Regulation Watch · Tax Compliance · Indonesia, including Indonesian branches and entities with the prescribed CRS or CARF nexus, whether domestically or foreign owned.
CRS Corrections Now Use the Amended Reporting Framework
From 1 October 2026, CRS reports for 2025 and earlier data years and any corrections filed from that date must follow PMK 108/2025 and the Amended CRS format, while 2026 data brings Indonesia's first CARF reporting cycle for qualifying crypto-asset service providers.
- Published
- Established on 29 December and promulgated on 31 December 2025 in State Bulletin 2025 No. 1255.
- Effective
- The regulation took effect on 1 January 2026. Its transition requires reports for 2025 and earlier data years, and corrections filed from 1 October 2026, to use PMK 108/2025; reporting for the 2026 data year begins in 2027.
- Added to Watch
- 1 October 2026
Who is affected
CRS-reporting financial institutions, including relevant deposit-taking, custodial, investment and specified insurance entities; other entities that meet the CRS tests; qualifying PT PMA and PT PMDN financial businesses; Indonesian branches; digital-financial-asset traders and other qualifying CARF-reporting crypto-asset service providers; directors and appointed reporting officers; and tax, compliance, technology, customer-onboarding and data-governance teams.
Practical impact
A CRS report for the 2025 or an earlier data year, or a correction submitted on or after 1 October 2026, can no longer use the former PMK 70/2017 reporting framework and XML Schema 2.0. DJP's official guidance requires the PMK 108/2025 framework and XML Schema 3.0 Amended CRS. The regulation also adds CARF registration, customer-identification, transaction-data and reporting duties for qualifying crypto-asset service providers, with the first CARF report covering the 2026 data year. Reporting entities remain responsible when a vendor or other third party prepares the file.
PMK 108/2025 was established on 29 December, promulgated on 31 December 2025 as State Bulletin No. 1255 and took effect on 1 January 2026. It replaced PMK 70/2017 and its amendments with Indonesia's technical framework for the Amended Common Reporting Standard and Crypto-Asset Reporting Framework. The rule was published earlier, but its filing transition becomes operational on 1 October 2026 and is therefore immediately relevant to reports and corrections prepared now.
The transition is based on submission date and data year. Reports and corrections submitted through 30 September 2026 could continue under the former framework. From 1 October 2026, a CRS report for the 2025 or an earlier data year, and any correction submitted from that date, must follow PMK 108/2025. DJP's official FAQ translates that change into a technical requirement: XML Schema 3.0 Amended CRS replaces XML Schema 2.0 for those filings.
The affected population is limited to entities that meet the reporting tests, not every PT PMA or ordinary operating company. It includes relevant deposit-taking, custodial, investment and specified insurance entities, together with other entities that satisfy the detailed CRS definitions. The entity should document its classification and reporting route because LJK reports generally pass through OJK, while other reporting entities file directly with DJP.
PMK 108/2025 also introduces CARF for qualifying crypto-asset service providers with the prescribed Indonesian nexus. Covered activities can include exchange between crypto assets and fiat currency, exchange between crypto assets, transfers and reportable retail-payment transactions. A qualifying provider must register its status, apply customer-identification and valid self-certification controls, finish identifying old users by 31 December 2026, capture the 2026 data set and prepare for the first CARF report in 2027.
Both CRS and CARF require a valid self-certification and evidence-based reasonableness review. A reporting entity may not open a new account or permit a new transaction when the required self-certification is refused, subject to the limited exceptions in the rule. Customer declarations, supporting documents and reporting records must be retained for at least five years after the end of the relevant reporting period.
Using a software vendor, agent or other third party does not transfer the legal responsibility away from the reporting institution or crypto-asset service provider. Management should therefore test file-version controls, reporter classification, responsible-officer data, portal access, field mapping, review evidence and submission receipts before a report or correction is filed under the new framework.
DJP may investigate reporting, identification, registration, recordkeeping and information-request failures through research, clarification and formal fulfilment requests. Unresolved non-compliance can progress to preliminary-evidence examination and investigation under the tax laws. The practical control from 1 October is to reject any legacy XML 2.0 workflow for an affected filing and require documented Amended CRS or CARF readiness instead.
Required action
- Stop using the PMK 70/2017 and XML Schema 2.0 workflow for any CRS report for 2025 or an earlier data year, or any CRS correction, submitted from 1 October 2026.
- Validate that the reporting platform, file generator and submission controls support PMK 108/2025 and XML Schema 3.0 Amended CRS before preparing or resubmitting a file.
- Reperform the reporter classification under the current definitions, including deposit-taking, custodial, investment and specified insurance entities, and document why the entity is reportable or nonreporting.
- Review new-account self-certification so it is complete, signed or affirmatively confirmed, dated and separately identifiable in the account-opening process; do not open or transact on a new account where a required valid self-certification is refused.
- Qualifying crypto-asset service providers should confirm their Indonesian nexus, register their PJAK Pelapor CARF status through the taxpayer portal, identify old users by 31 December 2026, and capture the 2026 transaction data needed for the first CARF report in 2027.
- Retain self-certifications, supporting documents, identification records, reporting workpapers and submission receipts for at least five years after the relevant reporting period, and record the responsible officer and any outsourced provider used.
- Before submitting a correction, reconcile entity, account-holder, tax-residency, TIN, balance, payment and reportable-transaction data to the Amended CRS or CARF field requirements and preserve evidence of reviewer approval.