Regulatory updates - Philippines

The updated audit procedures entail key changes, including:

• Audit notices must now prominently display their scope by disclosing if it refers to a full or limited examination.
• The BIR is prohibited from issuing multiple electronic letters of authority (eLAs) for the same taxable year but will instead conduct a single audit.
• Taxpayers wishing to separate their VAT audits may file a request no later than February 16, 2026.

Taxpayers may consult the updated control procedures in detail here.

The resumption of tax audits with the updated control procedures took effect immediately on January 27, 2026.

The RMC states the suspension aims to protect taxpayers from irregular, untimely or intrusive audits by limiting the field operations conducted by the authority.

The issuance of the circular stems from complaints from taxpayers, stakeholders and internal units reporting on irregularities and inconsistencies in audit operations.

During the suspension, the BIR will conduct a review of existing policies and procedures. Issuance of written orders to audit or investigate taxpayer liabilities is suspended during this period, except for in the following cases:

• Investigation of cases prescribing within six (6) months from the date of this Order
• Processing and verification of estate tax returns, donor's tax returns, capital gains tax returns, and withholding tax returns on the sale of real properties or shares of stocks, together with the documentary stamp tax returns related thereto
• Examination or verification of internal revenue tax liabilities of taxpayers retiring from business
• Letters of Authority (LOA)/ Mission Orders (Mo) necessary for active criminal probes conducted by duly authorized enforcement units through verified intelligence reports, inter-agency referrals, third-party data validation, or risk-scoring anomalies that require immediate audit action where delay would prejudice the government's case
• Claims for refund where the issuance of an LOA is statutorily required
• Other matters/concerns where deadlines have been imposed or under the orders of the Commissioner

The suspension took immediate effect on November 24, 2025, and will remain in force until lifted by the Commissioner.

On October 16 2025, the Bureau of Internal Revenue (BIR) published Revenue Regulations No. 026-2025 amending the transitory provisions of Revenue Regulations No. 011-2025.

Extension to e-invoicing compliance deadline

The amendment postpones the deadline for taxpayers in scope of the requirements to issue electronic invoices according to the below:

• Previous deadline: March 14, 2026
• Current deadline: December 31, 2026.

By the deadline, in-scope taxpayers must issue electronic invoices in XML, JSON or any other format as prescribed by the BIR from an invoicing system accredited by the BIR.

Taxpayers affected by the extension

The following taxpayers are in scope of the obligation, and thus affected by the postponement:

• Taxpayers engaged in e-commerce or internet transactions
• Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS)
• Large Taxpayers
• Taxpayers using Computerized Accounting System (CAS), and Computerized Books of Accounts (CBA), or other invoicing software

Sales Data Reporting upon establishment of BIR system

The amendment reemphasizes that the sales data reporting obligation remains dependent on the establishment of a BIR system capable of storing and processing the required data.