Supreme Court Mandates Electronic Documents for Tax Judicial Review Filings

JAKARTA. The Supreme Court (MA) has officially mandated that petitioners for a Judicial Review (Peninjauan Kembali or PK) in tax cases must attach electronic documents with every submission. This policy became effective on December 15, 2025, following the issuance of the Decree of the Clerk of the Supreme Court Number 1467A/PAN/HK2.7/SK/XII/2025.

This new regulation serves as the administrative implementation guidelines for PK legal actions against Tax Court decisions filed through the electronic justice system. Based on the Tax Court Secretariat Announcement Number PENG-1/PAN/2025, petitioners and respondents are now required to include digital documents on external storage media, such as CDs or flash drives, alongside physical files.

Tax Judicial Review Document Requirements

While the basic document requirements still refer to the Decree of the Chairperson of the Tax Court Number KEP-01/PP/2020, there are technical adjustments where the PK Petitioner must attach three types of electronic documents:

The PK Petitioner (Applicant) is required to attach:

1. A color-scanned copy of the Statement of Judicial Review (Memori PK) in PDF format.
2. The signed Judicial Review Deed (Akta PK) in PDF format.
3. A soft copy of the Statement of Judicial Review in .docx format, replacing the previous .rtf format.

The PK Respondent is required to attach:

1. A color-scanned copy of the Counter-Statement of Judicial Review (Kontra Memori PK) in PDF format.
2. A soft copy of the Counter-Statement of Judicial Review in .docx format, replacing the previous .rtf format.

These format adjustments are deemed to be more aligned with the needs of the electronic justice system and will facilitate the document upload and verification process through the e-Tax Court platform. (KEN)