Understanding PMK 122/2024: New Rules for Non-Exchange Transactions in Indonesia
Many accountants, auditors, and consultants in Indonesia still face challenges when reporting non-exchange transactions like taxes, grants, and subsidies under the older cash-based government accounting rules. This issue becomes more significant as national and regional budgets expand 💸. Without clear standards, financial statements can easily become inconsistent — especially for institutions managing transfers from several ministries under the supervision of the Ministry of Finance.
That confusion often intensifies when new regulations or transition deadlines arrive ⚠️. With accrual-based reporting now mandatory, many financial teams are still adjusting to new recognition and valuation methods. Even experienced advisors in Bali have struggled when clients from regional governments were asked to restate their accounts just to align with the latest financial standards from the Government Accounting Standards Committee.
With PMK 122/2024, the Ministry of Finance has established detailed rules for recognizing, measuring, and disclosing revenue from non-exchange transactions under PSAP No. 18. This regulation applies to taxes, grants, subsidies, debt forgiveness, and intergovernmental transfers 🔎. It reflects Indonesia’s shift toward accrual-based transparency — a policy reinforced by the Directorate General of Taxes and related fiscal authorities to strengthen accountability in public sector reporting.
Thanks to these new standards, accountants in government offices can now apply uniform valuation principles. For example, a donated ambulance valued at Rp 1.8 billion must be recorded as an asset at fair value — even when no payment occurs. This clarity reduces last-minute audit issues and improves comparability between fiscal years, ensuring data integrity across departments.
One regional government client in Bali recently found that over 40% of its “miscellaneous income” was actually conditional grant revenue that needed to be reclassified as liabilities until all terms were fulfilled ✅. Once their financial statements followed the PMK 122/2024 framework, they passed audit verification for the first time in two years — showing how critical it is to prepare early under the new guidelines supported by the State Treasury Directorate.
Now is the best time to train accounting teams, revise internal policies, and test updated reporting formats before the 2026 implementation deadline 🧠✨. For consultants and PT PMA advisors working with government or donor-funded projects in Indonesia, mastering PMK 122/2024 is not only a compliance necessity — it’s a strategic advantage that builds trust and credibility in every audit cycle.
Table of Contents
- What Is PMK 122/2024 and Why It Matters for Public Finance
- How Non-Exchange Transactions Are Defined Under New Rules
- Key Requirements of PSAP No. 18 for Asset Recognition 🧾
- Fair Value Measurement Explained for Government Reporting
- Impact on Tax, Grants, and Debt Forgiveness Disclosure 📊
- Timeline for Implementing PMK 122/2024 in Indonesia
- Best Practices for Accountants and Consultants in Bali
- Real Story: How One Bali Government Fixed Audit Issues ⚙️
- FAQs About PMK 122/2024 Non-Exchange Standards ❓
What Is PMK 122/2024 and Why It Matters for Public Finance
PMK 122/2024 is a new regulation in Indonesia that changes how government agencies record non-exchange transactions like taxes, grants, and donations. Before this rule, many public offices used cash-based accounting, meaning they only recorded money when it was received or spent. With this update, they must now follow an accrual-based approach, which logs income and assets when control is obtained — not just when cash is transferred 🏛️.
This matters because it improves transparency. Citizens and auditors can now see more clearly how funds, property, and service-based donations are used in public programs. For example, if a local government receives a fire truck worth billions of rupiah from a donor, the asset must now be properly valued and entered into financial statements, even if no money exchanged hands 🚒.
Another key benefit is making public accounts more compliant with global standards, so financial reports are easier to compare and verify. This helps prevent corruption, builds public trust, and supports better budgeting. For accountants in Indonesia, especially those in Bali working with PT PMA or government-related projects, understanding PMK 122/2024 is now essential for staying relevant and compliant.
Under PMK 122/2024, non-exchange transactions are activities where one party gives resources to another without expecting an equal return 🎁. This includes things like public taxes, grants, subsidies, and debt forgiveness. What makes this different from regular business transactions is that the benefit is not tied to a direct exchange of goods or services.
Let’s say a business donates office equipment to a local school. The school isn’t paying for the equipment; the donation is free. Under the new rules, that equipment must be recorded as an asset at fair value, because it’s something the school can use over time. The transfer is considered revenue, even though it didn’t involve cash.
Indonesia’s government created this rule to help public institutions properly track assets and resources that support social programs. Since many government entities weren’t doing this before, their financial reports didn’t fully reflect how resources were managed. Now, thanks to these new standards, such transactions must follow a more structured and traceable system 🧩 — keeping things more accountable and consistent across regions.
PSAP No. 18, which is at the heart of PMK 122/2024, has specific rules for how non-exchange transactions should be recorded as assets. First, the government agency must have control over the asset. That means it can use or benefit from the resource — like land, vehicles, buildings, or even donated software.
Second, the value of the asset needs to be reliably measured, which usually means fair value at the time it’s received. For example, if a charity donates medical equipment worth Rp 500 million to a public hospital, the asset must be recorded at that fair value, even if it wasn’t bought with government money 🤝.
Sometimes conditions are attached — like using the donation for a specific purpose within a timeframe. In such cases, the asset may be recorded, but the income linked to it isn’t recognized until the conditions are met. This helps ensure that liabilities and obligations are clear and that funds aren’t misreported as revenue too early.
So, government accountants must pay attention not only to what they receive, but also to what rules or expectations come with it. This helps align financial truth with accountability, especially when external audits or public reviews happen 📋.
Fair value is a key concept in PMK 122/2024. It means valuing an asset at its current market price, not what someone originally paid for it. For example, if someone donates a building worth Rp 3 billion to a local government office, it must be recorded at that price — even if it was bought years ago at a lower cost 🏢.
This helps financial records show real economic value. When government reports reflect true market conditions, they become more useful for decision-making, budgeting, and public accountability. It also aligns Indonesia with international public sector accounting standards, which many other countries already follow 🌏.
To determine fair value, accountants may need certified appraisers, market comparison data, or expert analysis depending on the type of asset. For instance, valuing a car or a plot of land is different from valuing donated software licenses or intellectual property. This means government teams need better training and support to meet these new obligations confidently.
Taxes are a big part of non-exchange revenue. Under the updated rule, taxes are recognized as income when there’s a legal right to collect and the taxable event has occurred — not when taxpayers actually pay. So, even if someone delays paying their tax bill, the income still gets recorded in the year it’s due 📅.
Grants and subsidies are also covered. If a government receives a grant with no strings attached, it’s recorded as income immediately. But if the grant requires certain actions — like building infrastructure — then it’s recorded as a liability until the activity is completed.
Debt forgiveness is another example. If the central government cancels a regional debt of Rp 5 billion, that amount becomes income in the books of the regional government. These updates help clarify how income happens in government, instead of relying on cash flows that could be delayed, disputed, or unclear 🏦.
The official implementation of PMK 122/2024 begins with the 2026 fiscal year 📆. While that might seem far away, government offices, accounting firms, and consultants need to prepare now. This includes upgrading accounting systems, training staff, testing fair value processes, and updating reporting formats.
Early adoption is allowed — which means some regions may already start following PSAP No. 18 if they’re ready. Others may need time to fix past errors, transition from cash-based reports, or gather missing asset valuations. Waiting until the last minute will only make that transition harder 🚨.
This is why accountants and PMA advisors in places like Bali are encouraging clients to start running hybrid reports in 2025. That way, they can fix any problems before the rule becomes mandatory, and avoid audit headaches or late penalties when the new requirements kick in.
For professionals in Bali who help government offices, NGOs, or donor-funded projects, the key is to get familiar with PMK 122/2024 and offer proactive support ✅.
Start by conducting a review of past financial statements to identify areas where non-exchange transactions were misclassified or missed entirely. Then, update accounting manuals, set fair value procedures, and train staff on how to use appraisal or valuation data.
It’s also smart to run simulations for common scenarios, like donated school property or grant-funded equipment. This helps build confidence and avoid mistakes. Setting up internal controls and timelines will ensure everyone is ready by 2026.
Consultants who learn early, prepare early, and help their clients do the same will have a huge advantage. They’ll be seen as trustworthy experts in a field where many are still learning to adapt 🌱.
Meet Putu Yasa, a 41-year-old finance officer from Tabanan, Bali. For years, his district’s financial reports failed audits because donations and grants weren’t properly recorded. Ambulances, medical equipment, and even donated land were logged under “miscellaneous income” instead of being treated as assets.
After attending a workshop on PMK 122/2024, Putu realized the problem. His office wasn’t recognizing non-exchange revenue properly — they were using cash basis reporting and missing millions of rupiah worth of assets. He worked with a consulting firm in Denpasar to reclassify past donations using fair value, based on market estimates and appraisal data.
Within six months, the district’s books were reorganized. They documented every grant, subsidy, and asset transfer using the new standards. When the auditors came back, they passed — for the first time in four years.
Putu became a trusted advisor in his own department, proving how good preparation can turn things around. His story shows that change is hard, but possible — especially when grounded in solid rules and training 💡.
Starting fiscal year 2026, with optional early adoption.
Taxes, grants, subsidies, donations, and debt cancellation.
At fair value, when the government gains control of them.
Then it’s recorded as a liability until conditions are met.
No, only government entities and related institutions.
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