Can a small business that isn't mandated into eFPS still use it?

Generally yes, through BIR eFPS's own online enrollment process, which has historically accommodated non-mandated taxpayers opting in alongside the categories Revenue Regulations No. 9-2001 and its amendments make mandatory. Approval and current practice can vary, so confirm with your RDO before assuming enrollment will be processed automatically.

Why would a non-mandated taxpayer want to enroll in eFPS voluntarily?

Common reasons include wanting a single online channel for both filing and payment instead of eBIRForms' separate filing-then-pay-through-a-channel workflow, preparing for an eventual mandatory category (such as nearing the Top Withholding Agent threshold), or simply preferring eFPS's online payment integration with enrolled banks.

What's the difference between eFPS and eBIRForms for a non-mandated taxpayer?

eBIRForms is the standard electronic filing option for taxpayers not required to use eFPS — it generates and submits the return electronically, with payment made separately through a bank, AAB, or other BIR-accredited channel. eFPS integrates filing and online payment into one system but requires enrollment and, for some return types, has historically required an enrolled payment bank.

Can a taxpayer who voluntarily enrolled in eFPS switch back to eBIRForms later?

Not as a simple, routine decision. Once enrolled in eFPS, a taxpayer is generally expected to continue filing through it, and reverting typically requires a request to the BIR rather than simply choosing to file through eBIRForms the next quarter. Treat voluntary enrollment as a longer-term commitment, not a trial you can casually exit.

Does voluntary eFPS enrollment change which forms or deadlines apply?

No. The tax forms and statutory filing deadlines that apply to a taxpayer are set by the tax type and taxpayer classification, not by the filing channel. eFPS and eBIRForms are both electronic filing channels for the same underlying returns — enrolling in eFPS voluntarily doesn't change what you owe or when it's due, only how you file and pay it.

Can a Non-Mandated Taxpayer Voluntarily Enroll in BIR eFPS?

A taxpayer who doesn’t fall into any of the categories the BIR mandates into eFPS can generally still enroll voluntarily, through the system’s own online registration — the mandatory list in Revenue Regulations (RR) No. 9-2001 and its many amendments has never been the only door into eFPS. The regulations have historically carved out a voluntary track alongside the mandatory one, dating back to the system’s earliest rollout, though enrolling is a step worth thinking through rather than a reversible trial.

This guide covers where that voluntary option comes from, what a non-mandated taxpayer actually gains by enrolling, and why reverting afterward isn’t simple. For who is mandated into eFPS today, see Who Must Enroll in BIR eFPS?; for the fallback channel most non-mandated taxpayers already use, see eFPS vs eBIRForms: Which One Do You Need to File With?.

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Where does the voluntary eFPS option come from? #

eFPS wasn’t designed purely as a mandatory system for large taxpayers — from its earliest amendments, the BIR built in room for smaller, non-mandated taxpayers to opt in on their own initiative. RR No. 9-2001 established the system and made it compulsory for BIR-classified Large Taxpayers, but subsequent regulations reflect a parallel voluntary track: an early amendment, RR No. 2-2002, extended the option to avail of eFPS to a batch of non-large taxpayers the BIR identified, rather than treating eFPS as closed to everyone outside the mandatory list.

That pattern — expanding the mandatory list while never closing the voluntary door — continued through RR No. 9-2002, RR No. 26-2002, RR No. 5-2004, RR No. 10-2007, RR No. 3-2009, and RR No. 1-2010, each of which widened who must use eFPS without removing the ability of a non-mandated taxpayer to register for it. RR No. 1-2010’s own official title, as indexed by the Supreme Court E-Library, captures the pattern of these amendments generally:

“AMENDING FURTHER SECTION 3 OF REVENUE REGULATIONS (RR) NO. 9-2001, AS LAST AMENDED BY RR NO. 10-2007, EXPANDING THE COVERAGE OF TAXPAYERS REQUIRED TO FILE RETURNS AND PAY TAXES THROUGH THE ELECTRONIC FILING AND PAYMENT SYSTEM (EFPS) OF THE BUREAU OF INTERNAL REVENUE”
— Revenue Regulations No. 1-2010 (official title)

Each of these amendments is framed as expanding mandatory coverage — none of them is framed as restricting who may register voluntarily, which is why BIR’s eFPS enrollment page has continued to accept applications from taxpayers outside the mandated categories, subject to the BIR’s own processing and the taxpayer’s RDO confirming registration details are in order.

What does a non-mandated taxpayer actually gain or risk by enrolling? #

Voluntary eFPS enrollment trades the simplicity of eBIRForms-plus-a-payment-channel for a single integrated system — but it also commits the taxpayer to eFPS’s own filing habits and payment-channel requirements going forward.

Consideration	eBIRForms (non-mandated default)	Voluntary eFPS enrollment
Filing	Prepare and submit the return through the Offline or Online eBIRForms Package	File directly within eFPS
Payment	Separate step: bank, AAB, GCash, Maya, or other accredited channel	Often integrated with an enrolled payment bank, depending on tax type
Switching back later	N/A (already the default)	Not routine — generally requires a request to the BIR rather than simply filing elsewhere next quarter
Best fit	Most small and medium taxpayers with no mandatory category	A taxpayer that wants one integrated channel, or expects to soon meet a mandatory category anyway (e.g., approaching the Top Withholding Agent threshold)

A business expecting to be designated a Top Withholding Agent soon, for example, may find it simpler to enroll in eFPS ahead of that designation rather than switching systems mid-year once the BIR publishes it on the mandatory list.

Worked example: a growing retailer considering voluntary enrollment #

Bataan Home Essentials, Inc. is not currently on any BIR mandatory eFPS list — it’s neither a Large Taxpayer nor a Top Withholding Agent, and it isn’t enrolled in TAMP. It currently files through eBIRForms and pays separately through its bank’s AAB counter each month.

The owner is considering voluntary eFPS enrollment because the company has grown steadily and the bookkeeper suspects it may cross the ₱12,000,000 Top Withholding Agent threshold within the next year or two, which would make eFPS mandatory anyway under RR No. 7-2019. Enrolling now, while the volume of filings is still manageable, lets the bookkeeper learn the system’s payment-channel requirements and build the habit of integrated filing-and-payment before the transition becomes mandatory and time-pressured. The tradeoff the owner accepts: once enrolled, reverting to eBIRForms isn’t a simple next-quarter decision if the integrated workflow turns out to be more cumbersome than expected for the company’s current size.

Summary #

The mandatory categories under RR No. 9-2001 and its amendments have never been the only way into eFPS — the regulations have consistently left room for a non-mandated taxpayer to enroll voluntarily, a track that traces back to RR No. 2-2002’s original 200-taxpayer pilot and has continued through every subsequent expansion. Enrolling makes sense for a taxpayer anticipating mandatory status soon or wanting one integrated filing-and-payment channel, but it is a commitment, not a trial — confirm your RDO’s current enrollment process and think through the payment-channel requirements before opting in, since reverting to eBIRForms afterward isn’t a routine switch.