BIR Compromise Penalty for Incomplete CRM/POS Tape Receipt Information and the Summary List of Machines Sold

Revenue Regulations No. 11-2004, Section 11, requires every CRM/POS distributor, dealer, or vendor to submit a quarterly Summary List of Machines Sold to the appropriate BIR office within 15 days of the quarter’s end — and incomplete tape-receipt information from the machines themselves is a related, separate finding. Neither carries a stated peso figure in RMO No. 7-2015’s published schedule, but the general NIRC Section 250 information-return compromise is the most defensible reference point for a missed submission.

This is part of the CRM/POS compliance cluster on this site — see BIR Compromise Penalties for CRM and POS Compliance Failures for the related machine-level requirements.

What does the Summary List of Machines Sold actually require? #

Section 11 of Revenue Regulations No. 11-2004 requires machine distributors, dealers, and vendors to electronically report every CRM/POS machine sold, within 15 days of each taxable quarter’s end. The regulation’s own text:

Sec 11, RR No. 11-2004 — “Incomplete information in the tape receipts. (Revenue Regulations 11-2004. Section 11 Summary List of Machines Sold — All machines distributor/dealer/vendor shall submit electronically (e-mail or web) to the LTAD 1 or II/LTDO (for Large Taxpayers) or to the RDO concerned (for Regular taxpayers), a Summary List of Machines Sold (Annex C), within fifteen (15) days from the end of each taxable quarter. The Summary List shall provide the following information: a) Machine accreditation-registration number; b) BIR Issued Provisional Permit Number; c) Brand and Model of the machine; d) Date of sale; e) Date of registration.)”

This is a seller-side obligation — the distributor, dealer, or vendor files it, not the business that bought and uses the machine. It exists so the BIR can cross-check machines actually sold against what buyers separately register.

What counts as incomplete tape receipt information? #

A compliant CRM/POS tape receipt needs the sale amount to print automatically at the time of the transaction, on both the audit tape and the customer’s itemized, consecutively numbered receipt tape — the same two-roller mechanics covered in BIR Compromise Penalties for CRM and POS Compliance Failures. Incomplete information generally means a required field — the amount, the date, or the sequential numbering — is missing, blank, or doesn’t print correctly on one or both tapes.

What compromise amount applies to a missed submission? #

Neither the Summary List filing nor the incomplete-tape-information item carries a stated peso figure in RMO No. 7-2015’s published schedule — but NIRC Section 250’s general information-return compromise is the closest, most defensible reference point, since a Summary List of Machines Sold is exactly the periodic report/schedule Section 250 describes.

Frequently asked questions #

What is the Summary List of Machines Sold? #

It’s a quarterly report Revenue Regulations No. 11-2004, Section 11, requires every CRM/POS machine distributor, dealer, or vendor to submit electronically to the appropriate BIR office within 15 days from the end of each taxable quarter, listing every machine sold with its accreditation-registration number, provisional permit number, brand, model, and dates of sale and registration.

Who has to submit this report — the machine buyer or the seller? #

The distributor, dealer, or vendor selling the CRM/POS machine — not the business buying and using it. This is a seller-side reporting obligation meant to give the BIR visibility into which machines have been sold to which taxpayers, cross-checked against each buyer’s own machine registration.

What compromise penalty applies to a missed or incomplete submission? #

RMO No. 7-2015’s Annex C lists incomplete tape-receipt information and the Summary List requirement without a stated peso figure for these specific items, but NIRC Section 250’s general information-return compromise — ₱1,000 for each information return, schedule, or report not made, filed, or submitted, capped at ₱25,000 per calendar year — is the most defensible reference point, since a Summary List of Machines Sold is exactly the kind of periodic report Section 250 describes.

What information must appear on a CRM/POS tape receipt? #

A compliant tape receipt needs the transaction amount automatically printed at the time of sale, consistent with the two-roller requirement under RR No. 10-99 — incomplete tape information generally means required fields (like the sale amount, date, or sequential numbering) are missing or don’t print correctly on the customer or audit tape.

Is this the buyer’s responsibility to check? #

A buyer registering a new CRM/POS machine should confirm the seller is a properly accredited distributor/dealer/vendor, since that accreditation status is part of what makes the machine’s own registration valid — but the Summary List submission itself is the seller’s filing obligation, not the buyer’s.

Summary #

Machine sellers, not buyers, carry the quarterly Summary List of Machines Sold obligation under RR No. 11-2004 — a 15-day-after-quarter-end filing that RMO No. 7-2015 doesn’t price with its own peso figure. The general Section 250 information-return compromise, already used elsewhere on this site for SLSP and other periodic filings, is the most reasonable reference point at ₱1,000 per document, capped at ₱25,000 per year, until a more specific figure is confirmed with the examining office.