Revenue Memorandum Circular No. 87-2025: CAS Registration Requirements

Overview

Revenue Memorandum Circular No. 87-2025 consolidates and updates the BIR's requirements for the registration of Computerized Accounting Systems (CAS) used by Philippine businesses. The circular supersedes selected prior issuances and introduces updated procedures for system registration, amendment, and cancellation. It applies to all taxpayers required to maintain computerized books of accounts under existing BIR regulations.

This brief provides a factual summary based on publicly available BIR guidance.

Who Must Register a CAS

Under RMC 87-2025, CAS registration is required for:

• Taxpayers whose gross annual sales, earnings, receipts, or output exceed the threshold specified in applicable BIR regulations
• Entities mandated to issue computerized invoices or receipts under existing issuances
• Taxpayers who voluntarily adopt a computerized accounting system in lieu of manual books

Taxpayers should verify their registration obligation with their Revenue District Office (RDO) of jurisdiction.

Registration Process

BIR RMC 87-2025 prescribes the following steps for initial CAS registration:

1. Pre-evaluation submission: Submit a completed BIR CAS application form together with a system description, functional flow chart, and sample output reports to the cognizant Revenue District Office or Large Taxpayer Division
2. System demonstration: Upon BIR evaluation, conduct a live walkthrough of the system's accounting modules and report generation capabilities
3. Issuance of Permit: Upon approval, the BIR issues a Permit to Use (PTU) specifying covered system modules and version
4. Amendment: Any material modification to a registered CAS requires filing of an amendment application prior to deployment

System Requirements and Data Integrity Standards

Registered systems must maintain an immutable audit trail for all accounting entries. BIR RMC 87-2025 requires that CAS systems preserve original transaction data and produce reports reconcilable to the general ledger without manual intervention.

Penalties for Non-Compliance

Taxpayers who operate unregistered computerized accounting systems, or who materially modify a registered system without BIR approval, are subject to administrative penalties as prescribed under the National Internal Revenue Code, including potential disallowance of deductions and surcharges on assessed deficiencies.

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Last updated: Pending CPA review. This brief is prepared for informational purposes based on publicly available BIR guidance. Consult a qualified tax professional for advice specific to your business.