Bureau of Internal Revenue
The Bureau of Internal Revenue (BIR) issued the following issuances on 27 January 2026 to provide guidance on the conduct and resumption of tax audit and field operations:
Revenue Memorandum Circular (RMC) No. 8-2026 provides the lifting of the suspension previously imposed under RMC No. 107-2025 and authorizes the resumption of tax audit and other field operations as follows:
- Issuance of Electronic Letters of Authority (eLAs), Mission Orders (MOs), and Tax Verification Notices (TVNs);
- Continuation and completion of audit cases previously suspended pursuant to RMC No. 107-2025;
- Enforcement, verification, assessment, and collection activities requiring audit or field operations; and
- Other audit or enforcement activities necessary to protect revenue or enforce compliance, subject to applicable issuances and the controls set forth in RMO No. 1-2026.
RMC No. 8-2026 shall take effect immediately.
(R.G. Manabat & Co. Note: The RMC was posted on the BIR website on 27 January 2026.)
Revenue Memorandum Order (RMO) No. 1-2026 prescribes the revised policies, controls, and procedural guidelines for tax audit and assessment following the lifting of the suspension under RMC No. 107-2025.
The following are the salient points of RMO No. 1-2026:
- A Single-Instance Audit Framework is introduced, which prohibits the issuance of multiple or overlapping eLAs covering the same taxpayer and taxable year. Under this approach, a taxpayer is generally subject to only one eLA for a given taxable year, covering all applicable internal revenue tax types, including Value-Added Tax (VAT). Exceptions are provided for fraud cases where one eLA may cover several years for certain transactional, event-based or terminal in nature audits [see Part IV (B) of the RMO].
- Beginning 4 March 2026, all pending eLAs for the same taxpayer and taxable year shall be automatically consolidated into one eLA to streamline audit processes. A taxpayer with multiple pending eLAs covering the same taxable year may file a written Request for Non-Consolidation, allowing such eLAs to proceed separately. The written request must be filed not later than 16 February 2026. The RMO provides the specific procedures and guidelines to be followed and observed in opting to not consolidate pending eLAs.
- New eLAs shall be issued based on system-assisted taxpayer selection to ensure objectivity and integrity, with anonymized selection and assignment to reduce discretion-related risks. The defined criteria and parameters in audit selection are outlined in Annex A of the RMO No. 1-2026, and taxpayer selection is subject to centralized approval.
- All existing task forces that were created primarily for the conduct of audit and assessment functions will be absorbed by the appropriate regular offices to align with the Single-Instance Audit Framework.
- Transition guidelines are provided for the VAT Audit Sections (VATAS) and Large Taxpayers VAT Audit Units (LTVAU), which shall wind up operations until 15 May 2026 to ensure alignment with the Single-Instance Audit Framework.
- The Revenue Officers authorized to conduct tax audits are now required to use a standardized audit checklist in Annex B of the RMO, to serve as the uniform reference for identifying, requesting, receiving, and evaluating documents necessary for audit, verification, or other authorized compliance activities.
RMO No. 1-2026 shall be effective immediately.
Here are the links to the full texts of the issuances:
RMC No. 8-2026, RMO No. 1-2026, RMO No. 1-2026 Annex A, and RMO No. 1-2026 Annex B.