Regulation of the Minister of Finance No. 55 of 2026 expands the regulatory framework for Tax Consultants and introduces a new framework for Other Parties Acting as Taxpayer Representatives, including competency, registration, supervision, and sanction requirements. It also regulates the forms and establishment requirements of Tax Consultant Offices.
If ultimately enforced, this Draft Bill establishes a centralized advocate regulatory framework through the National Advocate Council. The Draft Bill introduces stricter appointment and professional development requirements, including maximum appointment age, character and propriety testing, centralized registration and compulsory legal aid during internships. Law firms would face client data security and 10% pro bono requirements, while foreign advocate affiliations would face tighter restrictions and specified violations may incur administrative or criminal sanctions.
This Regulation establishes various eligibility and competency requirements that will now apply to clinical educators, including valid STR and SIP and at least two years of active professional practice. The new Regulation also provides a number of entitlements and an academic career pathway up to the professor level for clinical educators, while requiring healthcare service facilities to maintain data-based records that are integrated into SIKN and the Ministry of Higher Education, Science and Technology?s information system.
The Minister of Finance (?Minister?) has overhauled the qualifications and requirements that apply to Indonesia?s tax attorneys by expanding the categories of eligible representatives to include family members and other registered individuals. The new framework has also introduced an electronic process for the submission of Special Powers of Attorney through the Taxpayer Portal in line with automated credential verifications. The Minister has also provided a transitional grace period that will extend until 31 December 2026 and which will allow holders of tax brevet certificates or formal taxation qualifications to continue to act as tax attorneys in line with the previous paper-based procedure.
The MK has issued a decision that will require the legislature to amend the Advocates Law within a two-year period in order to address the fragmentation of professional organizations in this area. This revision is expected to introduce a clear separation between the representative functions of professional associations and the independent regulatory functions of professions. Furthermore, these changes are set to significantly reshape the procedures that apply to legal education, professional examinations, admissions and ethical supervision for all legal practitioners operating at the national level.
The Draft Regulation consolidates and replaces five separate regulations governing capital market professionals (i.e. WPPE, WPEE, WMI, and WAPERD), while significantly expanding the licensing framework through more granular license segmentation and tiered competency levels. It also introduces stricter compliance obligations, including mandatory use of an integrated electronic licensing system, real-time continuing education reporting, and clearer restrictions on dual roles and conflicts of interest, with non-compliance subject to administrative sanctions up to permanent license revocation.
Essentially, this new framework mandates enhanced due diligence in terms of the implementation of the Know-Your-Service-User Principle (Prinsip Mengenali Pengguna Jasa/PMJP) by notaries. This includes expanded identification obligations that cover service users (?Users?), authorized representatives and Beneficial Owners (?BO?), as well as the ongoing screening of Users and BO against certain designated lists, including lists that address terrorism and proliferation of weapons of mass destruction financing. In order to strengthen enforcement in this regard, the new framework clarifies the various forms of administrative sanctions that can be imposed in response to any non-compliance. Said sanctions range from written reprimands to dishonorable dismissals. Furthermore, the new framework has also introduced an account-blocking mechanism for accounts that are held at the official website of the Directorate-General of General Legal Administration (Administrasi Hukum Umum/AHU), which can be applied in certain circumstances.
While maintaining the three core services that can be provided by paralegals in line with their duties (e.g. advocating regional policies, participating in government programs and activities and/or cooperating with other parties in order to encourage or guide members of the general public to gain a deeper understanding of the law), this new Regulation now allows qualified paralegals to provide nine other types of non-litigation services. These nine services include: 1) Legal research and consultations; 2) Case investigations; 3) Mediation; 4) Negotiations; and/or 5) Drafting of legal documents.
Intellectual property appraisers (Appraisers) should register through the application of cost, market, income or other valuation approaches. Appraisers must secure licenses from the Ministry of Finance, must demonstrate competence within the field of intellectual property valuations and must register with the Ministry of Creative Economy. Panels should be formed by banks or financial institutions for valuations that are not handled by Appraisers. Public Appraisers may apply by submitting their license, association membership, training certification and other required documents.
The Draft Circular regulates the administration of supporting professions within the financial services sector and covers areas such as registration, changes to the scope of services, work leave and resignations. This new framework applies to professionals such as public accountants, actuaries, legal consultants, appraisers and notaries. These professionals must complete mandatory education programs and participate in continuous professional development, as well as submit annual activity reports to the OJK.