Global Daily Tax News, Philippines Institutes Fairer Tax Audit Framework, (Sep 14, 2026)

The Philippines' tax authority has confirmed it has instituted a new uniform nationwide audit framework.

Earlier, the BIR suspended the launch of new audits and investigations through Revenue Memorandum Circular No. 107-2025. This suspension was officially lifted by the BIR on January 27, 2026, in RMC No. 008-2026. The suspension had been in response to taxpayers' complaints regarding decisions to launch audits through the issuance of Letters of Authority (LOAs) and actions taken under Mission Orders (MOs).

LAOs are used to compel taxpayers to provide tax officials with access to their books and other records, while MOs enable officials to surveil and potentially take action against businesses.

Announcing the suspension at the time, the BIR's Commissioner, Charlito Mendoza, had stated: "This suspension is necessary to protect taxpayer rights, strengthen internal discipline, and ensure the integrity of our audit processes. We take every complaint seriously, and any misuse of authority, harassment, or irregularity has no place in the Bureau."

According to the BIR, the new framework, provided for in Revenue Memorandum Order No. 22, includes improved mechanisms for risk-based taxpayer selection, standardized audit procedures, and stronger accountability.

"This new BIR Audit Program strengthens both sides of the process: fairness for taxpayers and accountability within the BIR. Audits must follow clear rules and proper procedures, and our revenue officers must be able to support the assessments they issue with facts and law," Mendoza said.

The BIR said, for taxpayers, the new audit program reinforces the Single-Instance Audit Framework, generally limiting audit authority to one electronic Letter of Authority per taxpayer per taxable year, subject to specified exceptions. Audits are also limited to the tax types and taxable period covered by the authority issued.

To reduce discretion, taxpayer identities are kept anonymized during selection and assignment, as far as practicable, while workload and eligibility controls govern case distribution, it said. Revenue officers and officials must follow prescribed audit procedures, timelines, documentation, and monitoring requirements, it added.

The program also provides separate rules for mandatory cases and institutionalizes the Revalida, or "Audit of Auditors," under which audit reports and assessments may undergo technical and quality review to determine whether findings are supported by facts and law and whether due process was observed, the agency said.

Unauthorized audits, improper case classification, unjustified delays, and other violations may result in administrative sanctions and other liabilities under existing laws and rules, it said.