The Directorate General of Tax (DGT) continues to innovate in its efforts to modernize the taxation system in Indonesia. One of the latest significant steps is the issuance of PER-11/PJ/2025. This regulation marks a crucial point in the continuation of the digital transformation of the Coretax-based taxation system, with the primary objective of aligning the e-Tax Invoice application with the integrated DGT Coretax system. PER-11/PJ/2025 introduces crucial updates regarding upload deadlines, format, numbering, and relaxation schemes for Taxable Entrepreneurs (PKP).
This regulation stipulates that every electronic tax (VAT) invoice must be completed and uploaded automatically through the official module provided, a strategic step to enhance the efficiency, accuracy, and security of tax administration in Indonesia.
Key Differences from Previous Regulations
PER-11/PJ/2025 introduces several fundamental differences compared to previous regulations, namely PER-03/PJ/2022 and PER-11/PJ/2022. Some of these key differences include:
| Feature | PER-03/PJ/2022, PER-11/PJ/2022 and previous tax regulations | PER-11/PJ/2025 |
| Application Used | e-Tax Invoice Application | e-Tax Invoice Module within the DGT Coretax System |
| Requirements for PKP to Issue e-Tax Invoice | Possessed an electronic certificate, an activated PKP account | Possesses an electronic certificate/authorization code and access for Tax Invoice issuance |
| Business Location Address | Mandatory only for buyers in certain facilitated areas/locations | Mandatory/Optional entry of the business location address used by PKP |
| Transaction Code | Transaction Code 06 for Other Deliveries | Code 06 is used when PKP delivers Taxable Goods to foreign tourists through retail stores participating in the VAT Refund for Tourist scheme. Addition of transaction code 10 for other deliveries where VAT or VAT and Sales Tax on Luxury Goods (PPnBM) are collected by the issuing PKP |
| Status Code | Status code for Replacement Tax Invoice is 1 digit | Status code for Replacement Tax Invoices is 2 Digits |
| Tax Invoice Serial Number (TISN) | Issued by the DGT upon PKP’s request | Automatically issued by system when the e-Tax Invoice is uploaded to Coretax |
| Tax Invoice Upload Deadline | Latest by the 15th | Latest by the 20th |
| Tax Invoice Reporting for Retailer | The Tax Invoice is filled in manually on the VAT Return in the e-Invoice application. | Tax invoices are imported using the xml format in the Coretax e-Invoice System |
| Export Notification for Intangible Taxable Goods/Taxable Services (BKPTB/JKP) | Manually created by PKP outside the DGT system | Issues Export Notification for Intangible Taxable Goods and Taxable Services using the e-Tax Invoice module within the DGT Coretax System |
| Errors in Buyer Identity Entry | Not regulated | Replacement Tax Invoices cannot be issued; instead, the Tax Invoice must be canceled and followed by the issuance of a new Tax Invoice with the correct buyer identity |
| Replacement Tax Invoice Post-Return Note/Cancellation | Not regulated | Replacement Tax Invoices are issued taking into account return notes/cancellations (net value), and return of Taxable Goods/cancellation of Taxable Services are deemed not to have occurred |
Risks Faced by Taxpayers
These changes also bring several risks that PKPs need to be aware of:
- Administrative Sanctions due to Late Upload: If the e-Tax Invoice is not uploaded before the 20th of the following month, the invoice is considered invalid, cannot be credited or reported, and may result in administrative sanctions of 1% of the Tax Base (DPP).
- Incomplete Tax Invoice or Incorrect Transaction Code: Errors in format, data completeness, or the use of transaction codes (e.g., code 04 versus code 01 with an effective VAT rate of 11% via Tax Base calculation) can lead to the invoice being rejected and a penalty of 1% of the Tax Base (DPP) being imposed.
- Technical Risks & System Disturbances: Since the Coretax System is newly operational, Taxpayers must be vigilant due to the risk of technical issues and system errors. The risk of late payments and reporting due to system disruptions has the potential to result in administrative sanctions.
What Taxpayers Must Do
To ensure compliance and minimize risks, PKPs are advised to take the following steps:
- Update SOPs & Internal Systems: Ensure that accounting/tax teams understand the adjustment of the upload deadline to the 20th and the automatic TISN input process. Conduct internal training and update Standard Operating Procedures (SOPs).
- Check Tax Invoice Data: Conduct internal testing to ensure that transaction codes, data format, and electronic signatures are correct. Verify the use of code 04 for the effective VAT rate of 11% if necessary.
- Handle System Error: If a system failure occurs, document it in detail (screenshots, date, timestamp) as evidence to be reported to the DGT as a reason for delay.
- Consult a Tax Consultant / DGT: If any uncertainties arise, especially regarding format, codes, or effective rates, it is advisable to immediately consult with a tax consultant or the DGT to obtain clarification from official sources or trusted professionals.
Overall, PER-11/PJ/2025 is an important matter for the e-Tax Invoice system within the DGT Coretax framework. The main changes, including shifting the upload deadline to the 20th, Tax Invoice Serial Number (TISN) automation, clarification of transaction codes, transition period relaxation, and handling of force majeure circumstances, aim to strengthen the digitalization of tax administration. However, the successful implementation of this regulation highly depends on the readiness of PKPs, both in terms of technical aspects, processes, and human resources. Therefore, Taxable Entrepreneurs (PKP) must continue to monitor updates from the DGT and conduct regular internal verification to ensure that the use of e-Tax Invoices does not pose a risk of sanctions.
For further information and taxation queries, please reach to :
Email : info@mul-co.com
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