BIR Alphalist: What It Is and How to File (1604-C & 1604-E)

The alphalist is the alphabetical list of employees or income payees that a withholding agent attaches to its BIR annual information return. It reports, per individual, the total income paid for the year and the corresponding tax withheld and remitted.

Throughout the year, an employer or withholding agent files monthly or quarterly remittance forms (for example, BIR Form 1601-C for compensation and 1601-EQ for expanded withholding) that report lump-sum totals. The alphalist is the year-end reconciliation: it breaks those lump sums down by name, TIN, and amount so the BIR can match what each individual earned and had withheld against that person's own income tax return.

Because it is a per-individual breakdown tied to TINs, the alphalist is also how the BIR cross-checks employees' Forms 2316 and payees' Forms 2307. Errors, mismatched TINs, or missing payees are a common trigger for a Letter Notice or assessment.

The alphalist is never filed on its own — it is an attachment to an annual information return. Which return, and therefore which alphalist, depends on the type of withholding tax. There are three annual information returns, each with its own coverage and deadline.

Form 1604-C covers compensation income and carries the alphalist of employees. Form 1604-E covers expanded (creditable) withholding on payments to suppliers and other payees, and carries the alphalist of payees subjected to expanded withholding tax. Form 1604-F covers final withholding taxes (for example, on certain fringe benefits, interest, or dividends) and is a separate return — do not merge it with 1604-C or 1604-E.

The 1604-C alphalist must list every employee who received compensation during the year, not just those with tax withheld. That breadth is what catches many employers out.

It includes employees with tax actually withheld, employees whose compensation fell within the tax-exempt thresholds (so nothing was withheld), minimum-wage earners (who are exempt from income tax on their statutory minimum wage, holiday pay, overtime, night-shift differential and hazard pay), and employees terminated or separated during the year.

Each employee's figures on the alphalist should reconcile to that employee's BIR Form 2316. If your year-end 2316s and your 1604-C alphalist disagree, fix it before filing — the BIR matches them.

Categories that must appear in the 1604-C alphalist

• Employees with income tax withheld during the year
• Employees whose compensation was within the exempt threshold (no tax withheld)
• Statutory minimum-wage earners
• Employees terminated or separated before year-end
• Employees who had two or more employers during the year — they are NOT qualified for substituted filing and must file their own annual ITR (BIR Form 1700)

Covered taxpayers must submit the alphalist electronically in the prescribed .DAT format — manual, PDF, scanned, or plain Excel alphalists are not accepted. The BIR provides a free Alphalist Data Entry and Validation Module that produces the correct .DAT file.

The standard workflow: (1) install or open the BIR Alphalist Data Entry and Validation Module; (2) encode or import each employee/payee record with the correct TIN, name, income, and tax-withheld figures; (3) run the validation routine to catch TIN and format errors; (4) generate the validated .DAT file; (5) submit it. Non-eFPS filers submit the .DAT by emailing it to the BIR eSubmission facility at esubmission@bir.gov.ph and keep the system-generated acknowledgement; eFPS filers attach and transmit through eFPS.

Keep the validation report and the email/eFPS confirmation. That acknowledgement is your proof of timely submission if the figures are ever questioned.

Filing checklist

• Use the current BIR Alphalist Data Entry and Validation Module version
• Verify every TIN — invalid or missing TINs fail validation
• Reconcile alphalist totals to the monthly/quarterly returns (1601-C, 1601-EQ)
• Generate the validated .DAT (not PDF/Excel) for submission
• File the parent return (1604-C / 1604-E) and submit the .DAT via eSubmission or eFPS
• Save the acknowledgement email or eFPS confirmation

BIR Form 2316 is the Certificate of Compensation Payment and Tax Withheld that each employer issues to each employee. The per-employee figures on the 2316 are the same figures that feed that employee's line in the 1604-C alphalist — the two must agree.

Form 2316 has two separate obligations. Employers must furnish the signed 2316 to each employee on or before January 31 of the following year. Employers must also submit the 2316s (or the duplicate copies) to the BIR — historically due by February 28, though the exact deadline and acceptable submission channel are set by the governing Revenue Regulation, so confirm the current rule before relying on a fixed date.

Practically, treat the 2316 issuance, the 1604-C alphalist, and the 2316 submission to the BIR as one reconciled year-end package: same names, same TINs, same income and tax-withheld amounts.

Failure to file, late filing, or filing an incorrect or incomplete alphalist exposes the withholding agent to penalties under the National Internal Revenue Code — generally surcharge and interest on any related deficiency (Sec. 248 and 249) plus a compromise penalty, and the penalties for failure to file an information return or supply correct information under Sec. 250 and Sec. 255.

Because the exact peso amounts depend on the violation, the period, and current BIR issuances, treat any specific figure as something to confirm against the live NIRC sections and the prevailing Revenue Memorandum Order on compromise penalties rather than a fixed number.

The cheapest path is correctness on time: reconcile to the monthly returns, validate the .DAT, file 1604-C by January 31 and 1604-E by March 1, and keep the acknowledgement.