DJP's KEP-239/PJ/2026 opens a tax-sanction relief window: seven categories, most with a 30 June 2027 cut-off, and requests due by 1 October 2028

TaxKEP-239/PJ/2026UpdatedUpdated: October 15, 2026

Director General of Taxes Decision KEP-239/PJ/2026, signed on 8 October 2026 and in force the same day, puts into operation the sanction relief created by Article 27A of PMK 118/2024 as inserted by PMK 71/2026 (see our separate article). It says taxpayers "are granted" reduction or removal of administrative sanctions in seven categories: late filing of income-tax returns that show tax underpaid (annual returns up to tax year 2025, monthly returns up to September 2026), voluntary corrections, late payment, sanctions in assessment and collection letters issued from an audit, those issued before 8 October 2026, collection letters issued during the window, and sanctions on assets from the 2021 voluntary disclosure programme. Most categories qualify if the return is filed, or the tax and related amounts are paid, by 30 June 2027 (31 December 2027 for the voluntary-disclosure category); requests must reach DJP by 1 October 2028; and relief applies only to sanctions that are still unpaid, never to the tax itself. Media report the relief for late filing as 100% removal for returns filed from 8 October to 31 December 2026, 50% from 1 January to 31 March 2027 and 25% from 1 April to 30 June 2027; the Decision's annex, which sets the rate for each category, is not in the text we could read. DJP's Director General said on 14 October that the sanctions that could qualify total about Rp14.8 trillion and that the programme could bring in about Rp40.2 trillion of principal tax — an estimate, not a target.

Key points

  • Instrument: Director General of Taxes Decision KEP-239/PJ/2026 on tax policy relating to reduction or removal of administrative sanctions, signed by Director General Bimo Wijayanto in Jakarta on 8 October 2026 and in force on the date it was signed. It implements Article 27A of PMK 118/2024 as amended by PMK 71/2026.
  • Category (a), late returns: sanctions for late filing of the annual income-tax return for tax years up to 2025 and/or a monthly return for periods up to September 2026, with tax underpaid, filed between 8 October 2026 and 30 June 2027. Category (b), voluntary correction of those returns, and category (c), late payment or deposit of the tax due in them: filed and paid between the same dates.
  • Category (d), sanctions in assessment letters (SKP), land-and-building-tax assessments (SKP PBB) or collection letters (STP) issued from an audit between 8 October 2026 and 30 June 2027, with the related tax paid by 30 June 2027. Category (e), such letters issued before 8 October 2026, where the tax, tax debt and/or part of the sanctions is paid by 30 June 2027. Category (f), STP and STP PBB issued between 8 October 2026 and 30 June 2027, paid by 30 June 2027. Administrative fines on land and building tax are included in (d)–(f).
  • Category (g), voluntary disclosure: sanctions in an SKP issued from an audit of assets not or under-disclosed under PMK 196/PMK.03/2021 (the 2021 voluntary disclosure programme), issued between 8 October 2026 and 31 December 2027, with the related tax paid by 31 December 2027.
  • Deadline and conditions: the request must reach the Director General of Taxes by 1 October 2028 and meet Articles 23 and 24 of PMK 118/2024. It must attach a statement, signed on stamp duty paper, that no lawsuit or other legal remedy has been filed (or the withdrawal request if one was filed) and a stamped statement that the sanction arose from oversight (kekhilafan) rather than fault. Relief applies only to sanctions not yet paid or settled.
  • Rates, as reported — we have not seen the annex: for late filing with tax underpaid, 100% removal for returns filed 8 October–31 December 2026, 50% for 1 January–31 March 2027 and 25% for 1 April–30 June 2027 (DDTCNews, Kontan). The annex is said to use levels of 100%, 90%, 75%, 50% and 25% depending on sanction type and timing, and it also holds the sanction types, special conditions, worked examples and the sample statement and request forms.
  • What it does not do: the relief covers the sanction, not the tax. PMK 71/2026 requires the tax behind a sanction to be paid, and the Decision's own wording in (e) and (f) is that the tax, tax debt and/or part of the sanctions is paid; how the two fit together is for the annex, which we have not read. The text we read names no submission system, and the sample request and statement formats are in the annex.
  • DJP's own estimate, given by the Director General on 14 October at a press event in Jakarta (Kontan): sanctions that could qualify total about Rp14.8 trillion, and the programme could bring in about Rp40.2 trillion of principal tax, built from supervision (Rp12 trillion of tax, Rp5.7 trillion of sanctions), examination (Rp13 trillion and Rp2.9 trillion), collection (Rp9.6 trillion and Rp3.7 trillion) and the use of new databases (Rp5.6 trillion and about Rp2.5 trillion). He called it an estimate, not a formal target, that will deviate depending on taxpayers' "risk appetite".

What this means for your Indonesian entity

This is a time-limited chance to clear tax sanctions at a discount, and the Director General's own estimate shows it sits next to enforcement: DJP counts on the programme alongside supervision, audits, collection and new databases, so expect those to continue. Practical steps: (1) List what you have — late annual returns up to tax year 2025, late monthly returns up to September 2026, corrections you have been meaning to file, unpaid sanctions in assessment or collection letters (including land-and-building-tax fines), and any voluntary-disclosure assessment — and note which category each falls in. (2) For late filing the reported schedule steps down from 100% to 50% to 25% at 31 December 2026 and 31 March 2027, so a late return filed this year appears to carry the largest relief; confirm the rate for your category in the annex with your adviser before relying on any percentage. (3) The relief covers the sanction, not the tax: pay the tax, and because relief applies only to sanctions that are still unpaid, take advice before paying the sanction part of any letter. (4) Prepare the two stamped statements, and if you have an objection or lawsuit running on the same letter, decide with your adviser whether to withdraw it, since the relief requires that none is pending. (5) Put 1 October 2028 in the diary as the last day for the request, and use the sample formats in the Decision's annex. This is orientation, not advice; for a specific letter the Decision's annex and your tax adviser govern.

Sources

This page summarises publicly available information for orientation. It is not tax, legal, or accounting advice, and regulations change. Verify against the linked primary sources and contact us before acting on anything here.

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