SP2DK Response Deadlines Under PMK 111/2025
PMK 111/2025 sets the response period for an Indonesian tax clarification letter: 14 days from issue in the Taxpayer Account, plus 7 days if the tax office receives notice before the deadline.
Key points
- The 7-day extension counts only if the tax office receives the notice before the deadline.
- For a letter in the Taxpayer Account, the 14 days run from the issue date, not the date it is read.
- Article 8 lists 17 possible outcomes, including limits on public services and a tax audit.
PMK 111/2025 took effect on 1 January 2026 and governs supervision of registered taxpayers, unregistered taxpayers, and tax regions. Article 3(2) says supervision is based on research into data and information held by the Directorate General of Taxes.
For companies, Article 6 matters first. Article 6(2) gives up to 14 days to respond to a request for an explanation of data or information, known as an SP2DK, counted from the earliest of five delivery events.
A letter sent through the Taxpayer Account counts from its issue date. A letter sent by registered email counts from the date it was sent. The deadline can start before anyone at the company has opened the letter.
The 7-day extension has a timing condition
Article 6(5) allows an extension of up to 7 days with written notice to the tax office that issued the letter. Article 6(6) requires the office to receive that notice before the deadline ends. A notice posted on day 14 is therefore at risk. Article 6(7) allows the Taxpayer Account, post, or hand delivery.
If the response is not accepted
Article 6(11) covers three situations: the response does not match, further data has emerged, or the taxpayer has not responded. In each, the tax office may invite the taxpayer to a discussion or make a visit. Discussions are held in person or by video conference and recorded in minutes.
Article 4(4) requires taxpayers to attend when invited and to allow visits. During a visit, Article 23 requires officers to show their identification and supervision order and to explain the activity. The taxpayer may ask for these.
Article 8(1) lists 17 possible outcomes. The lightest is closing the matter. Others include changes to data by the tax office, ex officio VAT registration, limits on certain public services, a tax audit, and a preliminary evidence examination.
Advisory and warning letters have their own track. Article 10(2) gives 14 days to respond to an advisory letter. Article 13 ties warning letters to late tax returns and compliance with tax rules.
What to set up now
First, name one person and a backup to check the Taxpayer Account every working day, and confirm the registered email address is active. Then log each letter by issue date, not the date it was read.
When a letter arrives, decide by day three or four whether the reconciliation can finish in 14 days. If not, send the extension notice through a channel with a certain receipt date.
Prepare the response on the data requested, with supporting documents. See our page on SP2DK response support.
Frequently asked questions
Can we respond more than once?
Yes. Article 6(8) allows more than one response within the period or its extension.
What if we disagree with the data in the letter?
Article 6(4) requires the explanation to come with evidence or supporting documents.