coretax, through the Third-Party Data Portal, the Financial Institution Reporter Portal, or a host-to-host connection where the reporting entity’s system is directly connected to the DGT’s system. IBK may also be exchanged through the Financial Information Access Application (Aplikasi Akses Informasi Keuangan or ASIK) or through another website or application integrated with the DGT’s administration system.
Where the relevant electronic channel is not yet available or cannot be used, the IBK request and submission may be carried out through non-electronic means. This includes direct delivery or delivery by post, courier or logistics service provider, supported by proof of dispatch.
Conclusion
The Circular Letter reinforces the DGT’s ability to obtain detailed financial information not only in relation to taxpayers, but also in relation to their management, shareholders, beneficial owners, representatives and other connected parties where relevant to tax compliance monitoring. Although the Circular Letter primarily provides internal procedures for DGT officials and reporting entities, its practical impact extends to a broad range of business actors whose financial information may become part of a tax review, audit, collection process, dispute or investigation.
Businesses should therefore ensure that their tax filings are consistent with their financial records, bank account movements, ownership information and transactions with shareholders, management, affiliates and other related parties. Particular attention should be given to transactions that may not be immediately apparent from the company’s tax returns, including shareholder funding, related-party payments, reimbursements, intercompany transactions and transactions involving accounts held by connected persons.
From a governance perspective, businesses should also maintain complete and accessible supporting documents, clear beneficial ownership records and reliable audit trails for significant financial transactions. Any discrepancy between tax reporting and information maintained by financial institutions or crypto-asset service providers may increase the likelihood of further enquiries from the DGT. Accordingly, businesses may wish to conduct periodic internal reconciliations and address potential inconsistencies before they are identified through an IBK request.
For further information, please contact:
MetaLAW, Legal & Tax Consultant, Jakarta, Indonesia
general@metalaw.id
