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PMK 55/2026 Changes the Rules of the Game for Tax Consultants: What You Need to Know to Stay Compliant

October 1, 2026

The Minister of Finance issued Regulation No. 55 of 2026 (“PMK 55/2026”) on Tax Consultants and Other Parties Acting as Taxpayer Proxies on July 22, 2026, and promulgated it on August 24, 2026. The regulation repeals the PMK No111/PMK.03/2014 on Tax Consultants as amended by PMK 175/PMK.01/2022, and is effective from the date of promulgation, with a number of transitional provisions that limit the adjustment time for license holders and old competency documents. The changes introduced have important implications for tax consultants, tax consulting offices, and other parties who act as taxpayer proxies.

We summarize below the main changes and how they compare with previous regulations.

• The requirements to be licensed as a tax consultant who can be a taxpayer proxy have been tightened, with new and changed qualifications. PMK 55/2026 requires that all applicants have, at a minimum, a bachelor’s degree (Article 5, paragraph 2(d)), as well as tax work experience of at least one year in the last three years for a level B license and two years for a level C license (Article 5, paragraph 3(e)). PMK 175/2022 did not specify formal education requirements, while PMK 111/2014 allowed for a level A certification exam path for D-III graduates of accounting or taxation (Article 12(a)). The work experience requirement has also changed: Under PMK 111/2014, 12 months of practical experience is only required to increase the license level (Article 5, paragraph 3), while PMK 55/2026 sets this experience requirement for first time applicants.
• The waiting period for former employees of the Ministry of Finance before they can act as tax consultants has been extended from two years to five years. In addition, this waiting period is extended to all former employees of the Ministry of Finance, including government employees with employment agreements, who were previously unregulated (Article 5, paragraph 2(l)).
• Tax consulting offices are now regulated as a business entity. For the first time, PMK 55/2026 explicitly regulates tax consulting offices as a business entity, of which there are four forms: individuals, civil partnerships, firms, and limited liability companies (Article 16, paragraph 1). PMK 111/2014 and PMK 175/2022 only regulated individual tax consultant practice licenses.
• The tax consultant certificate is replaced by the certificate of competency, with a limited validity period. Article 60(f) states that the tax consultant certificate from the previous regulations remains valid as a certificate of competency, but is limited to a maximum of two years from the certificate’s issuance date (not from the enactment of PMK 55/2026).
• Responsibility for the professional exam moves under the Tax Consultant Association. Under PMK 55/2026, the tax consultant professional exam is now organized by the Tax Consultant Association (Article 32), replacing the Tax Consultant Certification Organizing Committee mechanism that applied under PMK 111/2014.
• A new oversight committee is formed. PMK 55/2026 establishes the Committee for Strengthening the Professionalism of Tax Consultants (Articles 56 to 59). Its mandate is broader than that of the Tax Consultant Certification Organizing Committee in PMK 111/2014, which only handled certification. This new committee is authorized to prepare practice standards, a code of ethics, competency standards, as well as a competency test and continuing professional education (“PPL”) policies for tax consultants. The steering team has seven members, four from the Ministry of Finance, two from the Tax Consultant Association, and one from academia (Article 57, paragraphs 3 and 4).
• The targets for annual PPL credit points (“SKP”) is now tiered and lower for certain levels compared to the old rules. Article 26 sets out PPL obligations, with annual SKP targets tied to the licensing levels—for level A license holders, the minimum is 20 SKPs, with 16 of them structured (this is unchanged from PMK 111/2014 (Article 24, paragraph 3); for level B, it is at least 30 SKPs, with 24 structured; and for level C, it is at least 45 SKPs, with 36 structured. The level B and level C targets under PMK 55/2026 have been significantly lowered, from 40 SKPs to 30 SKPs for level B, and from 60 SKPs to 45 SKPs for level C.
• Membership in the Tax Consultant Association is now a post-licensing obligation, not a condition before issuance of the license. Article 25 emphasizes that all tax consultants are required to become members of the Tax Consultant Association no later than 30 working days after the tax consultant license has been issued. This provision changes the position of association membership in the licensing flow. In PMK 111/2014, association membership was a condition before the license was issued (Article 2, paragraph 1(f)). PMK 55/2026 changes this to an obligation after issuance of the license, complete with separate deadlines and sanctions. Failure to fulfill this obligation is subject to administrative sanctions in the form of a license freeze for three months, and continues to the revocation of the license if the membership obligation remains unfulfilled after the freeze period ends.
• The required annual report has become more detailed, now including data on service fees per client. Articles 28 and 29 require tax consultants and tax Consulting offices to submit annual reports no later than April 30 of the following year, which must include profiles, proof of submission of tax returns, as well as details of services provided, such as client information, type of service, assignment period, and service fees received. The details of these service fees are a new element, because PMK 111/2014 (Article 25, paragraph 2) only required reporting on client information and the number of taxpayers served, without details of the cost per assignment.

Recommendations

These changes have a direct impact on individual tax consultants, tax consulting offices, and other parties acting as taxpayer proxies who are already operating under the old regulations. Tax consulting offices need to re-examine the composition of their partners, directors, or commissioners, the validity period of their staff’s tax consultant certificates, as well as the readiness of their annual reporting system, which now demands more complete client information details and service fees. Individual tax consultants need to ensure that they join the Tax Consultant Association in a timely manner after issuance of their license, as well as ensure they meet the new PPL SKP targets.

By Tommy Hendharto Oetomo – Managing Partner