Do You Need a BIR Permit to Use (PTU) for Excel-to-DAT Conversion Software?
No — a tool that converts your Excel data into a properly formatted BIR DAT file for RELIEF, QAP, SAWT, or Alphalist submission does not require a BIR Permit to Use (PTU) or Computerized Accounting System (CAS) registration. Those requirements, simplified under Revenue Memorandum Circular (RMC) No. 5-2021, target software that records a business’s actual sales transactions and books of accounts — not a tool that reformats data you’ve already recorded elsewhere into the BIR’s required submission structure.
This is a common point of confusion for taxpayers who already know their point-of-sale or accounting software needed BIR registration, and assume every piece of tax-related software needs the same treatment.
Convert Excel to a BIR DAT File — No Registration Needed FREE →What actually requires CAS/PTU registration? #
RMC No. 5-2021 simplified — and in the process, clarified the actual scope of — registration for Computerized Accounting Systems (CAS), Computerized Books of Accounts (CBA), and their components. The circular describes the scope broadly: any system, application, or software adopted to generate a business’s accounting records, reports, and documents, including online systems that function as ordering, booking, collection, or receipting/invoicing facilities — whether or not integrated with a wider accounting system.
RMC No. 5-2021 itself describes the change in registration mechanics this way:
“All taxpayers intending to use CAS, CBA and/or its components, including the ESS, middleware and other similar systems shall not be required to secure Permit to Use (PTU).”
Instead, the taxpayer registers the “System” with their RDO by submitting a Checklist of Documentary Requirements. The common thread across everything covered by that registration is that the software is standing in for (or generating) the business’s official records of its own transactions: sales, receipts, invoices, and the books built from them. That’s also why one of the grounds for revoking a system’s registration under RMC No. 5-2021 is tampering with sales data or altering a software’s features to avoid recording a sale transaction — the whole point of CAS oversight is protecting the integrity of a business’s recorded sales.
Where a DAT converter sits outside that scope #
An Excel-to-DAT conversion tool does something categorically different: it takes data you’ve already recorded through your normal books, invoices, and payroll records, and reformats it into the specific layout the BIR requires for a RELIEF, QAP, SAWT, or Alphalist submission. It isn’t recording a sale, generating an invoice, or serving as your books of accounts — the transactions it works with already happened and were already recorded elsewhere.
| Computerized Accounting System (CAS/CBA) | Excel-to-DAT converter | |
|---|---|---|
| What it does | Records official sales transactions, generates invoices/receipts, maintains books of accounts | Reformats already-recorded data into the BIR’s required DAT structure |
| Registration under RMC No. 5-2021 | Required (via CDR submission to the RDO, no PTU needed) | Not required — outside the circular’s scope |
| Risk it’s meant to guard against | Tampering with or hiding actual sales transactions | Not applicable — no sales transactions are recorded or altered |
Does this mean no BIR software needs registration? #
Not necessarily — it means the two questions are separate, and one tool’s registration status says nothing about another. A business might legitimately need to register its point-of-sale system or accounting software as a CAS under RMC No. 5-2021, while separately using a DAT converter that needs no registration at all, because the converter isn’t the system generating or recording the business’s sales in the first place.
If you’re unsure whether a specific piece of software your business uses falls under CAS/CBA registration, the deciding question is always the same: does it record, generate, or serve as the official documentation of a sales transaction or the books built from it? If yes, look into CAS registration. If it only reformats data you’ve already recorded for a specific BIR submission, that registration requirement doesn’t apply.
Frequently asked questions #
Do I need a BIR Permit to Use (PTU) to use an Excel-to-DAT conversion tool? #
No. PTU and CAS/CBA registration requirements, as simplified under Revenue Memorandum Circular No. 5-2021, apply to Computerized Accounting Systems and similar software that record a business’s official sales transactions and books of accounts. A tool that converts data you already have in Excel into a properly formatted BIR DAT file for RELIEF, QAP, SAWT, or Alphalist submission does not record sales transactions or maintain your books, so it falls outside that registration requirement.
Does RMC No. 5-2021 still require a Permit to Use for Computerized Accounting Systems? #
No — RMC No. 5-2021 removed the PTU requirement even for CAS, CBA, and their components. Taxpayers using these systems now register the “System” with their RDO by submitting a Checklist of Documentary Requirements, rather than applying for and waiting on a formal Permit to Use.
What kind of software does require CAS registration? #
Software that generates a business’s accounting records, reports, or documents — including systems that function as ordering, booking, collection, or receipting/invoicing facilities, whether or not integrated with a broader accounting system — falls under CAS/CBA registration requirements.
Is a DAT file converter the same thing as a Computerized Accounting System? #
No. A DAT file converter takes data you’ve already recorded elsewhere (typically in Excel, sourced from your actual books, invoices, and payroll records) and reformats it into the BIR’s required submission layout for RELIEF, QAP, SAWT, or Alphalist filings. It doesn’t independently record sales transactions, issue receipts, or serve as your books of accounts, which is what triggers CAS registration.
Could my accounting software still need CAS registration even if my DAT converter doesn’t? #
Yes — those are separate questions. If your business separately uses a computerized accounting system, invoicing system, or point-of-sale software to record its actual books and transactions, that system may need CAS/CBA registration under RMC No. 5-2021 regardless of what tool you also use to prepare BIR DAT file submissions from that data.
Summary #
CAS/CBA and Permit to Use requirements under RMC No. 5-2021 target software that records a business’s actual sales transactions and books of accounts — a category an Excel-to-DAT conversion tool doesn’t fall into, since it only reformats data already recorded elsewhere into the BIR’s required RELIEF, QAP, SAWT, or Alphalist submission structure. Your point-of-sale or accounting software may still need CAS registration on its own terms — that’s a separate question from whether your DAT-conversion tool needs one. For the underlying format itself, see What Is a BIR DAT File?, and for the related PTU question on sales machines, see Do You Still Need a BIR Permit to Use (PTU) for Your POS or CRM Machine?.