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What Annex F means for BIR Form 2316
The two documents are easy to confuse because both are called annexes in BIR rules, but they are not interchangeable. A BIR response on the Philippine FOI portal distinguishes the Sworn Declaration (Annex C under RR No. 2-2015) from the Certification of the List of Employees Qualified for Substituted Filing (Annex F under RR No. 11-2018). Read the BIR’s FOI response.
| Document | Issuance | What it is |
|---|---|---|
| Annex F | RR No. 11-2018 | Certified List of Employees Qualified for Substituted Filing of ITR |
| Annex C | RR No. 2-2015 | Sworn Declaration |
Use the document name and issuance together when checking a form or asking the BIR for filing instructions. The BIR’s 2026 Revenue Memorandum Circulars index also illustrates that “Annex F” appears in other BIR issuances, so the annex letter alone does not identify a document.
How to prepare the Annex F employee list
When the printed table fits
BIR Revenue Memorandum Circular No. 24-2019, dated February 4, 2019, says the Annex F table applies to employers with eighteen (18) or fewer employees. This describes the capacity of the printed table; it is not a general tax threshold or a complete statement of who qualifies for substituted filing. See BIR RMC No. 24-2019.
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When the list needs more space
For more employees, the circular allows additional pages or a separate list attachment. The certification must clearly refer to the continuation pages or attachment, and the certifying employer or duly authorized representative must sign at the bottom of every attached page. This makes the additional pages part of the certified list rather than an unreferenced supplement.
Notarization
RMC No. 24-2019 states: “the submission of un-notarized certified list may be allowed by this Bureau provided that all the pages attached to the certification are duly signed by the certifying employer or its duly authorized representative.” That is permissive BIR guidance, not a guarantee that an unnotarized list will be accepted in every filing situation.
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Deadline and submission: confirm the applicable year
The BIR FOI response gives February 28 of the following year as the date for the employer to submit the Sworn Declaration and the certification of the list of employees qualified for substituted filing to the RDO. Since that statement appears in an FOI response rather than a current-year circular, confirm the deadline and submission method for the applicable tax year with the BIR or your Revenue District Office (RDO). Instructions may depend on employer filing category and local guidance.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What to verify before filing
- Confirm you have the certified list under Annex F of RR No. 11-2018, rather than the Sworn Declaration under Annex C of RR No. 2-2015.
- Check the current BIR instructions for the applicable tax year, your employer category, and the receiving RDO.
- If the list continues onto other pages, make sure the certification explicitly refers to them and that each page is signed by the certifying employer or authorized representative.
- Do not infer from the printed table’s 18-employee capacity who is eligible for substituted filing; use the governing issuance and current BIR guidance for eligibility.
The cited official materials do not establish the exact current-year template, full eligibility conditions, submission channels for every employer category, or whether employees who resigned during the year should appear on the list. For those questions, seek instructions for the relevant tax year from the BIR or your RDO rather than relying on informal online discussions.
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