Does BIR Excel Uploader Still List SRS? Why the Semestral List of Regular Suppliers No Longer Exists

A DAT file format doesn’t stop existing in a converter’s dropdown menu just because the BIR stopped accepting it. BIR Excel Uploader’s own format page still names SRS — the Semestral List of Regular Suppliers — alongside RELIEF, Alphalist, QAP, MAP, and SAWT as a conversion option, but the BIR terminated the SRS filing requirement back in 2019. A filer following an old template or an outdated “supported formats” list can waste hours building a report the BIR no longer has anywhere to receive.

This post explains what SRS was, why the BIR dropped it, and which current filing — QAP — actually carries that data today. It’s part of the same due-diligence check covered in Best BIR Excel Uploader Alternative for QAP Filing and Who Is a BIR Top Withholding Agent?.

What was the Semestral List of Regular Suppliers? #

SRS was a twice-a-year DAT file listing every “regular supplier” a Top Withholding Agent bought from and withheld 1% or 2% creditable withholding tax from, due every July 31 and January 31. Revenue Regulations (RR) No. 14-2008 required the BIR’s Top 20,000 private corporations — later folded into the broader Top Withholding Agent (TWA) classification — to submit the list to the Large Taxpayers Assistance Division or the Revenue District Office with jurisdiction over the withholding agent.

The “regular supplier” concept SRS reported on is the same one that later governed — and still governs — when a TWA issues BIR Form 2307 in the first place. As carried forward into Section 2.57.2 of RR No. 2-98, as amended by RR No. 11-2018:

“Regular suppliers” refer to suppliers who are engaged in business or exercise of profession/calling with whom the taxpayer-buyer has transacted at least six (6) transactions, regardless of amount per transaction, either in the previous year or current year. As a general rule, this term does not include a casual purchase of goods/services that is purchase made from a non-regular supplier and oftentimes involving a single purchase. However, a single purchase which involves Ten thousand pesos (₱10,000.00) or more shall be subject to withholding tax under this subsection.

SRS was, in effect, a semestral roll call of exactly these suppliers — a report layered on top of withholding data the BIR already collected elsewhere. See The “Regular Supplier” Rule for BIR Form 2307 for how that same six-transaction test still applies today, independently of the now-defunct SRS report.

Why did the BIR terminate SRS in 2019? #

The BIR withdrew the SRS requirement under Revenue Memorandum Circular (RMC) No. 122-2019, stating that the information it captured duplicated what the Quarterly Alphalist of Payees (QAP) and the annual BIR Form 1604-E alphalist already reported. By 2019, every TWA was already filing QAP each quarter with BIR Form 1601-EQ or 1601-FQ, listing the same regular suppliers and the same withholding amounts SRS asked for twice a year — just on a more frequent, more granular schedule.

Practitioner summaries of the circular (Grant Thornton’s tax alert among them) note three practical reasons the BIR gave for dropping SRS entirely rather than just simplifying it:

• The data was already fully captured in QAP and the annual BIR Form 1604-E alphalist, making SRS a duplicate report of the same transactions.
• The original SRS population — the Top 20,000 private corporations — had already been superseded by RR No. 11-2018’s broader Top Withholding Agent classification, which doesn’t map cleanly onto a “Top 20,000” list anymore.
• Dropping it aligned with the BIR’s ease-of-doing-business push to cut redundant reportorial filings rather than add new ones.

Why does BIR Excel Uploader’s site still list SRS as a format? #

BIR Excel Uploader’s excel-file-to-bir-dat-format page lists SRS (Semestral List of Regular Suppliers) as one of the formats it converts to, alongside RELIEF, Alphalist, QAP, MAP, and SAWT — a listing that appears to predate the 2019 termination and doesn’t flag that SRS is no longer an active BIR filing. That’s not necessarily a sign the tool is broken; a standalone Excel-to-DAT converter’s format list is only as current as its last update, and a discontinued government report is an easy one to miss retiring from a features page.

The practical risk isn’t the converter itself — it’s a filer who sees “SRS” listed as a supported format and assumes it must still be something the BIR expects, then spends time building a report with no active submission channel behind it.

Worked example: a bookkeeper following an old checklist #

A small accounting firm’s year-end compliance checklist, last revised in 2018, still lists “SRS — due January 31” as a task for its Top Withholding Agent clients — a line nobody had reason to question until a new hire actually went looking for where to submit it.

Mariposa Bookkeeping Services handles compliance for a mid-sized trading company classified as a Top Withholding Agent. Every January, the firm’s junior bookkeeper works through a standing checklist inherited from a predecessor — and one line item reads “Prepare and submit SRS DAT file, due Jan 31.” Following the checklist, she opens a converter, selects the SRS format, and starts mapping the client’s regular-supplier ledger into it — only to find no current BIR guidance on where an SRS file is actually filed anymore. A quick check against RMC No. 122-2019 confirms the requirement was withdrawn in 2019; the client’s regular-supplier withholding data has been going out through QAP every quarter since, attached to BIR Form 1601-EQ. The checklist item gets deleted, and the hour she would have spent formatting a defunct report goes into confirming the current quarter’s QAP DAT file instead, generated through BIR Online Tools’ QAP module.

What should you file instead of SRS? #

Today, the same regular-supplier withholding data SRS used to report semestrally is already covered by two filings you’re likely preparing anyway: QAP every quarter and the annual BIR Form 1604-E alphalist once a year. There is no separate semestral report to reconstruct or catch up on.

If your QAP and BIR Form 1604-E filings are current, there’s nothing SRS-shaped left to file. See What Is QAP? for how the quarterly listing works if it’s a newer part of your compliance routine than SRS was.

Frequently asked questions #

What was the Semestral List of Regular Suppliers (SRS)? #

SRS was a twice-yearly DAT file that the BIR’s Top 20,000 private corporations (and later Top Withholding Agents) submitted, listing regular suppliers of goods and services subjected to 1% and 2% creditable withholding tax, due every July 31 and January 31 under Revenue Regulations No. 14-2008.

Is SRS still required by the BIR? #

No. The BIR terminated the SRS submission requirement in 2019 under Revenue Memorandum Circular (RMC) No. 122-2019, because the same withholding-agent-to-payee data is already captured in the Quarterly Alphalist of Payees (QAP) and the annual BIR Form 1604-E alphalist.

Why did BIR Excel Uploader’s site still mention SRS as a format? #

Its excel-file-to-bir-dat-format page lists SRS (Semestral List of Regular Suppliers) alongside RELIEF, Alphalist, QAP, MAP, and SAWT as a conversion option. The tool’s original SRS conversion feature predates the 2019 termination, and the listing does not appear to have been updated to reflect that the filing itself no longer exists.

What replaced SRS after 2019? #

The Quarterly Alphalist of Payees (QAP), filed with BIR Form 1601-EQ or 1601-FQ every quarter, and the annual alphalist attached to BIR Form 1604-E. Both already list the same regular-supplier withholding data that SRS used to report separately every semester.

How do I know if I still need to prepare an SRS-format DAT file? #

You don’t. If your accountant, a template, or a downloaded tool is asking for an SRS file, that request is out of date — confirm with your current QAP and BIR Form 1604-E filings instead, since SRS was withdrawn as a BIR reportorial requirement in 2019.

Does the BIR’s Validation Module still accept SRS-format DAT files? #

The BIR’s published guidance since RMC No. 122-2019 no longer lists SRS among current reportorial requirements, so a file built in that discontinued format has no active filing channel to be submitted to, regardless of whether an offline converter can still technically generate it.

Summary #

SRS (Semestral List of Regular Suppliers) was withdrawn as a BIR filing requirement in 2019 under RMC No. 122-2019, folded into the QAP and annual BIR Form 1604-E alphalist filings that already capture the same regular-supplier withholding data on a more frequent schedule. A supported-formats list that still names SRS — as BIR Excel Uploader’s does — reflects the tool’s older feature set, not a live BIR requirement, so treat any checklist or template still asking for an SRS file as outdated. Confirm your regular-supplier data is flowing through your current QAP filings instead, and use BIR Online Tools’ QAP module to generate and validate that file each quarter.