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Are you a "large taxpayer"? How BIR classification decides your deadline

The BIR keeps two separate large-taxpayer lists. Under the Ease of Paying Taxes Act, a Large Taxpayer is a business with gross sales of P1 billion or more in a taxable year, and the BIR's ORUS system shows each business its class. The Large Taxpayers Service is a different list, joined only by written notice from the Commissioner. As of 6 October 2026, either list puts a business under BIR e-invoicing, with 31 December 2026 the date in force.

Illustration: a row of three tiles joined in order, a receipt, then a government building, then a document with a tick, with a government building highlighted in olive.

Why does it matter which large-taxpayer list you are on?

On 6 October 2026, the BIR opened its Taxpayer Portal to taxpayers "classified as Large under Ease of Paying Taxes (EOPT) Act." In May 2026 it had opened the same portal, as a pilot, to companies registered with its Large Taxpayers Service. Same word, two groups, and the BIR handles them separately. Being in either group puts a business inside the BIR e-invoicing mandate, with 31 December 2026 the date in force.

The EOPT list is a sales band: gross sales of P1 billion or more in a taxable year, under RR No. 8-2024. The Large Taxpayers Service, or LTS, is a list of companies the Commissioner has notified in writing, chosen under RR No. 17-2010 on criteria that include sales but also tax payments, net worth, purchases, capitalization and group membership. A company can be on one list, both, or neither.

This post explains how each list works, how to find out where your company stands, and what follows from each answer. It reflects BIR issuances as of 6 October 2026. It is not tax advice: confirm your own position with your Revenue District Office (RDO), your LT office or your accountant.

What are the four EOPT taxpayer classes?

RR No. 8-2024 sorts business taxpayers into four classes by gross sales for the taxable year. It implements Section 21(b) of the Tax Code as amended by the EOPT Act, and RMO No. 37-2024 dates its effectivity to 27 April 2024. The bands are fixed peso amounts, and only the top band puts a business in the EOPT Large category of the e-invoicing rules.

"Gross sales" has a narrow meaning here. RR No. 8-2024 defines it as "total sales revenue, net of VAT, if applicable, during the taxable year, without any other deductions," and counts business income only. Compensation income, passive income under Sections 24, 25, 27 and 28, and income excluded under Section 32(B) are left out. Each taxpayer is classified on its own gross sales, so two companies in the same family group can sit in different classes.

  • ·Micro: gross sales of less than P3 million.
  • ·Small: P3 million to less than P20 million.
  • ·Medium: P20 million to less than P1 billion.
  • ·Large: P1 billion and above.

How did the BIR decide which class you are in?

Mostly from a 2022 tax return. Under RMO No. 37-2024, businesses registered in 2022 or earlier were classified on the gross sales declared in their income tax return for taxable year 2022. If your sales have grown since then, the class on the BIR's record can be lower than your sales today, and it stays there until it is reclassified.

The other starting rules in the same order:

  • ·Registered in 2022 or earlier with no 2022 return on file: Micro, or Small if VAT-registered.
  • ·Registered in 2023, or in 2024 before 27 April: the same, Micro, or Small if VAT-registered.
  • ·Registered after 27 April 2024: classified on what the business declared in its registration form, BIR Form No. 1901 or 1903.
  • ·Branches: a branch follows the classification of its head office.
  • ·Mixed-income individuals: only business income counts.

Who can change your class?

You can. Requests go through the head office. A move up can be made online in ORUS or with a registration update form at your home RDO, and RMO No. 37-2024 says such requests are processed for approval automatically; a manual one is approved within the day. A move down, other than from Small to Micro, needs an income tax return, income statement or other proof of gross sales for the last two years, and the RDO or LT office notifies you of a seven-working-day processing period.

The BIR can as well. Its National Office can run a reclassification every two years "on the basis of taxpayers' gross sales from their latest filed ITRs or VAT returns, if ITRs are not available." An RDO or LTS division can also recommend moving one taxpayer after verifying its sales; once approved, the new class takes effect when the taxpayer receives the notice. After a BIR-initiated change, a taxpayer cannot request another in the same taxable year without meritorious reasons, and the decision of the Regional Director or the Assistant Commissioner for the LTS on that request is final.

How do you check your EOPT class in ten minutes?

Look it up in ORUS, the BIR's Online Registration and Update System. RMC No. 62-2024 added a "BIR Registered Business Search and Taxpayer Classification Inquiry" function, and RMO No. 37-2024 sends taxpayers to it. You need the registered name or trade name as shown on the Certificate of Registration, BIR Form No. 2303, plus the TIN and branch code. These are the steps as the BIR published them in May 2024:

  1. Open ORUS and choose "Verify TIN/Search BIR-Registered Business" from the functions shown.
  2. Select "BIR-Registered Business Search and Taxpayer Classification Inquiry" from the dropdown, then click Proceed.
  3. Enter the registered name or trade name, the TIN and the branch code. Use the head office, because branches follow it.
  4. Tick the verification box and click Search. The class appears as Micro, Small, Medium or Large.
  5. Write the class next to your gross sales, net of VAT, from the last two income tax returns. If the two disagree, the BIR's record is out of date, and the section on classification changes below says what that does to your deadline.

What is the Large Taxpayers Service, and how does a company get on it?

The LTS list is kept by the Commissioner; a company does not fall into it by crossing a number. RR No. 17-2010 defines a Large Taxpayer as one that "has been classified and notified in writing" by the Commissioner as meeting the criteria. Meeting a criterion makes a company a candidate. The written notice puts it on the list, and only a written notice of delisting takes it off.

Two other provisions shape the list. Section 4.6 lets the Commissioner select and notify additional Large Taxpayers. Section 7 lets the Commissioner recommend changes to the criteria to the Secretary of Finance every three years. The BIR's lists of Revenue Regulations from 2011 to 2026 show none since RR No. 17-2010 with large taxpayers in its subject, checked on 6 October 2026.

Which companies are automatic candidates?

Section 4.5 makes some companies candidates because of what they are, whatever their sales:

  • ·branches of a taxpayer already under the LTS;
  • ·"subsidiaries, affiliates and entities of conglomerates / group of companies" of a large taxpayer on the initial list;
  • ·the surviving company in a merger or consolidation involving a large taxpayer, and any corporation that takes over a large taxpayer's business in a spin-off;
  • ·SEC-registered corporations with authorized capitalization of at least P300 million, and multinational enterprises with authorized capitalization or assigned capital of at least P300 million;
  • ·publicly listed corporations, and universal, commercial and foreign banks;
  • ·taxpayers with authorized capitalization of at least P100 million in banking, insurance, telecommunications, utilities, petroleum, tobacco or alcohol, and corporations producing metallic minerals.

Which payment and size thresholds make a company a candidate?

Section 5 adds any taxpayer that meets one or more of the following. Most are measured on the preceding year.

Note the withholding line. It counts every type of withholding tax, including tax withheld on compensation, across the head office and all branches, so a large payroll counts toward it even when sales do not. That is one way a company can land on the LTS list with sales well under P1 billion.

  • ·net VAT paid or payable of at least P200,000 per quarter;
  • ·excise tax of at least P1 million a year;
  • ·income tax of at least P1 million a year;
  • ·withholding tax remitted, all types, of at least P1 million a year;
  • ·percentage tax of at least P200,000 per quarter;
  • ·documentary stamp tax of at least P1 million a year;
  • ·gross sales or receipts of at least P1 billion;
  • ·net worth of at least P300 million at year end;
  • ·gross purchases of at least P800 million;
  • ·a place on the SEC's published list of top corporate taxpayers.

How do you know whether your company is under the Large Taxpayers Service?

Check two things. Has the company received a written notice from the Commissioner classifying it as a Large Taxpayer, with no written notice of delisting since? And which BIR office is it registered with? LTS companies are registered with an office or division of the Large Taxpayers Service, not an ordinary Revenue District Office. No notice and an RDO registration means you are not under the LTS.

RMO No. 37-2024 names the LTS units that process classification requests alongside the RDOs: the LT Assistance Division, the Excise LT Regulatory Division, and the LT Divisions in Cebu and Davao. The office matters for e-invoicing. RMC No. 98-2026 says the application for a Permit to Issue e-invoices is filed with "the Revenue District Office (RDO)/Large Taxpayer (LT) Office where they are registered."

The ORUS lookup in the previous section reports the four EOPT classes. RMC No. 62-2024 does not say it shows LTS status, so do not read "Large" in ORUS as an answer to this question.

Can a company be Large under EOPT but not under the LTS?

Yes, and the reverse is possible too. The EOPT class turns on gross sales alone. LTS membership turns on a written notice, backed by criteria that reach well beyond sales. The two portal circulars reflect the split: RMC No. 53-2026 sent LTS companies to their "Large Taxpayers Office/Division," while RMC No. 109-2026 sends EOPT Large taxpayers to "their concerned Revenue District Office where they are registered."

Here is what each combination means for e-invoicing, as of 6 October 2026:

  • ·On both lists: covered twice, under categories 2 and 3 of RMC No. 98-2026.
  • ·Large under EOPT, not under the LTS: covered under category 3. The Permit to Issue application goes to your RDO.
  • ·Under the LTS, not Large under EOPT: covered under category 2, whatever your sales. The application goes to your LT office.
  • ·On neither list: not covered as a large taxpayer, and possibly covered anyway, through e-commerce or invoicing software.

What does your classification mean for the BIR e-invoicing deadline?

It decides which route into the mandate applies to you. RMC No. 98-2026, issued on 22 September 2026, lists five categories that must issue electronic invoices on or before 31 December 2026, Micro taxpayers excepted. Two of the five are the large-taxpayer lists. Two catch Small and Medium businesses for reasons unrelated to size. The fifth is open-ended.

  • ·E-commerce: taxpayers engaged in e-commerce or internet transactions, classified Small, Medium or Large. Micro is exempt.
  • ·LTS: taxpayers under the jurisdiction of the Large Taxpayers Service.
  • ·EOPT Large: taxpayers classified as Large Taxpayer under the EOPT Act and RR No. 8-2024.
  • ·Systems: taxpayers using CAS or CBA with accounting records (with electronic invoicing), and other invoicing software.
  • ·Commissioner's choice: other taxpayers as may be required by the Commissioner.

What if you are on neither large-taxpayer list?

You may still be covered. A Medium business that sells online falls under the e-commerce category, and one that uses CAS or CBA with accounting records (with electronic invoicing), or other invoicing software, falls under the systems category, whatever its size. Micro is the only class exempted outright. The pillar post on who is covered works through all five categories.

Coverage applies to the whole company. RMC No. 98-2026 says the head office and all branch offices must issue e-invoices "regardless of whether the covered activity is undertaken at a particular branch." If each branch invoices its own way, that is where the work concentrates.

Can the 31 December 2026 date still move?

Yes. It is the date in force on 6 October 2026, set by RR No. 26-2025 and restated by RMC No. 98-2026, and no later issuance moving it was found on the BIR's 2026 lists that day. Section 3 of RR No. 26-2025 says the Commissioner "may further extend the deadlines or compliance period on the transition period" as deemed necessary. Confirm the date with your RDO or LT office before you plan spending around it.

Issuing e-invoices and reporting sales data to the BIR are separate obligations. RMC No. 98-2026 says covered taxpayers must comply with electronic sales reporting "only upon the issuance by the Bureau of the implementing policies, guidelines, and procedures for such purpose."

What happens to your deadline if your classification changes?

Moving up starts a new clock; moving down does not stop the old one. RMC No. 98-2026, Section IV.16, gives a taxpayer reclassified upward, Medium to Large for example, a compliance period the BIR will set of not less than six months from the date of reclassification. A taxpayer reclassified downward, Large to Medium or delisted from the LTS, "shall continue to comply with the previously approved electronic invoicing requirement."

The same section treats enlisting in the LTS as a move to a higher category, so a company that receives an LTS notice gets the same minimum of six months from its reclassification.

One case the sources do not settle. The EOPT category covers taxpayers "classified as" Large. If your last return shows gross sales above P1 billion but ORUS still shows Medium, the record and the numbers disagree. RMO No. 37-2024 lets you request the move up through ORUS, approved automatically, and the six-month clock in RMC No. 98-2026 runs from reclassification. Whether you are inside the EOPT category before then is a question to put to your RDO in writing.

What else changes with your classification?

A few things beyond e-invoicing, which is why the class on the BIR's record is worth keeping accurate. The EOPT class sets lower penalties for the two smallest classes and, since 6 October 2026, access to the BIR's Taxpayer Portal for Large ones. LTS status carries its own filing rules under RR No. 17-2010.

Micro and Small: lower penalties

RR No. 6-2024 cuts several penalties for Micro and Small taxpayers. The civil penalty for late filing or payment is 10 percent of the amount due. Interest is half the Section 249 rate, which the regulation puts at 6 percent for these taxpayers. A missed information return costs P500 per failure, capped at P12,500 a calendar year, and the compromise penalty for non-fraud violations of Sections 113, 237 and 238, the invoicing provisions, is halved.

Large under EOPT: the Taxpayer Portal

RMC No. 109-2026, dated 6 October 2026, lets taxpayers classified as Large under EOPT enroll in the BIR's Taxpayer Portal, which shows registration information, the status of filed returns per tax type, tax payments, an account ledger per tax type, and system reminders. Help with enrollment comes from the RDO where the taxpayer is registered. LTS companies have had the portal since the pilot announced in RMC No. 53-2026 on 26 May 2026.

Under the LTS: filing rules

Under RR No. 17-2010, Large Taxpayers must file and pay through the BIR's Electronic Filing and Payment System, must put the withholding tax remittances and information returns of the head office and every branch into one consolidated return, and, if newly identified, must adopt an accredited computerized accounting system within six months of the written notice.

What should you check this week?

Four facts settle most of this: your EOPT class on the BIR's record, your actual gross sales net of VAT for the last two years, whether the company holds a written LTS notice, and which BIR office it is registered with. Put them side by side and match them to the five categories, in this order.

  1. Run the ORUS lookup for the head office and write down the class it shows.
  2. Take gross sales, net of VAT, from the last two income tax returns and note where each year falls against P3 million, P20 million and P1 billion.
  3. Ask whoever files your returns which BIR office the company is registered with, and whether a written Large Taxpayer notice is on file with no delisting notice after it.
  4. List every channel where you sell online and every system that produces an invoice, including any CAS or CBA.
  5. Match the results to the five categories in RMC No. 98-2026. If one applies, ask your RDO or LT office what the Permit to Issue application needs.
  6. If the ORUS class and your sales disagree, decide with your accountant whether to request reclassification, and ask your RDO in writing how it affects your deadline.
  7. Recheck the 31 December 2026 date with your RDO or LT office before committing money to it, since the Commissioner can extend it.

Common questions

Is a company with P1 billion in sales automatically under the Large Taxpayers Service?

No. Gross sales of P1 billion or more put it in the Large band of the EOPT classification and make it a candidate for the LTS under RR No. 17-2010. It comes under the LTS only when the Commissioner notifies it in writing. As of 6 October 2026, either status puts it in the BIR e-invoicing mandate.

Does each branch have its own taxpayer classification?

No. RMO No. 37-2024 says branches follow the classification of their head office, and RMC No. 98-2026 applies e-invoicing to the head office and all branches together.

Can a business ask the BIR to change its classification?

Yes, through its head office. A move up can be requested in ORUS, where it is approved automatically, or with a registration update form at the home RDO. A move down needs proof of gross sales for the last two years, and RMO No. 37-2024 sets a seven-working-day processing period. A move from Small to Micro follows the same route as a move up.

If sales fall below P1 billion, can a company stop issuing e-invoices?

No. RMC No. 98-2026 says a taxpayer reclassified to a lower category, including Large to Medium or delisting from the LTS, continues to comply with the e-invoicing requirement already approved for it.

Does the EOPT class depend on the whole family group's sales?

No. RR No. 8-2024 classifies each taxpayer on its own gross sales. Group membership matters for the LTS instead: RR No. 17-2010 makes subsidiaries, affiliates and group companies of a large taxpayer on the initial list automatic candidates.

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