BIR Compromise Penalty for Not Presenting BIR Form 1900 or 1905 During a Tax Mapping Visit

Failing to present BIR Form 1900 or BIR Form 1905 — the application authorizing registered sales books or a permit to use loose-leaf books of accounts — carries a flat ₱1,000 compromise penalty under RMO No. 7-2015’s schedule, tied to NIRC Section 236/275. This is a distinct, smaller finding from the ₱1,000-per-unit CRM/POS sticker penalty that sits right next to it in the same table — the two are easy to conflate but price different things.

For the broader registration and bookkeeping picture this fits into, see BIR Compromise Penalty Table for Registration, Receipts, and Invoicing Violations and BIR Books of Accounts.

What does the BIR charge for missing this application form? #

RMO No. 7-2015’s Annex A prices this exact violation at ₱1,000, distinct from the CRM/POS/CAS sticker requirement it appears next to in the schedule.

The underlying criminal exposure for both is the same: a fine of not more than ₱1,000 or imprisonment of not more than 6 months, or both, under Section 275 — the compromise is the amount a revenue officer offers in place of pursuing that criminal track.

What do BIR Form 1900 and BIR Form 1905 actually authorize? #

BIR Form 1900 is the Application for Authority to Use Computerized Accounting System (CAS) or Components thereof, including Loose-Leaf Books of Accounts and/or Invoicing/Receipting Software — the form a business files before it can rely on loose-leaf or computerized bookkeeping instead of manual, pre-printed ledgers. BIR Form 1905 is the general Application for Registration Information Update/Correction/Cancellation, which also covers renewing or updating a permit to use loose-leaf books — see How to Update Your Registration Information or Transfer RDO for the form’s broader uses beyond bookkeeping permits.

When a tax mapping officer asks for this: a business using loose-leaf or CAS-based books is expected to have BIR’s approved copy of the relevant application on hand, alongside the books themselves, since the permit is what makes the loose-leaf or computerized format legitimate in the first place — see BIR Books of Accounts for how the three bookkeeping formats and their registration requirements differ.

Worked example: a loose-leaf filer without the approved permit on hand #

A mid-sized retailer keeps its books on a loose-leaf system, printed and bound monthly from its accounting software. During a tax mapping visit, the officer asks to see the BIR-approved Permit to Use Loose-Leaf Books of Accounts; the retailer’s staff can locate the printed books but not the original approved BIR Form 1900 application. This is the ₱1,000 flat compromise under Section 236/275 — separate from, and smaller than, a finding that the books themselves weren’t properly registered or weren’t available at all.

Frequently asked questions #

How much is the compromise penalty for not presenting BIR Form 1900 or 1905? #

₱1,000, under RMO No. 7-2015’s Annex A/C, for failure to present the application form (BIR Form 1900 and 1905) authorizing the use of registered sales books or a permit to use loose-leaf sales books, tied to NIRC Section 236/275.

What is BIR Form 1900 for? #

BIR Form 1900 is the Application for Authority to Use Computerized Accounting System (CAS) or Components thereof, including Loose-Leaf Books of Accounts and/or Invoicing/Receipting Software — it’s the form a business files to get BIR authority before relying on a loose-leaf or computerized bookkeeping setup.

What is BIR Form 1905 for? #

BIR Form 1905 is the Application for Registration Information Update/Correction/Cancellation, used for a range of registration changes including RDO transfer, updating registered activities, and — relevant here — renewing or updating the permit to use loose-leaf books of accounts.

Is this the same as the ₱1,000-per-unit CRM/POS sticker penalty? #

No, though the two appear side by side in RMO No. 7-2015’s schedule. Failure to attach the authorized CRM/POS/CAS sticker or decal is priced at ₱1,000 per unit (per machine). Failure to present the BIR Form 1900/1905 application form itself is a flat ₱1,000, not scaled per machine or per book.

Does every business need to keep this application form on hand? #

Only businesses using registered sales books, loose-leaf books of accounts, or a permit-based bookkeeping format need to have the corresponding BIR Form 1900 or 1905 approval on hand — a business using simple manual books registered once at the RDO doesn’t have this specific application-form requirement, though it still needs its Certificate of Registration and other standard documents available.

Summary #

Not being able to produce the BIR-approved application authorizing registered or loose-leaf sales books is its own ₱1,000 compromise finding under RMO No. 7-2015 — a small but distinct item from the per-unit CRM/POS sticker penalty next to it in the schedule. Any business using loose-leaf or computerized books should keep the approved BIR Form 1900 (or the relevant Form 1905 update) on file with the books themselves, ready to produce alongside them during a tax mapping visit.