BIR Form 1601-C vs 1604-C: What's the Difference and Do You Need to File Both?

BIR Form 1601-C and BIR Form 1604-C are not competing options — every employer that withholds tax on compensation must file both. BIR Form 1601-C is the monthly return that actually remits withheld compensation tax to the BIR, twelve times a year. BIR Form 1604-C is the annual information return, filed once, that reconciles the full year’s withholding per employee and moves no additional money on its own.

Why do employers confuse BIR Form 1601-C and BIR Form 1604-C? #

Both forms report income tax withheld on compensation, both reference the same underlying payroll data, and both are filed with the BIR by the same withholding agent — which is exactly why new bookkeepers assume one might substitute for the other. It doesn’t: one remits tax on a recurring monthly cycle, and the other reports and reconciles that same withholding once a year.

What does each form actually do? #

The clearest way to separate the two forms is by what happens when you file each one: does money change hands, or does the BIR simply receive a report? BIR Form 1601-C carries an actual tax payment every month it’s filed; BIR Form 1604-C carries no payment field at all — it is purely an information return.

The official BIR eFPS guidelines for Form 1604-C describe who carries the filing obligation in the same terms as any other withholding return — but the form’s own title is the operative distinction. The predecessor combined form’s eFPS “Who Shall File” instructions read:

“The return shall be filed by every employer or withholding agent/payor who is either an individual, estate, trust, partnership, corporation, government agency and instrumentality, government owned and controlled corporation, local government unit and other juridical entity required to deduct and withhold taxes on compensation paid to employees.”

— BIR Form No. 1604-C, “Who Shall File,” Guidelines and Instructions, eFPS (Electronic Filing and Payment System), Bureau of Internal Revenue (efps.bir.gov.ph)

Notice what that sentence does not say: it never mentions a payment amount, a tax due, or a bank remittance — because BIR Form 1604-C’s official title is the Annual Information Return, not a remittance return. BIR Form 1601-C’s official title, by contrast, is the Monthly Remittance Return — the word “remittance” is in the form’s own name for a reason. That naming difference, set by Revenue Regulations No. 2-98, as amended by Revenue Regulations No. 11-2018, which split the old combined 1604-CF into separate 1604-C (compensation) and 1604-F (final withholding) returns, is the legal basis for treating the two forms as sequential, not alternative, obligations.

A worked example: a 5-employee business’s full-year cycle #

A small accounting firm with five rank-and-file employees files BIR Form 1601-C every month to remit that month’s withholding, then closes the year with a single BIR Form 1604-C that reconciles all twelve remittances against what each employee’s records show. The two filings never report the same number twice — one is cash moving, the other is a year-end count.

Meridian Bookkeeping Services has five rank-and-file employees on payroll, none of them Minimum Wage Earners. For June 2026, its payroll run withholds the following compensation tax under the graduated withholding table:

By July 10, 2026 (the non-eFPS deadline), Meridian files BIR Form 1601-C for June and remits the full ₱15,500 through any Authorized Agent Bank under the EOPT Act’s file-anywhere rule. It repeats this cycle — a new 1601-C, a new remittance — every month of 2026, including a year-end adjustment run through the December filing to true up each employee’s annual tax due against what was actually withheld per pay period.

Across all twelve monthly 1601-C filings for calendar year 2026, Meridian’s cumulative remittance totals ₱189,840. By January 31, 2027, Meridian:

1. Issues each of its five employees a BIR Form 2316 showing their full-year compensation and tax withheld.
2. Files BIR Form 1604-C together with the Alphalist of Employees, listing all five employees (none flagged as MWE), whose individual annual tax-withheld columns sum to ₱189,840 — the same figure already remitted across the twelve monthly filings.
3. Pays nothing additional with the 1604-C itself, because the form has no remittance field — the tax was already in the BIR’s hands months earlier.

If Meridian’s alphalist total came out to, say, ₱187,200 instead — ₱2,640 short of the remitted amount — that gap would flag for review rather than resolve itself, since the 1604-C has no mechanism to pay the difference; any shortfall has to trace back to a correction in the underlying monthly 1601-C figures.

What happens if the totals don’t reconcile? #

A withholding agent that files every monthly BIR Form 1601-C on time can still get flagged at year-end if the BIR Form 1604-C alphalist doesn’t add up to the same cumulative figure. The BIR increasingly treats the annual information return as a cross-check against the year’s remittances, not a formality — a mismatch is one of the more common triggers for a request for explanation or a closer look at payroll withholding.

Revenue Memorandum Circular No. 55-2026 (issued May 26, 2026) reiterated to withholding agents that submitting the Alphabetical List of Employees/Payees alongside their withholding tax returns is a mandatory obligation distinct from remitting the tax itself, and that the BIR uses alphalist data for data-matching and cross-checking against amounts already remitted. A late or missing BIR Form 1604-C or alphalist is treated as a failure to file a required information return under Section 250 of the NIRC — a P1,000 penalty per failure, capped at P25,000 per calendar year — separate from any surcharge or interest that would apply to a late or short 1601-C remittance.

How BIR Form 1604-C connects to the Alphalist of Employees and BIR Form 2316 #

BIR Form 1604-C never stands alone — it is filed together with the Alphalist of Employees, and its per-employee figures are meant to match what each employee already received on their own BIR Form 2316. Treating all three as one connected year-end package, rather than three separate errands, is what keeps the reconciliation clean.

For the full mechanics of the annual alphalist — including how BIR Form 1604-C compares to BIR Form 1604-E and BIR Form 1604-F — see BIR Annual Alphalist (1604-C, 1604-E, 1604-F). For the monthly remittance side of this same withholding, see What Is BIR Form 1601-C and How Do You File Monthly Withholding Tax on Compensation?. And for the specific reconciliation errors that show up most often when the alphalist and the twelve 1601-C filings don’t match, see Common 1604-C Alphalist of Employees Errors.

Frequently asked questions #

Do I need to file both BIR Form 1601-C and BIR Form 1604-C? #

Yes. BIR Form 1601-C and BIR Form 1604-C are not alternatives to each other — every employer that withholds tax on employee compensation must file BIR Form 1601-C monthly, twelve times a year, to remit the tax withheld, and BIR Form 1604-C once a year to report and reconcile the full year’s withholding per employee, supported by the Alphalist of Employees.

What is the difference between BIR Form 1601-C and BIR Form 1604-C? #

BIR Form 1601-C is the Monthly Remittance Return of Income Taxes Withheld on Compensation — it moves money from the employer to the BIR. BIR Form 1604-C is the Annual Information Return of Income Taxes Withheld on Compensation — it reports and reconciles what was already remitted through the year’s twelve 1601-C filings and does not remit any tax on its own.

Does filing BIR Form 1604-C require an additional tax payment? #

No. BIR Form 1604-C is an information return, not a remittance return — it has no payment or tax-due section. The tax itself was already paid through the twelve monthly BIR Form 1601-C filings (and any year-end adjustment); BIR Form 1604-C simply reports and reconciles those figures per employee, alongside the Alphalist of Employees.

What happens if my BIR Form 1604-C totals don’t match my BIR Form 1601-C remittances? #

A mismatch between the cumulative total on BIR Form 1604-C and the sum of the year’s BIR Form 1601-C remittances is a common BIR data-matching flag. It can trigger a request for explanation, a compromise penalty, or a closer audit of payroll withholding, since both returns are meant to describe the same withholding activity from two different angles.

When is BIR Form 1604-C due, and is that different from BIR Form 1601-C’s deadline? #

BIR Form 1604-C, together with the Alphalist of Employees, is due on or before January 31 of the year following the taxable year it covers. BIR Form 1601-C has a different, recurring deadline — generally the 10th day of the month following the month of withholding for non-eFPS filers, with staggered dates for eFPS filers — because it is filed monthly, not once a year.

Is BIR Form 1604-C the same thing as the Alphalist of Employees? #

No, though the two are filed together. BIR Form 1604-C is the return itself — the Annual Information Return of Income Taxes Withheld on Compensation. The Alphalist of Employees is the supporting schedule attached to it, listing each employee by name and TIN with their annual compensation and tax withheld, separating Minimum Wage Earners from non-MWE employees.

Summary #

BIR Form 1601-C and BIR Form 1604-C describe the same withholding activity from two different angles, and neither one replaces the other. BIR Form 1601-C is filed monthly and actually remits withheld compensation tax to the BIR; BIR Form 1604-C is filed once a year, alongside the Alphalist of Employees, to report and reconcile that same withholding per employee, and carries no payment of its own. A business that files twelve accurate 1601-C returns still owes a reconciled, on-time 1604-C by January 31 — skipping it, or letting the two sets of totals drift apart, is a documented BIR data-matching flag and a Section 250 penalty exposure in its own right.