SP2DK in English: What It Means and How to Reply in 14 Days
An SP2DK asks you to explain your own tax reporting; it is not an audit. Under PMK 111/2025 you have 14 days to answer, and up to 7 more on written notice.
References (4)
- PMK No. 111 Tahun 2025 tentang Pengawasan Kepatuhan Wajib Pajak — set 30 December 2025, in force 1 January 2026. Article 6 sets the response window, the events it runs from and the extension; Article 7 the discussion; Article 8 the possible outcomes
- PMK No. 111 Tahun 2025, Article 6(2) — 14 days, running from whichever of five delivery events happens first
- PMK No. 111 Tahun 2025, Article 6(5) and 6(6) — an extension of up to 7 days, by written notice that must be received before the original window ends
- PMK No. 111 Tahun 2025, Article 8(1) — the seventeen outcomes an SP2DK may be proposed for, including a formal audit and a preliminary criminal investigation
An SP2DK — Surat Permintaan Penjelasan atas Data dan/atau Keterangan, a request for an explanation of data or information — is a letter from Indonesia’s Directorate General of Taxes asking you to account for something in your own tax reporting.
It is not an audit. It is a request to explain, with a deadline attached, and the deadline is the part that matters.
What changed on 1 January 2026
If you have read about this letter before, some of what you read is now out of date, including the version of this article we published in 2025.
Since 1 January 2026 SP2DK has been governed by PMK 111/2025, a Minister of Finance regulation set on 30 December 2025.
The rules below come from that regulation: the events that start your clock (Article 6(2)), the extension and how to claim it (Article 6(5) and 6(6)), what the tax office does with your answer (Article 6(9) to 6(11)), and the outcomes the process can be proposed for (Article 8(1)).
One wording note, because it decides how you count. The regulation says 14 hari — 14 days — and does not qualify them as calendar days. We have not seen the counting convention settled, so we aim to answer inside the window or ask for more time. In our experience more time is usually possible, as long as we keep in touch with the tax office.
How long you have to answer an SP2DK
Fourteen days, and the clock can start before you have read the letter. Under Article 6(2) it runs from whichever of these happens first:
- The date the letter is issued, where it is delivered through your Taxpayer Account in CoreTax, the tax office’s online system.
- The date it is sent to the email address registered in the tax office’s own system.
- The date of proof of sending, where it goes by fax.
- The date of proof of sending, where it goes by post, expedition or courier.
- The date it is handed over in person, whether to you, your representative, your proxy, an employee, or an adult member of your family.
A letter can start the clock before you have seen it
Under Article 6(2), a letter handed over in person to an adult member of your family starts your fourteen days from that day, and a letter delivered through your CoreTax Taxpayer Account starts them from the date it is issued there. Somebody needs to be watching that account.
Asking for more time
Seven more days, and one detail that decides it
Article 6(5) lets you extend the window by up to seven days. Two things about it are worth knowing. It is a notification (pemberitahuan), not an application. And under Article 6(6) the notice must be received by the office that issued the letter before your original window closes, so a notice that arrives after that is too late. File it through your Taxpayer Account, or take it to the office.
Why the tax office issues one
In our experience these letters follow a specific discrepancy. Five patterns account for most of what we see.
Income that does not match what third parties reported
Income on your annual return that sits below what third-party data shows, such as the tax your customers withheld from paying you, is a common starting point.
Assets that do not appear in the return
An acquisition that never appears in a return is a straightforward question waiting to be asked.
This pattern can also bring one of these letters to an individual: a director whose spending or asset purchases sit awkwardly beside the income on their own return can be asked to explain the difference, and the answer belongs in their personal tax position rather than the company’s.
Documentation that does not support the figures
VAT invoiced against VAT reported, expenses claimed against receipts held, deductions taken against the evidence for them.
A compliance history that invites a closer look
Late annual returns, underpaid tax and repeated corrections to filed returns are the kind of history that invites a closer look.
Withholding reported against a loss
A corporate return showing a loss, set against withholding tax that customers reported on substantial payments to you, is a mismatch worth explaining before anyone asks. With the bookkeeping kept right through the year, a return that reconciles to your own ledgers before it is filed gives you the answer ready.
From letter to outcome
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Read what is actually being asked
The letter names the data it is querying and the periods it covers. The scope is narrower than it looks, and answering a wider question than the one asked invites the next one.
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Answer, with the documents attached
Where you disagree with the data in the letter, Article 6(4) requires your explanation to come with supporting evidence. You may answer more than once inside the window.
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The tax office examines the response
Article 6(9). The tax office examines (penelitian) the response.
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It fits, and a record is drawn up
Article 6(10). Where the response fits what was asked, the tax office draws up a berita acara, an official record. This is the ordinary ending, in the cases we see.
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Or it does not, and you are invited in
Article 6(11) and Article 7. Where the answer does not fit, where new data has appeared, or where nothing was sent in time, the tax office may call you to a discussion, in person or by video, and may also visit.
How to answer well
Tie every document to the transaction it explains, in the order the letter raises them. A bundle of statements with a covering note asks the examiner to do the reconciliation themselves, and an examiner doing your reconciliation is an examiner forming their own view of it.
Answer only what was asked. Keep the explanation factual, name the regulation where one supports your position, and where the discrepancy came from a genuine error, correct the return rather than arguing the point. If the underlying question is about how your corporate tax position was arrived at, the answer is usually in your own records rather than in an argument about the law.
Where an SP2DK can end up
Article 8(1) lists seventeen things the process can be proposed for. In our experience most letters end at the first: the request is closed, and that is the end of it. The rest of the list is why the deadline deserves respect. It includes correcting your registered data on the tax office’s own initiative, deregistering your tax number, revoking your VAT-registered status, restricting or blocking certain public services, a valuation for tax purposes, surveillance and intelligence activity, a formal audit, and a preliminary criminal investigation.
Those last two are what people have in mind when they worry about one of these letters. It is worth being precise about them: an audit is one possible outcome of this process, not the process itself. Answering properly, inside the window, is the part you control.
You can read PMK 111/2025 in full on the Ministry of Finance’s legal documentation portal, JDIH Kemenkeu.