Not a Registered Taxpayer but Can Still Receive an SP2DK, DGT Explains Why

JAKARTA. The government has issued a new regulation concerning the issuance of a Request for Explanation of Data and/or Information Letter (SP2DK).

One of the substantive changes is that an SP2DK may be issued to both taxpayers and non-taxpayers. This provision is stipulated in the Minister of Finance Regulation (PMK) Number 111 of 2025.

According to Director General of Taxes Bimo Wijayanto, the expansion of the SP2DK scope is part of the government’s effort to carry out tax revenue extensification.

Leveraging the Depth of DGT Data

Bimo explained that the Directorate General of Taxes (DGT) currently has a broad and in-depth database and sources of information. The data and information are not only related to registered taxpayers but also to parties who have not yet been registered as taxpayers.

“The data not only refers to taxpayers who are already registered, but also those who have not yet entered the DGT system. This is part of the extensification effort,” said Bimo on Thursday (8/1), during the presentation of the 2025 State Budget realization.

Therefore, if DGT data reaches subjects or entities that meet the subjective and objective requirements as taxpayers, the DGT may issue an SP2DK.

SP2DK to Monitor Tax Compliance

Based on Minister of Finance Regulation (PMK) Number 111 of 2025, the SP2DK is one of the instruments for monitoring tax compliance. Such monitoring may be carried out on registered taxpayers, non-taxpayers, as well as through region-based supervision.

1. Supervision of registered taxpayers includes:
2. Reporting business locations to obtain a Business Location Identification Number (NITKU)
3. Reporting business activities to be registered as a VAT-registered person (PKP)
4. Registration of Land and Building Tax (L&B Tax) objects in the plantation, forestry, mining, oil and gas, geothermal, mineral and coal sectors, and other sectors
5. Submission of Land and Building object tax returns (SPT)
6. Filing tax returns (SPT)
7. Tax payment or remittance
8. Tax withholding or collection
9. Bookkeeping or record-keeping
10. Other tax obligations

Meanwhile, supervision of non-taxpayers includes:

1. Registration to obtain a Taxpayer Identification Number (NPWP) or activation of the National Identity Number (NIK) as an NPWP
2. Reporting business locations to obtain an NITKU
3. Reporting business activities to be registered as a PKP
4. Registration of PBB objects in certain sectors
5. Tax payment or remittance
6. Tax withholding or collection
7. Filing tax returns (SPT)
8. Other tax obligations

Providing Legal Certainty

Bimo also stated that previously, the SP2DK provisions were only regulated under the Director General of Taxes Circular Letter Number SE-05/PJ/2022. By regulating SP2DK under Minister of Finance Regulation (PMK) Number 111 of 2025, stronger legal certainty is expected to be achieved.

In addition, elevating the regulatory level of SP2DK into a PMK is expected to create more uniform implementation within the DGT.

Thus, confirmation of data and information belonging to individuals or entities that have not yet been registered as taxpayers can be carried out formally through an SP2DK. (ASP/KEN)