BIR RMO No. 22-2026 — the consolidated and revised BIR Audit Program

What the Order does

• Consolidates every BIR audit programme into one uniform framework, building on RMO No. 1-2026, as amended.
• Institutionalises the Single-Instance Audit Framework — generally one electronic Letter of Authority per taxpayer, per taxable year, covering all internal revenue taxes rather than fragmented, per-tax audits.
• Anchors audits on risk-based, system-assisted and anonymised case selection.
• Confirms that an audit may proceed only under a valid eLA, Tax Verification Notice (TVN) or Mission Order (MO). Anything else is unauthorised.
• Takes effect immediately upon issuance.

Timelines to remember

Selection triggers to watch

Case selection is risk-based and system-assisted. These are the indicators that put a return in front of an examiner.

• Under-declared sales or income, or overstated expenses, by 30% or more — prima facie fraud.
• A drastic decrease in reported sales or VAT payments.
• Input VAT exceeding 75% of total output tax.
• Substantial sales but a net loss reported.
• Income tax due below 2% of gross sales or revenues.
• Assets up by more than 50% year on year despite a net loss.
• Over five years in operation and never audited.
• Discrepancy notices, or third-party information that does not match the return.

For taxpayers

• Verify authority first. No audit is valid without a duly issued eLA, TVN or MO.
• One eLA per taxable year. Expect a single, all-tax audit; its scope is limited to what the eLA, TVN or MO states.
• Mind the 10-day clock. Not submitting requested documents within ten days triggers a First Notice, then a Second and Final Notice, then a Subpoena Duces Tecum, and possible criminal action.
• You may choose the venue. The Taxpayer’s Consent on Audit Venue lets the examination sit at your office or at the BIR office — until a Subpoena Duces Tecum is issued.
• Keep complete records. Certified true photocopies may be accepted; originals may still be required for verification.

For external auditors and CPAs

• The consolidated eLA shifts audits from fragmented, VAT-only examinations to comprehensive all-tax ones. Prepare clients accordingly.
• Map working papers to the BIR’s Standard Checklist of Requirements. Complete documentation and a clean audit trail are now central.
• Know the risk indicators driving selection, so a client can self-assess before an eLA lands.
• Watch the timelines: 180 days (Regional / OAS) or 240 days (LTS) to complete, and the 15-day PAN-to-FLD/FAN window under RR 18-2013.
• The “Audit of Auditors” (Revalida) reviews BIR examiners’ own work — expect more rigorous, better-documented assessments.

For businesses and stakeholders

• Anonymised, system-assisted assignment reduces undue influence, and revenue officers’ caseloads are capped and monitored.
• A full digital trail. Case activity is tracked in BIR systems (IRIS-CMS-A and eLAMS) end to end.
• Due process safeguards. The PAN, the FLD/FAN and the FDDA follow prescribed timelines and formats.
• Voluntary compliance is the theme. Accurate returns and good records lower your risk profile.
• Accountability both ways. Erring officials face administrative sanctions; taxpayers get a fairer, more transparent process.

What this means for you

A cleaner, more transparent and better-documented audit process — and a higher bar for record-keeping and audit-readiness. Accurate returns, complete working papers and reconciled books are your best protection. With examiners’ own work now subject to review, expect assessments to be more rigorous and more firmly evidenced.

How we can help

From audit-readiness reviews and documentation gap-checks to reconciliation, BIR examination support, and assessment and protest assistance — we help you stay ready before an eLA ever arrives.

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