New Finance Minister says tax refunds that are due "will be paid" — but DJP keeps its "selective" approach, under preliminary-refund rules tightened by PMK 28/2026

TaxPMK 28/2026Issued: September 18, 2026

Tax refunds (restitusi) have become one of the most visible pressure points on businesses in Indonesia this year, and the new Finance Minister addressed them in his first budget press conference on Friday 18 September. Suahasil Nazara said refunds that are a business's right "will certainly be given," and that he has instructed Director General of Taxes Bimo Wijayanto to manage refunds — including communicating how they are being managed. That is reassurance, not a change of policy: three days earlier Bimo had described refund processing as "selective, more measured, more planned" and directed at sectors that are genuinely compliant, with several companies' claims under audit. The rules underneath have tightened too. PMK 28/2026, in force since 1 May, cut the ceiling for fast-track (preliminary) VAT refunds from Rp5 billion to Rp1 billion per period and added a Rp4.2 billion deliveries cap, voided every existing "compliant taxpayer" designation, and made re-qualifying harder. The same briefing put the budget deficit at Rp240.1 trillion (0.93% of GDP) at the end of August; the latest full-year outlook, published in July, is 2.85% of GDP — above the 2.68% budgeted and close to the 3% legal ceiling.

Key points

18 September, APBN KiTa press conference at the Ministry of Finance: Finance Minister Suahasil Nazara — "If it is the right of the business, it will certainly be given." He said he has asked DG of Taxes Bimo Wijayanto to handle refund management, "including communication about the refund management we are running." No new regulation or change of procedure was announced.
15 September, after the ministerial handover: DG Bimo said refunds are processed "selectively, more measured, more planned, directed at sectors that are genuinely compliant," that several companies' claims are under audit in line with standard procedure, and that refunds will follow the new minister's direction while accommodating development-financing needs and keeping the budget sustainable. Apindo chair Shinta Kamdani asked both agencies for faster resolution, citing corporate cash flow.
Scale, as reported rather than officially published: a University of Indonesia (FEB UI) study cited on 16 September puts VAT refunds paid through August 2026 at Rp130.9 trillion, against roughly Rp190–200 trillion in the same period of 2025.
PMK 28/2026 on preliminary refunds (pengembalian pendahuluan) — signed 29 April 2026 by then-minister Purbaya, promulgated 30 April, in force 1 May 2026 — replaces PMK 39/PMK.03/2018 and its three amendments (117/PMK.03/2019, 209/PMK.03/2021 and PMK 119/2024). A preliminary refund is decided by "research" (penelitian) of the claim rather than a tax audit.
Who can use it — taxpayers meeting certain requirements (Article 17D of the KUP Law): individuals without business income; individuals with business income and an overpayment of up to Rp100 million; companies with turnover up to Rp50 billion and an overpayment up to Rp1 billion; and VAT-registered businesses (PKP) with deliveries up to Rp4.2 billion and a VAT overpayment up to Rp1 billion per period. The PKP ceiling was previously Rp5 billion, with no deliveries cap.
"Compliant taxpayer" status (WP kriteria tertentu, Article 17C KUP): every designation issued under the old rules lapsed on 1 May 2026. Re-applications were accepted from 1 to 10 June 2026 (or on the regular annual schedule), with a decision due within 30 working days. The criteria are stricter: an unqualified audit opinion without an explanatory paragraph for three consecutive years; no restatement from correction of errors or manipulation; the audit firm within its five-year engagement limit; fiscal profit/loss corrections from tax audits of no more than 5% over the last three years; and any request for explanation of data (SP2DK) issued at least three months before designation answered.
Low-risk PKP (Article 9(4c) of the VAT Law) keep per-period preliminary VAT refunds for exports, deliveries to VAT collectors and supplies where VAT is not collected — but only if they are listed companies, state- or region-owned enterprises or their more-than-50% subsidiaries, customs MITA or AEO holders, manufacturers with their own production site, or licensed pharmaceutical wholesalers or medical-device distributors, with 12 months of on-time VAT returns and no open preliminary-evidence audit or tax-crime investigation.
Decision deadlines run from receipt of the application: for compliant taxpayers, three months (income tax) or one month (VAT); for Article 17D taxpayers, 15 working days (individual income tax) or one month (corporate income tax and VAT); for low-risk PKP, one month. If DJP misses the deadline, the application is deemed granted.
Budget position at 31 August, reported 18 September: deficit Rp240.1 trillion (0.93% of GDP) with a primary surplus of Rp154 trillion; tax revenue Rp1,409 trillion (59.8% of the Rp2,357.7 trillion target, up 24.1% year on year); net debt financing Rp506 trillion (60.8% of the full-year plan). The latest full-year outlook, published in July under Purbaya, is a deficit of Rp734.3 trillion or 2.85% of GDP, against Rp689.1 trillion (2.68%) budgeted and the 3% legal ceiling.

What this means for your Indonesian entity

The minister's words are reassurance, not a new rule — nothing in the refund process changed on 18 September. What matters for cash-flow planning is the combination of a deficit running wider than budgeted and a refund regime that is explicitly "selective": that is the setting in which refund claims get audited rather than researched, and in which SP2DK letters and audit notices become more frequent. Four checks. (1) If you file VAT overpayments, test each period against PMK 28/2026: above Rp1 billion overpaid or Rp4.2 billion in deliveries, you are outside the Article 17D fast track, and unless you qualify as a low-risk PKP or a compliant taxpayer, the claim goes through a full refund audit — which the KUP Law allows up to 12 months to decide. (2) If you held compliant-taxpayer status before May, confirm that you re-applied and were re-designated; the old status did not carry over. (3) Answer every SP2DK promptly and completely — an unanswered request about fiscal profit or loss now bars compliant-taxpayer status, not just raises audit risk. (4) In your forecast, do not treat a refund as cash in the month you file; model it on the audit timeline, and flag the age of the receivable to whoever signs off the close. We are not forecasting when the refund backlog clears.

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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