How Employers Submit BIR Form 2316 to the BIR: DVD-R, USB, or eAFS

Employers submit BIR Form 2316 duplicates to the BIR as scanned PDF files on a DVD-R or USB storage device with a notarized certification, or by uploading them through the BIR’s eAFS (Electronic Audited Financial Statements) system — never as loose, unscanned paper. This rule comes from Revenue Regulations (RR) No. 2-2015, which introduced the scanned-copy-on-DVD-R process, and RR No. 16-2021 (clarified by Revenue Memorandum Circular No. 117-2021), which added eAFS and USB as alternative modes without discontinuing DVD-R.

This guide covers the submission mechanics only — not when BIR Form 2316 is due. For the January 31 (employee copy) and February 28 (BIR copy) dates themselves, see BIR Form 2316 Deadlines. And because this is a narrower, employer-specific obligation under withholding-tax regulations rather than the general ITR-attachment process, see the section below on how it differs from the BIR eAFS System for financial-statement attachments.

How do employers actually submit BIR Form 2316 copies to the BIR? #

An employer with employees qualified for substituted filing keeps the signed original BIR Form 2316 with the employee, scans the duplicate copy, and delivers that scanned file to the BIR through one of a short list of BIR-sanctioned modes — DVD-R, USB, or the eAFS portal — rather than hand-carrying a stack of paper to the Revenue District Office (RDO). The underlying obligation to submit — the February 28 deadline and the requirement to attach a certified list of qualified employees — comes from RR No. 11-2013 amending RR No. 2-98. What has changed repeatedly since then is how that duplicate physically reaches the BIR.

What did RR No. 2-2015 require before eAFS existed? #

RR No. 2-2015, which amended RR No. 2-2006 and RR No. 11-2013, let employers replace loose hard copies of BIR Form 2316 (and BIR Form 2307) with scanned PDF files stored on a DVD-R, accompanied by a notarized certification that the soft copies are complete and exact reproductions of the signed originals. The filenames had to follow a fixed convention — built from identifying details such as the employee’s name, Taxpayer Identification Number (TIN), and the taxable period covered — organized alphabetically rather than dumped onto the disc in random order. A secondary source summarizing the regulation’s operative requirement puts it this way:

“The DVD-R shall be submitted together with a notarized Certification duly signed by the authorized representative of the taxpayer certifying that the soft copies of the said BIR forms contained in the DVD-R are the complete and exact copies of the original thereof.”

That line is from Roque Law’s 2015 tax alert describing RR No. 2-2015’s text; it is a secondary paraphrase of the regulation, not a direct lift from the Official Gazette copy, since the primary regulation text could not be fetched directly for this article. The rule applied first to taxpayers under the BIR’s Large Taxpayers Service (LTS), with non-LTS, RDO-registered employers given the option to use scanned DVD-R submission instead of hard copies — but once a non-LTS employer opted in, RR No. 2-2015 did not let it revert to hard-copy submission in a later period.

What changed under RR No. 16-2021 and RMC No. 117-2021? #

RR No. 16-2021, issued June 11, 2021 and clarified by RMC No. 117-2021 that November, kept the DVD-R-plus-notarized-certification process alive but added the eAFS system — and, as a practical substitute where DVD-R drives are hard to find, a USB memory stick or similar device — as additional, equally valid submission facilities for BIR Forms 2307 and 2316. It did not retire DVD-R outright; it broadened the menu of accepted modes.

The regulation also set a firm operating rule that trips up employers who assume they can pick and choose per batch:

• An employer may use any one of the available modes — DVD-R, USB, or eAFS — for a given submission period.
• An employer may not mix modes within that same period: submitting part of its workforce’s certificates on DVD-R and the rest through eAFS in the same February 28 filing is not a compliant approach under RR No. 16-2021.
• Whichever mode is chosen governs which companion rules apply: DVD-R or USB submissions still follow RR No. 2-2015’s format, naming, and notarized-certification requirements, while eAFS submissions follow the eAFS-specific circulars (RMC Nos. 49-2020, 82-2020, and 44-2021) on file format and upload mechanics.

Is DVD-R submission still required or allowed today? #

DVD-R has not been legally discontinued as a submission mode, but it has become the least practical option as physical optical-disc drives disappear from modern laptops and desktops — several practitioner guides for the current filing season describe DVD-R as no longer the preferred channel, with USB and eAFS taking its place in practice. Nothing in RR No. 16-2021 or RMC No. 117-2021 revokes DVD-R as a legally valid mode; the shift away from it is a matter of hardware availability and BIR office preference rather than a formal repeal. Employers should confirm with their registering RDO, or check the current eAFS guidance at the BIR’s portal, before assuming any one mode is mandatory for a given filing season — the mode itself is a choice, but it must be a single, deliberate choice communicated consistently for that period.

Who must submit electronically, and who can still use hard copies? #

The scanned-copy requirement under RR No. 2-2015 was built around Large Taxpayer (LTS) status rather than a simple employee headcount: employers registered with the BIR’s Large Taxpayers Service must use a scanned mode (DVD-R, USB, or eAFS), while non-LTS employers registered under an ordinary RDO have historically had more flexibility, including the option to submit hard copies if they have not opted into scanned submission. In practice, most mid-size and large payroll operations now submit electronically because:

• eAFS avoids a physical trip to the RDO and gives an immediate confirmation receipt as proof of filing.
• Hard-copy submission for a workforce of any meaningful size means collating, binding, and hand-delivering a thick stack of signed certificates — a process RDO staff increasingly discourage even where it remains technically available.
• Once an employer opts into scanned submission in one filing period, it cannot fall back to hard copies for a later period.

Worked example: a 40-employee company’s February 28 submission #

A domestic company with 40 rank-and-file and managerial employees finishes its December payroll in early January 2026, issues each employee’s signed BIR Form 2316 by January 31, 2026, and then has about four weeks to prepare its BIR-facing submission before the February 28, 2026 deadline. Assume the company is not under the Large Taxpayers Service and has previously submitted on DVD-R.

Switching to eAFS this year rather than repeating last year’s DVD-R process is a legitimate choice under RR No. 16-2021 — the company simply cannot submit some of the 40 certificates one way and the rest the other way within the same February 28 filing.

How does this differ from the BIR eAFS System post on financial-statement attachments? #

This post is about the employer’s February 28 obligation to get signed BIR Form 2316 duplicates to the BIR for employees — a withholding-tax compliance step under RR No. 11-2013 and RR No. 2-98 — while the eAFS System guide covers the broader role eAFS plays as the standard channel for Audited Financial Statements and other Income Tax Return attachments, on a deadline tied to the Annual Income Tax Return (generally 15 calendar days after the statutory ITR deadline). The two overlap only at the point where eAFS happens to be one of the accepted upload channels for BIR Form 2316 as well — the deadline that actually governs an employer’s BIR Form 2316 duplicate submission stays February 28 regardless of which mode is used, it does not shift to the 15-day AITR-attachment window. For the two underlying dates themselves — January 31 for employees, February 28 for the BIR — see BIR Form 2316 Deadlines, a companion post in this series.

Frequently Asked Questions #

How do employers submit BIR Form 2316 to the BIR? #

Employers scan the signed duplicate copies of BIR Form 2316, save them as PDF files following the BIR’s naming convention, and submit them either on a DVD-R or USB storage device together with a notarized certification, or by uploading them through the BIR’s eAFS (Electronic Audited Financial Statements) system. Loose, unscanned paper copies are not an accepted submission format for taxpayers covered by these rules.

Is a DVD-R still required to submit BIR Form 2316? #

No. Revenue Regulations No. 16-2021, clarified by Revenue Memorandum Circular No. 117-2021, kept the DVD-R and notarized-certification process from Revenue Regulations No. 2-2015 available but added the eAFS system and USB storage devices as alternative modes. Employers choose one mode per submission period rather than being locked into DVD-R.

Can an employer submit BIR Form 2316 using both DVD-R and eAFS in the same year? #

No. Under Revenue Regulations No. 16-2021, a taxpayer may use any one available mode or facility for a given submission period but is not allowed to mix modes — for example, submitting some employees’ certificates on DVD-R and others through eAFS in the same February 28 filing is not a compliant approach.

Can an employer still submit BIR Form 2316 in hard copy? #

Generally no, once an employer is within the scope of Revenue Regulations No. 2-2015’s scanned-copy requirement — chiefly Large Taxpayers. Non-Large Taxpayers registered with a Revenue District Office may have more flexibility, but once a taxpayer opts into scanned submission, it cannot revert to hard-copy submission for later periods.

What is the deadline for submitting BIR Form 2316 to the BIR? #

The employer’s duplicate-copy submission to the BIR, covering employees qualified for substituted filing, is due not later than February 28 following the close of the calendar year under Revenue Regulations No. 11-2013 amending RR No. 2-98. That date governs regardless of which submission mode — DVD-R, USB, or eAFS — the employer uses.

What happens if the BIR Form 2316 files are misnamed or in the wrong format? #

The BIR’s prescribed modes require PDF files following a specific naming convention that embeds identifying details such as the employee’s name, TIN, and taxable period. Files that do not follow the required format or naming convention risk being treated as an invalid or incomplete submission, which carries the same exposure as not submitting at all.

Summary #

Submitting BIR Form 2316 to the BIR is no longer a matter of handing the RDO a bundle of signed paper. Since RR No. 2-2015, employers scan the signed duplicates into PDF files and submit them on DVD-R (or, more practically today, USB) with a notarized certification; since RR No. 16-2021 and RMC No. 117-2021, the eAFS system is an equally valid alternative mode. The one firm operating rule across all of it: pick a single mode for each February 28 filing period and stay with it — DVD-R, USB, and eAFS are not meant to be mixed within the same submission. The underlying deadlines for who gets a certificate and when are covered separately in BIR Form 2316 Deadlines, and the broader electronic-attachment system that also happens to accept BIR Form 2316 uploads is covered in the BIR eAFS System guide.