Association Membership No Longer a Licence Requirement for Consultants

JAKARTA, DDTCNews – Through MoF Reg. 55/2026, the Ministry of Finance (MoF) has amended the provisions concerning the obligation of tax consultants to become members of a tax consultant association. One of the changes relates to the deadline for fulfilling the membership obligation.

Under MoF Reg. 55/2026, the obligation to become an association member must now be fulfilled within a maximum of 30 business days after the tax consultant licence is obtained. Accordingly, fulfilment of this obligation is no longer a requirement that must be completed prior to applying for a tax consultant licence.

"The obligation to be a member of the tax consultant association…must be fulfilled no later than 30 business days after obtaining the tax consultant licence," reads Article 25 paragraph (1) of MoF Reg. 55/2026, as cited on Thursday (3/9/2026).

Under that article, a tax consultant who has just obtained a licence is still given time to fulfil the membership obligation. The deadline is 30 business days from the date on which the tax consultant licence is obtained.

This provision differs from the previous regulation. Under MoF Reg. 111/2014, as amended by MoF Reg. 175/2022, membership of a tax consultant association was one of the requirements for a person seeking to become a tax consultant.

In other words, under the previous rules, association membership had to be fulfilled before a person could obtain a practise licence. This was also reflected in the practice licence application requirements, which obliged the applicant to attach a photocopy of the tax consultant association membership decision letter.

MoF Reg. 55/2026, however, shifts this mechanism. Association membership is no longer positioned as one of the requirements for obtaining a tax consultant licence, but instead becomes an obligation that must be fulfilled after the licence is obtained.

MoF Reg. 55/2026 also stipulates an administrative penalty should this obligation not be fulfilled. A tax consultant who fails to become a member of a tax consultant association within the prescribed period shall be subject to an administrative penalty in the form of a 3-month suspension of the tax consultant licence.

Should the tax consultant still fails to become a member of a tax consultant association after the suspension period expires, the tax consultant licence will be revoked. Practice licences issued pursuant to MoF Reg. 111/2014, as amended by MoF Reg. 175/2022, shall continue to remain valid as tax consultant licences under the new provisions.

"Practice licences that have been issued pursuant to MoF Reg. 111/2014, as amended by MoF Reg.175/2022, before this ministerial regulation comes into force, shall be declared to remain valid as tax consultant licences as stipulated under this ministerial regulation," reads Article 60 letter a of MoF Reg. 55/2026. (rig)