PMK 28/2026: Faster Tax Refunds for Compliant Taxpayers

Effective 1 May 2026, the government enacted Minister of Finance Regulation (PMK) No. 28 of 2026 on the procedures for the preliminary refund of tax overpayments. It replaces PMK 39/2018 and changes how taxpayers claim a fast-tracked refund (restitution) of overpaid tax. The good news: the process can be much faster. The catch: your compliance is genuinely put to the test.

What Is a Preliminary Refund?

When the tax you paid or that was withheld is greater than what you actually owe, the state must return the difference. Normally, that refund goes through an audit that can take months.

A preliminary refund is the fast lane: the tax authority (DJP) returns your overpayment up front through verification (data validation) rather than a full audit. Your business cash flow is not tied up for long.

Processed by Verification, Not Audit

This is where the speed comes from. Through the integrated Coretax DJP system, DJP electronically validates the accuracy of tax calculations, withholding slips, payments, tax invoices, and import documents. Because it runs on already-connected data, a decision can arrive far sooner than a field audit.

Three Eligible Groups

PMK 28/2026 sets out three preliminary-refund tracks:

1. Taxpayers with Specific Criteria (Article 17C, KUP Law)

For taxpayers with a strong compliance record. The requirements are strict:

• Annual returns filed on time for the last 3 years;
• Monthly (Masa) returns for January–November of the last year filed;
• No tax arrears;
• Never late paying tax in the last 5 years;
• Financial statements audited with an unqualified opinion for 3 consecutive years;
• No criminal conviction in taxation in the last 5 years.

Taxpayers in this group must apply for designation to DJP no later than 10 January.

2. Taxpayers Meeting Specific Conditions (Article 17D, KUP Law)

A track for limited business scale and overpayment value. No special designation is needed — you simply tick the facility on the return. The limits include:

• Individual taxpayers: overpayment of up to Rp100 million;
• Corporate taxpayers: turnover up to Rp50 billion and overpayment up to Rp1 billion.

3. Low-Risk Taxable Entrepreneurs (PKP) (Article 9(4c), VAT Law)

Covers, among others, listed companies, state- and region-owned enterprises (BUMN/BUMD), main customs partners, Authorized Economic Operators (AEO), pharmaceutical producers, and certain medical-device distributors.

The Refund Facility Is Now More Selective

Compared with the old rules, PMK 28/2026 tightens and clarifies who qualifies. The fast facility is aimed at taxpayers who are genuinely compliant with clean data. For those whose administration is not yet in order, refunds can still be processed — but through the slower normal (audit) route.

Note: Existing-Status Taxpayers Must Re-Apply

Taxpayers who already hold specific-criteria status under the old rules must re-apply to keep the facility. The transition provisions give a window to re-apply; if you miss it, your refund request will be processed the normal way. Don’t let your fast-track facility lapse over a missed administrative step.

What Does This Mean for Your Business?

• Do you routinely overpay (e.g. an exporter with large input VAT)? This facility can protect your cash flow significantly.
• Want to reach specific-criteria status? Start tidying your compliance now — on-time filing, no arrears, and an unqualified audit opinion all require a multi-year track record.
• Small overpayment value? Check whether you qualify for the simpler Article 17D track.

Misjudging eligibility or misfiling a return can get your request rejected — or worse, trigger an audit.

Need Help With Your Refund?

The Mandiri Pajak team can assess your refund eligibility, prepare your documents and returns correctly, and guide the refund process so it is fast and safe. Explore our services or book a free consultation with our certified consultants — Correct Taxes, Peace of Mind.