QAP Filing Deadlines: When Is the Quarterly Alphalist of Payees Due?

QAP (Quarterly Alphalist of Payees) is due on or before the last day of the month following the close of each taxable quarter — the identical deadline as the BIR Form 1601-EQ or 1601-FQ return it attaches to. There is no separate QAP deadline to track: if the quarterly withholding tax return is on time, so is its QAP.

This guide covers exactly when QAP falls due each quarter, why the EOPT Act didn’t change that date even though it changed how the return can be filed, and what happens when it’s missed.

When is QAP actually due? #

QAP is due on or before the last day of the month following the close of the taxable quarter, filed as a required attachment to BIR Form 1601-EQ (expanded/creditable withholding) or BIR Form 1601-FQ (final withholding) under Revenue Regulations No. 11-2018. Since Philippine taxable quarters follow the calendar year, the four due dates repeat in the same pattern every year:

If the last day of the month falls on a weekend or a declared holiday, BIR practice — consistent across its filing deadlines generally — is to move the deadline to the next working day; always confirm this against any BIR advisory issued close to the actual due date rather than assuming it automatically.

A worked example: Q1 2026 #

A withholding agent’s Q1 2026 covers January 1 to March 31, 2026. Its BIR Form 1601-EQ (or 1601-FQ, or both, depending on what it withheld) and the corresponding QAP DAT file listing every payee withheld from during that quarter are both due on or before April 30, 2026 — the last day of the month following the quarter’s close. The same pattern repeats for Q2 2026 (due July 31, 2026), Q3 2026 (due October 31, 2026), and Q4 2026 (due January 31, 2027).

Did the EOPT Act change this deadline? #

No — the EOPT Act changed filing channels and venue rules, not the date itself. Republic Act No. 11976, the Ease of Paying Taxes (EOPT) Act, is implemented for withholding-related filing procedures through Revenue Regulations No. 4-2024, which removed the old 25% surcharge for filing “at the wrong venue” (an RDO other than the one with jurisdiction) and pushed taxpayers toward the BIR’s electronic filing channels — eBIRForms and eFPS. Neither RR No. 4-2024 nor any other current implementing issuance moved the last-day-of-month-following-quarter deadline that RR No. 11-2018 already set for Form 1601-EQ, 1601-FQ, and their QAP attachment.

One EOPT-driven change that does affect who files: the Act exempted micro taxpayers from the obligation to withhold creditable tax under Section 57(B) of the NIRC, meaning a qualifying micro taxpayer that makes no payments subject to expanded withholding has no 1601-EQ or QAP obligation to begin with. This affects whether the return applies to a business at all, not when it’s due once it does apply.

What happens if QAP is filed late? #

A late or missing QAP is treated as part of the underlying 1601-EQ or 1601-FQ filing failure rather than a separate penalty in its own right — the return and its DAT-file attachment are filed together, so a missed deadline exposes the withholding agent to the standard late-filing consequences under the NIRC: a 25% surcharge on the tax due under Section 248, 12% annual interest under Section 249, plus applicable compromise penalties under RMO No. 7-2015. Because QAP data also feeds the payee’s own BIR Form 2307 certificates and the withholding agent’s annual 1604-E filing, a late or inaccurate QAP can compound into corrections needed on both of those downstream filings as well.

Frequently asked questions #

When is QAP due? #

The Quarterly Alphalist of Payees (QAP) is due on or before the last day of the month following the close of the taxable quarter — the same deadline as the BIR Form 1601-EQ or 1601-FQ return it attaches to.

Is the QAP deadline the same for 1601-EQ and 1601-FQ? #

Yes. Both BIR Form 1601-EQ (expanded/creditable withholding) and BIR Form 1601-FQ (final withholding) share the same quarterly deadline — the last day of the month following the close of the quarter — and each requires its own QAP attachment covering only the payees reported on that specific return.

Did the EOPT Act move the QAP filing deadline? #

No. Republic Act No. 11976 (the EOPT Act) and its implementing Revenue Regulations No. 4-2024 changed where and how a return can be filed — removing the old penalty for filing at the wrong venue and expanding electronic filing — but did not move the last-day-of-month-following-quarter deadline for Form 1601-EQ, 1601-FQ, or their QAP attachment.

What happens if QAP is filed late? #

A late or missing QAP attachment is treated the same as a late or missing information return under Section 250 of the NIRC, and the underlying 1601-EQ or 1601-FQ return itself is subject to the surcharge, interest, and compromise penalty rules for late-filed returns under Sections 248 and 249.

Do all withholding agents file both 1601-EQ and 1601-FQ, and both QAPs? #

No. A withholding agent files 1601-EQ and its QAP only if it made payments subject to expanded (creditable) withholding tax during the quarter, and 1601-FQ and its QAP only if it made payments subject to final withholding tax. A business with only one type of withholding activity in a given quarter files only the corresponding return and QAP.

Summary #

QAP doesn’t carry its own separate due date — it’s due whenever the 1601-EQ or 1601-FQ return it attaches to is due, which under RR No. 11-2018 is the last day of the month following the close of each calendar quarter (April 30, July 31, October 31, and January 31 of the following year). The EOPT Act’s RR No. 4-2024 reworked filing venue and channel rules but left that quarterly deadline untouched. For the mechanics of building the QAP DAT file itself, see How to Convert Excel to BIR DAT File for QAP; QAP’s quarterly data later rolls up into the once-a-year BIR Annual Alphalist filing, and the same payees appear individually on BIR Form 2307 certificates issued throughout the year.