BIR RMC 39-2026: 2025 Income Tax Return Attachment Deadlines
Complete guide to BIR RMC 39-2026 attachment deadlines for 2025 income tax returns. Learn about eAFS submission deadlines, key dates, and avoid BIR penalties.
What you'll learn in this BIR RMC 39-2026 guide
This BIR RMC 39-2026 guide clarifies the deadline for submitting required attachments to 2025 Annual Income Tax Returns (BIR Form No. 1701) through the Electronic Audited Financial Statement (eAFS) system.
For your 2026 tax compliance, also see our BIR Form 1701 Electronic Filing Guide, BIR RMC 037-2026 1701 MS Electronic Filing Guide, and Philippines Tax Calendar 2026 Guide.
What is Revenue Memorandum Circular No. 39-2026?
Important BIR Clarification
Revenue Memorandum Circular No. 39-2026 clarifies the deadline for submitting required attachments to your 2025 Annual Income Tax Return
eAFS Attachment Deadline
It addresses when taxpayers must submit their attachments through the Electronic Audited Financial Statement (eAFS) system after electronically filing BIR Form No. 1701
Who This Applies To
This circular is crucial for Filipino business owners, freelancers, and mixed income earners because it provides clear guidance on attachment deadlines, helping you avoid penalties and ensure compliance with BIR requirements
Understanding the eAFS Requirement
What is eAFS?
The eAFS system is BIR's digital platform for submitting financial statements and other required attachments electronically
Who Must Use eAFS
Why eAFS Matters
The eAFS system ensures that your financial records are properly documented and accessible to the BIR for audit and verification purposes.
The Three Filing Scenarios
⚠️ Important: All Scenarios Have the Same Attachment Deadline
Regardless of when you file BIR Form No. 1701, the deadline for submitting eAFS attachments is consistently May 15, 2026
Filing on or Before April 15
If you file on or before April 15, 2026 (Wednesday)
Filing on April 16
If you file on April 16, 2026 (Thursday)
Filing on May 15
If you file on May 15, 2026 (Friday)
Key Dates to Remember
📅 2026 Tax Filing Calendar
🚨 Critical Reminder
Regardless of when you file your BIR Form No. 1701 (whether on April 15, April 16, or May 15, 2026), the deadline for submitting your eAFS attachments is consistently May 15, 2026.
Step-by-Step eAFS Submission Process
Prepare Your Financial Statements
Before accessing the eAFS system, ensure you have: audited financial statements (if required), statement of financial position (balance sheet), statement of comprehensive income (income statement), notes to financial statements, tax reconciliation schedule, and other required supporting documents
Access the eAFS Portal
Go to the BIR eAFS portal (https://efiling.bir.gov.ph/), log in using your BIR-registered account credentials, and navigate to the eAFS submission section
Upload Your Attachments
Select the tax return type (BIR Form No. 1701), upload your financial statements in the required format (PDF), ensure all files are properly named and organized, and review all uploaded documents for accuracy
Submit and Acknowledge
Submit your eAFS attachments, wait for the system confirmation, save or print the acknowledgment receipt, and keep a copy for your records
Common Mistakes to Avoid
Missing the May 15 Deadline
Many taxpayers assume that if they file early (e.g., in March or early April), they have more time to submit attachments. This is incorrect. The attachment deadline is always May 15, 2026, regardless of when you file your return.
Submitting Incomplete Attachments
Ensure all required documents are included. Incomplete submissions may be rejected, leading to potential penalties.
Using Incorrect File Formats
The eAFS system typically requires PDF files. Submitting documents in other formats (Word, Excel, etc.) may cause submission errors.
Not Keeping Copies
Always keep copies of your submitted attachments and acknowledgment receipts for your records. These are important for audit purposes and future reference.
Waiting Until the Last Minute
Technical issues, system downtime, or other unforeseen problems can prevent last-minute submissions. Aim to submit your attachments at least a week before the deadline.
Tips for Timely Submission
Create a Filing Calendar
Mark important dates on your business calendar: April 15, 2026 (Tax return filing deadline), May 15, 2026 (eAFS attachment deadline), and set reminders 2 weeks before each deadline
Prepare Documents Early
Start preparing your financial statements and supporting documents at least 2-3 months before the deadline. This gives you ample time to address any issues or discrepancies.
Work with Your Accountant Early
If you work with an accountant or bookkeeper, coordinate with them well in advance. Ensure they understand the May 15 attachment deadline and can prepare your documents accordingly.
Test the eAFS System
Before the actual submission deadline, familiarize yourself with the eAFS portal. Test the system to ensure your files meet the requirements and can be uploaded successfully.
Have a Backup Plan
In case of technical issues, have alternative arrangements ready: a reliable internet connection, access to a different computer, and contact information for BIR technical support.
What Happens If You Miss the Deadline
Consequences of Late Submission
Missing the May 15, 2026 deadline for eAFS attachment submission can result in penalties, increased audit risk, compliance issues, and potential interest charges.
Potential Penalties
- ✗ Penalties for late submission of required attachments
- ✗ Increased risk of tax audit selection
- ✗ Compliance issues affecting tax status
- ✗ Potential interest charges on late submissions
If You Anticipate Missing the Deadline
- → Contact your Revenue District Office (RDO) immediately
- → Explain your situation clearly
- → Request guidance on how to proceed
- → Document all communications
2025 Annual Income Tax Return Filing Checklist
Before Filing Your Return
- Gather all income documents (salary, business income, other income)
- Collect all expense receipts and supporting documents
- Prepare your financial statements
- Reconcile your books with bank statements
- Calculate your taxable income accurately
- Determine applicable tax deductions and credits
Filing Your BIR Form No. 1701
- File electronically through the BIR eFiling portal
- Double-check all entries for accuracy
- Pay any taxes due
- Save or print the filing acknowledgment
- Note your filing date
Submitting eAFS Attachments
- Prepare all required attachments (financial statements, schedules)
- Convert documents to required PDF format
- Access the eAFS portal
- Upload all attachments
- Review uploaded documents
- Submit and save acknowledgment
- Keep copies for your records
After Submission
- Organize all filing documents in a secure folder
- Update your tax compliance records
- Plan for next year's tax filing
- Consult with your tax advisor if needed
Conclusion
Key Takeaway
Revenue Memorandum Circular No. 39-2026 provides clear guidance on the deadline for submitting eAFS attachments for your 2025 Annual Income Tax Return. The key takeaway is simple: regardless of when you file BIR Form No. 1701 (whether on April 15, April 16, or May 15, 2026), you must submit your attachments through eAFS by May 15, 2026.
By understanding these requirements and preparing early, you can ensure compliance with BIR regulations and avoid potential penalties. Mark your calendars, prepare your documents, and submit your attachments on time to maintain good standing with the BIR.
For additional guidance or clarification, don't hesitate to contact your Revenue District Office or consult with a qualified tax professional.