Briefing Document: Indonesia’s E-Invoicing and E-Reporting

Last Update: December 6, 2025

SUMMARY

INDEPTH ANALYSIS

• July 2014: Introduction – The e-Faktur system was first introduced on a pilot basis as part of Indonesia’s tax modernization to combat fraud and improve VAT collection. [sovos.com]
• July 2015: Initial Mandate – Electronic invoicing became mandatory for VAT-registered businesses in Java and Bali (the first regions to adopt the system). [sovos.com]
• July 2016: Nationwide Mandate – e-Faktur became mandatory for all VAT-registered taxpayers (PKP) across Indonesia. From this date, all corporate taxpayers must issue their VAT invoices electronically via the government’s system. Paper or non-approved invoices ceased to have legal validity. [sovos.com]
• 2016–2020: Expansion and Updates – The mandate was extended to all businesses above the VAT registration threshold (annual sales > IDR 4.7–4.8 billion). Smaller enterprises that crossed the threshold were onboarded, and the system was refined. [edicomgroup.com]
• 1 October 2020: e-Faktur 3.0 – A new version of the e-Faktur system (version 3.0) launched with improvements. This update enabled online access (web-based system), real-time validation, and auto-population of VAT returns based on e-invoice data. It also enhanced security and integration with other systems. [sovos.com] [edicomgroup.com], [vatcompliance.co]
• April 2022: Regulatory Update – The DGT issued Regulation PER-03/PJ/2022 (effective 1 April 2022) to consolidate and simplify VAT invoice rules. This aligned invoice requirements with a 2021 tax law update and introduced clearer rules on invoice content, codes, and deadlines (detailed below). (PER-03/PJ/2022 was later amended by PER-11/PJ/2022.) [taxathand.com]
• 31 July 2024: Core Tax System Announcement – The government announced the development of a new Core Tax Administration System (“PSIAP”) to further digitize tax services. This future system aims to automate tax compliance, provide a more seamless e-invoicing process, and even allow automated completion of tax return forms for taxpayers. (This is a work in progress for coming years.) [edicomgroup.com], [sovos.com] [edicomgroup.com]
• Current Status (2025): E-invoicing via e-Faktur is fully established as the norm for VAT reporting. No major new mandates have been announced in the immediate future, aside from ongoing enhancements to the digital infrastructure. The VAT rate is 11% (rising effectively to 12% in 2025 with adjustments in tax base, per new MoF regulations, though this doesn’t change e-invoicing procedures). [voxelgroup.net] [assets.kpmg.com], [assets.kpmg.com]

• Domestic B2B and B2G: All business-to-business and business-to-government transactions that are subject to VAT must be invoiced through e-Faktur. Indonesia’s mandate applies to all VAT-taxable supplies of goods or services within Indonesia made by a VAT-Registered Person. This includes standard B2B sales and any supplies to government entities (B2G). [voxelgroup.net]
• Domestic B2C: Sales to consumers (end customers) are also covered by the VAT invoice requirements. In practice, retail transactions by a VAT-registered retailer (Pengusaha Kena Pajak Pedagang Eceran) still require an invoice, but they are allowed to issue a simplified e-invoice without the buyer’s tax ID for ease of retail trade. These consumer invoices (with no buyer NPWP listed) are valid for recording VAT but cannot be used by the buyer to claim input tax credit (since the buyer is an end-user). Aside from this simplification, there is no blanket exemption for B2C: VAT-registered businesses must electronically invoice even B2C sales to ensure all VAT collected is reported. The government encourages e-invoicing for B2C to improve transparency, although in practice many such invoices may be aggregated (e.g. a combined invoice for daily retail sales) as allowed by regulation. [taxathand.com], [taxathand.com] [voxelgroup.net] [taxathand.com]
• Exports (Outbound Cross-Border Sales): Exports of goods or services from Indonesia (which are generally zero-rated for VAT) are within the e-invoicing mandate. When a PKP exports taxable goods or provides taxable services abroad, a zero-rated electronic tax invoice must be issued upon export. The e-Faktur system includes specific “transaction codes” to categorize these transactions (e.g. a special code for exports or other zero-rated deliveries). This ensures export sales are reported to the tax authority even though the VAT rate is 0%. [taxathand.com], [vatcompliance.co] [taxathand.com], [assets.kpmg.com]
• Imports (Inbound Cross-Border Purchases): Imports are not invoiced via e-Faktur because the foreign supplier is not in the Indonesian system. Instead, import VAT is collected through customs mechanisms. Upon importation of goods, Indonesian Customs issues import documents that serve as the tax invoice for VAT purposes (allowing the importer to claim input VAT). These import transactions are outside the e-Faktur clearance process and are reported via the import declaration and the importer’s VAT return, not through the e-invoicing portal. (In short, e-Faktur covers domestic and export sales by Indonesian VAT-registered firms; it does not apply to invoices issued by overseas vendors.) [grantthornton.global], [grantthornton.global]
• Transactions not subject to VAT: If a sale is exempt or not subject to VAT under Indonesian law, no VAT invoice is required. Such transactions are outside the e-Faktur mandate. However, virtually all taxable events that do attract VAT require an e-invoice if carried out by a VAT-registered person. [vatcompliance.co]

• Established Businesses: All businesses established in Indonesia that are registered for VAT (Pengusaha Kena Pajak, PKP) fall under the e-invoicing mandate. This includes companies, organizations, and individuals with business enterprises that have obtained a tax ID (NPWP) and PKP status. The current threshold for mandatory VAT registration is annual revenue > IDR 4.8 billion, meaning larger SMEs and all big companies are PKP. Once registered, they must issue all their VAT invoices electronically via the e-Faktur system. Notably, this applies to all companies with headquarters or branches in Indonesian territory. So both principal offices and local branches of Indonesian or multinational companies must comply. [vatcompliance.co] [invopop.com], [grantthornton.global] [voxelgroup.net]
• Non-Established Entities: Foreign or non-resident companies without an establishment in Indonesia generally cannot register for VAT directly and thus are out of scope of e-Faktur. In Indonesia, there is no provision for a completely non-established business to issue local VAT invoices unless they have created a taxable presence. However, if a foreign business has a registered Permanent Establishment (PE) or is otherwise VAT-registered in Indonesia (e.g. through a local branch or subsidiary), it is treated as a local PKP and must use e-Faktur for its transactions in Indonesia. For example, a foreign company that opened an Indonesian branch and crossed the threshold to register for VAT would need to comply with e-invoicing for its local sales. [grantthornton.global], [grantthornton.global] [vatcompliance.co]
• VAT on Digital Services by Non-Residents: (Note: This is a separate regime.) Indonesia requires certain foreign digital service providers to collect VAT on B2C digital supplies, but those are done via a simplified scheme and do not involve e-Faktur invoices. Such non-resident digital suppliers issue their own invoices and report VAT through a special system, not through the standard e-invoicing platform, since they are not PKP in the traditional sense. In summary, the e-invoicing mandate primarily concerns domestically established taxpayers. Non-established companies without a local tax ID are not directly subject to it. [grantthornton.global]

• Invoice Format: Indonesia’s e-invoice is essentially a structured electronic document (in XML format) submitted through the e-Faktur platform. The tax authority’s system then generates a human-readable PDF of the invoice that includes a unique serial number and a QR code attesting to approval. The official invoice number is the Nomor Seri Faktur Pajak (NSFP), issued in sequence by the tax office to each PKP. Each approved e-invoice will show this NSFP and an embedded QR code which encodes key invoice data and verification information. The presence of the QR code indicates the invoice has been cleared by the Directorate General of Taxes (DGT). Only invoices in the prescribed electronic format, cleared by the system, are recognized for VAT purposes; paper or PDF invoices that lack a DGT QR code/approval are invalid. [voxelgroup.net] [invopop.com] [sovos.com], [voxelgroup.net]
• Data Fields: A valid Indonesian electronic tax invoice (Faktur Pajak) must contain all information required by law (as specified in PER-03/PJ/2022). Key data points include: [taxathand.com], [vatcompliance.co]
  • Supplier (Seller) details: Name, address, and NPWP (Tax ID number) of the taxable person delivering the goods/services. [taxathand.com]
  • Customer (Buyer) details: Name, address, and tax identification of the buyer/recipient. For business or government buyers, this means their NPWP; for individual Indonesian buyers, it can be their national ID (NIK) if they don’t have an NPWP; for foreign buyers, a passport or other identification can be used. (For retail consumer sales, buyer details may be left generic as “consumer” or omitted, per the simplified invoice rules, but then such invoice cannot be used to claim VAT credit.) [taxathand.com]
  • Invoice specifics: The serial number of the invoice (NSFP code) and the date of issuance. These are generated through the e-Faktur system. The invoice also includes a transaction code indicating the nature of the sale (e.g. standard sale, export, government customer, self-billing, tax-exempt, etc., codes 01–09 as defined by DGT). [taxathand.com]
  • Description of goods/services: A description of the taxable goods delivered or services rendered, including quantity and unit price. [taxathand.com]
  • Amounts and tax: The total sale value and the amount of VAT charged. If applicable, any Luxury Goods Sales Tax (LST) must also be listed (for high-value items subject to luxury tax). Currently VAT is 11% (rising effectively to 12% in 2025), and this rate or 0% (for exports) should be reflected. The e-Faktur system automatically calculates VAT and will validate these amounts against the rate. [taxathand.com]
  • Seller’s signature: In the context of e-invoices, this is implemented as a digital signature/certificate. The regulation formally requires the name and signature of the authorized person issuing the invoice. With e-Faktur, companies use a digital certificate issued by DGT to sign the invoice data. The system then marks the invoice as approved and tamper-evident (the QR code and digital stamp serve this purpose). No physical signature is needed on the PDF, as the electronic approval suffices. [taxathand.com] [voxelgroup.net]
  • Other info: Any other information as specified by DGT (for example, if the invoice is a credit note or debit note, it should reference the original invoice; if a combined invoice for multiple deliveries in a month, it should meet the conditions in the regulation).
    In short, the e-invoice contains comprehensive details of the transaction and both parties, ensuring the tax authority has all necessary data for VAT enforcement. An invoice that lacks any mandatory element is considered incomplete/invalid and may result in disallowance of input VAT for the buyer and potential penalties for the issuer. [taxathand.com] [grantthornton.global], [grantthornton.global]

• Clearance Model: Indonesia uses a clearance model for e-invoicing. This means every invoice must be reported to and approved by the tax authority (DGT) essentially at the time of issuance before it is finalized. The taxpayer issues the invoice electronically using the e-Faktur system (or integrated software) and submits it online to DGT’s servers for validation. Only after the system checks and approves the invoice (assigning it a valid number and QR code) can the seller provide the invoice to the customer. In practice this is near real-time – typically a matter of seconds or minutes for the system to return an approval. [invopop.com] [voxelgroup.net]
• How Data is Transmitted: Taxable persons have a few options to send invoice data to the DGT:
  • Using the official e-Faktur application provided by the DGT (available as a desktop client or web-based app). Many businesses use the e-Faktur client software to prepare and upload invoices in batches. [sovos.com]
  • Using approved third-party or in-house systems (via an API, often called “host-to-host” connection) that integrate with DGT’s servers. Larger companies often set up system integration so their ERP can communicate directly with the tax authority’s platform.
    In all cases, the taxpayer must obtain a digital electronic certificate from DGT to authenticate and sign submissions. When an invoice is created, the software uses this certificate to sign the data and sends it to DGT for validation. The DGT system then verifies the data format and tax calculations, and if everything is in order, it registers the invoice and returns a confirmation along with the QR code and unique number. This approved invoice is then stored in the central system and can be downloaded/printed by the issuer. [sovos.com] [edicomgroup.com] [voxelgroup.net]
• Reporting Timeline (Deadline): Although clearance is intended to be instantaneous at issuance, there is a hard deadline to ensure no invoice goes unreported. According to DGT Regulation PER-03/PJ/2022 (Art. 18), all e-invoices made in a given month must be uploaded and approved by the 15th day of the following month at the latest. In other words, if for some reason an invoice was not submitted on the day of issuance (say, due to technical difficulties or mistaken delay), the issuer has until the 15th of the next month to get it into the e-Faktur system. Invoices not uploaded and approved by that deadline are rejected by the system and will not be recognized as valid VAT invoices. This rule was confirmed and is now also codified in MoF Regulation No. 81/2024 (Art. 387(1)). There is effectively zero tolerance for late reporting of invoices – the system strictly enforces the cut-off date. (Notably, in early 2025 the tax authority clarified that despite some system issues during the transition to the new core system, the penalty for late invoice uploads was not waived; taxpayers are still expected to meet the deadline.) [news.ddtc.co.id]
  • For practical purposes, most businesses submit invoices in real time or daily to avoid any risk with the deadline. The e-Faktur application is online, so many will upload each invoice immediately during issuance. The 15th of next month is an ultimate deadline intended for contingency.
  • If a force majeure (serious system outage, etc.) prevents timely upload, the regulations allow for issuing invoices manually on paper temporarily, but those still must be entered into the system once available. Barring such exceptional cases, all invoices are expected to be e-reported to the tax authority within the mandated timeframe.
• E-Reporting vs E-Invoicing: Indonesia does not have a separate standalone “e-reporting” system for invoices outside of e-Faktur – the e-Faktur platform itself serves the reporting function by transmitting each invoice to the tax authority. Because every invoice is cleared through the central system, the tax authority automatically receives all the required data in real time (continuous transaction control). Businesses are not required to send additional periodic SAF-T or listings of invoices beyond what e-Faktur already captures. The VAT return filing each month is essentially fed by the e-Faktur data (see Integration with VAT Returns below), so no separate invoice listing needs to be sent. In summary, Indonesia’s e-invoicing doubles as e-reporting – invoice data is transmitted electronically to the DJP as each invoice is issued. The only “deadline” for reporting is the 15th of next month rule noted above. For cross-checking, buyers also report their purchase invoices (which the system matches if both sides use e-Faktur). This comprehensive approach means Indonesia has a full transaction-level reporting via the clearance system, rather than requiring taxpayers to send summary reports of invoices after the fact. [voxelgroup.net]

• Failure to Issue/Report Invoice: If a VAT-registered seller does not issue a valid tax invoice for a taxable transaction, or issues it late (beyond the allowed time), or the invoice is not in the required form (thus deemed invalid), an administrative fine of 1% of the tax base (1% of the sale value) is levied. This penalty is stipulated in Article 14(4) of the General Tax Provisions (KUP) Law and applies per invoice/taxable event. For example, if an invoice of IDR 100 million (tax base) was not properly issued, the fine is IDR 1 million. (This 1% of gross amount roughly equals 10% of the VAT that would be due, since VAT is 10–11%.) [news.ddtc.co.id], [news.ddtc.co.id]
• Invoice Invalidated by Late Upload: As noted, an invoice not uploaded by the 15th of the next month is rejected by the system. In the eyes of the law, that situation is treated as if the taxpayer never issued a valid invoice on time. So the same 1% fine applies for a late-uploaded invoice (the issuer “prepared the invoice late”). There is no exemption from this penalty even if the tax itself is paid; the act of late reporting triggers it. Recent guidance (2025) re-emphasized that these fines will be enforced even during system transitions. [news.ddtc.co.id]
• Consequences for Input VAT: If an invoice is not properly issued or approved, it is not a valid VAT invoice. That means any VAT charged on it cannot be claimed as input VAT by the buyer. This is an indirect penalty: the customer might refuse to pay VAT or the seller might have to absorb the VAT because the buyer loses credit. Thus, non-compliance can disrupt business relationships and VAT recovery. [news.ddtc.co.id]
• Other Penalties: General tax administration penalties also apply (e.g. fines for late VAT return filing, interest on late payment of VAT due, etc.). For instance, late filing of the monthly VAT return itself incurs a fixed IDR 500,000 penalty, and late payment of VAT incurs interest ~2% per month. These are separate from the invoicing-specific penalties. [grantthornton.global], [grantthornton.global] [grantthornton.global]
• Operational and Legal Risks: Beyond monetary fines, non-compliance can lead to operational issues – invoices rejected by the system mean sales might not be recognized for tax purposes, which could cause audits or required corrections. Repeated violations could subject a company to audits and increased scrutiny by the tax office. In extreme cases, if e-invoicing rules are persistently flouted, it could even affect a company’s VAT registration status.
  In summary, compliance is critical: an invoice that isn’t issued through e-Faktur is essentially illegal in VAT terms, and will invite a penalty. The standard penalty is 1% of the transaction value for not properly issuing an e-invoice, alongside the practical disallowance of VAT credit for the counterparty. Companies therefore tightly adhere to the e-Faktur process to avoid these outcomes. [vatcompliance.co] [news.ddtc.co.id]

• Retention Period: The tax law specifies a 10-year retention period for VAT invoices. Businesses must keep electronic archives of all issued e-Faktur invoices (and likely purchase invoices/credit notes) for at least ten years after the transaction. This is to allow audits or verification within the statute of limitations. [invopop.com]
• Format of Archiving: Since e-Faktur invoices are digital, they should be stored in an electronic format that preserves their integrity (usually the XML data and the corresponding PDF). The DGT provides an official mechanism to download and save invoices from the system. Many companies will store PDFs with QR codes as well as the raw data. It’s important that the digital signature/QR remains verifiable in the archive.
• Access by Authorities: Upon audit or request, taxpayers must be able to present these e-invoices to the tax authorities. Because the data is also on DGT’s servers, there is redundancy – but the taxpayer is still expected to maintain its own records.
• Compliance: Failure to maintain the records for 10 years would violate record-keeping obligations and can lead to penalties under general tax rules. However, most companies rely on the e-Faktur system which inherently keeps a copy of all invoices in the central database. The DJP (tax authority) itself retains the data, but prudent practice is for businesses to also back up their invoices.
  In short, archiving of e-invoices for ten years is mandatory. This aligns with Indonesia’s requirement for taxpayers to preserve books of accounts and documentation for a decade. The electronic format of e-Faktur makes it easier to comply, as data can be stored digitally rather than in massive paper files. [invopop.com]

• Monthly VAT Return (SPT) Integration: All approved e-invoices are logged in the central system, which the taxpayer uses to prepare the monthly VAT return. With the introduction of e-Faktur 3.0 (2020), the system began auto-populating portions of the VAT return form with the sales (output VAT) and purchase (input VAT) data that had been captured via e-Faktur. In practice, this means when a taxpayer goes to file the monthly return, the details of how much VAT they collected (from the e-invoices issued) are already tallied, and the input VAT from suppliers’ e-invoices can be cross-verified or pre-filled as well. This reduces manual errors and ensures the return matches the invoice data. [sovos.com]
• Pre-Filled Returns: While the taxpayer still reviews and formally submits the return, the aim is to have a “pre-filled” VAT return using e-invoice information. Indonesia’s tax authority has explicitly moved in this direction: the e-Faktur system automatically integrates each validated invoice into the appropriate tax period’s report. By the end of each month, a taxpayer’s output VAT and allowable input VAT are essentially summarized from the e-Faktur database. The taxpayer can download a draft SPT or use the e-Filing system to see the figures. This capability was a major step toward easing compliance. [edicomgroup.com]
• Automatic VAT Calculation: Because every output transaction is recorded, the tax authority can even compute the net VAT payable or creditable. In the future, with the Core Tax System, it is expected that tax returns may be generated automatically for the taxpayer’s confirmation, thanks to complete data capture. [edicomgroup.com]
• No Pre-Population for non-e-Faktur data: If a taxpayer has certain transactions outside e-Faktur (e.g. import VAT or adjustments), those might still need to be entered manually in the return. But the bulk of the data (domestic sales/purchases) is already there.
• Pre-Filled vs. Pre-Filed: Note that Indonesia still requires the taxpayer to log in and file the monthly return (it’s not entirely automatic submission). But the content is largely pre-filled from e-Faktur records, making filing more of a review process. The introduction of this feature has improved compliance and reduced mistakes.
• Confirmation of Pre-Filled Success: The integration was confirmed by the introduction of e-Faktur v3.0 in Oct 2020, which “enabled the auto-population of VAT returns for taxpayers” under the e-invoice mandate. The Directorate General of Taxes continues to encourage taxpayers to utilize the system so that their filings align exactly with invoice data.
  In summary, yes – Indonesia effectively provides pre-filled VAT returns using e-invoice data. Taxpayers benefit from a streamlined process where their electronic sales and purchase invoices feed into their VAT declarations. This increases accuracy and allows the tax office to cross-check compliance easily. There is currently no regime of completely “pre-issued” returns by the authority (taxpayers still must submit the return), but the groundwork for that is in place with full e-invoicing. [sovos.com]

• Law on General Tax Provisions (UU KUP) – Article 13 and 14 of this law set out the basic obligations and penalties, including the 1% penalty for failing to issue a proper tax invoice. [news.ddtc.co.id]
• VAT Law (Law No. 8/1983 as amended, latest by Law No.7/2021 “HPP”) – This law requires that a VAT invoice be issued for each taxable transaction and grants authority to the DGT to regulate the form and procedure. Recent amendments raised the VAT rate and allowed digital reporting mechanisms.
• DGT Regulation No. PER-16/PJ/2014 (now superseded) – The original regulation introducing electronic VAT invoices (e-Faktur) in 2014. It detailed technical implementation. This was replaced by newer rules.
• DGT Regulation No. PER-03/PJ/2022 – “Tentang Faktur Pajak”: This is the current primary regulation on VAT invoices, effective 1 April 2022. It consolidates rules for creating, correcting, and reporting invoices. PER-03/PJ/2022 defines the required invoice content, the format (including the possibility of combined invoices, use of NIK for individuals, etc.), the procedure for using e-Faktur, and the deadlines for uploading invoices. It revoked several older regulations to simplify compliance. (Reference: Indonesian official regulation PER-03/PJ/2022, as cited in Deloitte Tax Alert.) [taxathand.com] [taxathand.com], [news.ddtc.co.id]
• DGT Regulation No. PER-11/PJ/2022 – This is an amendment to PER-03 (issued later in 2022) that made some adjustments. One known change was reinforcing the upload deadline rules in Article 18, etc.. [news.ddtc.co.id]
• Minister of Finance Regulation No. 18/PMK.03/2021 – An MoF regulation that among other things, set policies for VAT provisions and gave mandate for electronic tax administration modernization. (PER-03/PJ/2022 was aligned to this PMK and to the Harmonization of Tax Regulations Law of 2021.)
• Minister of Finance Regulation No. 81/PMK.03/2024 – This is a 2024 MoF Regulation that, among various VAT procedural changes, reiterated the requirement that tax invoices be uploaded via the taxpayer portal by the 15th of the next month (Article 387). It essentially embeds the e-invoice reporting deadline into a Ministerial Regulation. [news.ddtc.co.id]
• DGT Official Guidance and Portal: The Directorate General of Taxes (DJP) provides information on its website pajak.go.id about e-Faktur and compliance. For instance, it announced training sessions when PER-03/2022 was issued. The official e-Faktur software and manuals can be downloaded from the DJP portal. Taxpayers can refer to the “e-Faktur & e-Nofa” section on the site for technical guides, and the KMS FAQ for common questions. (Most of the official resources are in Indonesian.) [pajak.go.id] [voxelgroup.net]
• DGT Contact Center (Kring Pajak): The tax authority’s helpdesk often publishes updates on e-Faktur issues (e.g. notices about system maintenance or new versions, like the XML converter update). Following these ensures compliance with the latest technical requirements. [news.ddtc.co.id]
• Newsletters and Releases: The DGT and MoF occasionally release official news or press releases regarding e-invoicing developments. For example, in July 2024 they publicized the move toward the new core tax system which will further automate e-reporting. Tax firms (Big 4, local consultants) also issue English-language newsletters summarizing these changes, which are useful external resources (see KPMG, Deloitte, etc. as cited). [edicomgroup.com]
• Legal Texts: Tax professionals can access the full Indonesian text of regulations like PER-03/PJ/2022 on databases (e.g. DDTC, Ortax). These detail every aspect (such as transaction codes, examples of combined invoices, etc.). For instance, Article 18 of PER-03 as amended, and Article 14(4) of KUP Law, were quoted in a 2025 DDTC News piece for clarity on deadlines and fines. [news.ddtc.co.id], [news.ddtc.co.id]