Who Must File QAP? BIR Withholding Agent Filing Obligations Explained
Any withholding agent that made even one payment subject to expanded withholding tax during a quarter must file QAP — there is no minimum number of payees or peso amount that exempts a smaller filer. A carve-out that once let withholding agents with fewer than 10 payees submit a manual list was discontinued in 2014, so today the DAT-file obligation applies uniformly, from a one-payee sole proprietor to a large corporation.
Check Your QAP Obligation and Build the DAT FREE →Which withholding agents must file QAP? #
A withholding agent files QAP whenever it made a payment subject to expanded (creditable) or final withholding tax during the taxable quarter — filing status, not size, triggers the requirement. Under Section 2.58 of Revenue Regulations (RR) No. 2-98, as amended by RR No. 11-2018, the return filed for that quarter must be accompanied by the alphalist reflecting every payee, TIN, income paid, and tax withheld.
A withholding agent typically falls into this obligation because it:
- Has “Withholding Tax – Expanded” (or Final) listed as an active tax type on its BIR Form 2303 Certificate of Registration, or
- Made a payment — professional fee, rental, commission, contractor’s fee, purchase of goods or services — that is subject to expanded withholding tax under the applicable Alphanumeric Tax Code (ATC), whether or not it is a designated Top Withholding Agent.
If neither condition applies for a given quarter, there is no expanded withholding activity to report and no QAP payee data to build. For what a QAP row itself contains, see What Is QAP?.
Does the number of payees change the filing requirement? #
No — the old rule that let small withholding agents skip electronic filing was discontinued in 2014, so payee count no longer determines whether QAP must be filed as a DAT. Before that, RR No. 2-98 as amended by RR No. 10-2008 allowed withholding agents with fewer than 10 employees or payees to submit a manual paper alphalist instead of an electronic one.
RR No. 1-2014, clarified in Q&A form by RMC No. 5-2014, ended that carve-out: manual submission of alphalists with fewer than 10 payees under the annual returns (BIR Form 1604-CF and BIR Form 1604-E) was discontinued beginning January 31, 2014 and March 1, 2014 respectively, “and every year thereafter.” The same electronic-only requirement extends to the quarterly QAP attached to BIR Form 1601-EQ and BIR Form 1601-FQ. A withholding agent today files QAP electronically through one of three channels regardless of whether it has 1 payee or 1,000:
| Submission channel | How it works |
|---|---|
| eFPS attachment | Uploaded directly with the electronically filed BIR Form 1601-EQ or 1601-FQ |
| eSubmission | Uploaded via the BIR’s eSubmission portal on bir.gov.ph |
| Sent as a DAT file to the BIR’s dedicated alphalist email address |
Manual paper filing and submission on physical storage media (CDs, DVDs, USBs) are no longer accepted for any withholding agent. A more recent reminder of this obligation’s weight is RMC No. 55-2026 (issued May 26, 2026), which reiterates that alphalist submission is mandatory alongside remittance itself:
“Since the alphalist forms an integral part of the withholding tax return, its submission is likewise a mandatory obligation of the withholding agent.”
— Revenue Memorandum Circular No. 55-2026 (May 26, 2026), as quoted in PwC Philippines’ Tax Alert No. 32
For how the DAT file itself is built from a payee spreadsheet, see How to Convert Excel to BIR DAT File for QAP; the free QAP module on BIR Online Tools generates a validation-ready DAT regardless of whether a quarter has 2 payees or 200.
Are Top Withholding Agents subject to a different QAP rule? #
Top Withholding Agents (TWAs) follow the identical QAP filing rule as any other withholding agent — what changes is how many of their payments become reportable, not whether or how they file. A TWA is a taxpayer the BIR has classified, under RR No. 7-2019, as required to withhold 1% on local purchases of goods and 2% on services once its gross sales, purchases, or claimed deductible expenses reach ₱12,000,000 or more in the preceding year.
Once that classification takes effect, ordinary local purchases that were never withheld before — routine supplier payments, rent, services — become subject to expanded withholding tax and therefore appear on the TWA’s QAP going forward. The company doesn’t file a different kind of QAP; its QAP simply grows to include suppliers that a non-TWA business of the same size would not have withheld from at all. The full mechanics of TWA classification, thresholds, and rates are covered in Who Is a BIR Top Withholding Agent? rather than repeated here.
What if a withholding agent has zero EWT transactions in a quarter? #
A quarter with no expanded withholding activity leaves nothing to populate on QAP, but that does not automatically excuse the underlying BIR Form 1601-EQ if expanded withholding is registered as an active tax type. The QAP attachment itself has no payee rows to report — there is nothing to list — but many withholding agents whose Certificate of Registration carries “Withholding Tax – Expanded” as a tax type still file the 1601-EQ for that quarter as a no-payment return, because the return obligation flows from registration status rather than from having a transaction that quarter.
This is a registration-specific question rather than a blanket rule, so confirm it against your own BIR Form 2303 tax types or with a tax professional before assuming a quarter can simply be skipped. For the deadline that governs both the return and any QAP data it carries, see QAP Filing Deadlines.
Worked example: three payees is still enough to require a DAT file #
All names and TINs below are fictional, illustrating why payee count alone never exempts a filer.
A freelance bookkeeping practice — a single proprietor registered with “Withholding Tax – Expanded” on its BIR Form 2303 — pays only three suppliers subject to expanded withholding tax in Q3 2026:
| Payee (fictional) | TIN (fictional) | ATC | Income (Q3) | Tax withheld |
|---|---|---|---|---|
| Amihan Office Supplies | 111-222-333-000 | WC010 | ₱25,000.00 | ₱1,250.00 (5%) |
| Reyes Freight Services | 222-333-444-000 | WC010 | ₱18,000.00 | ₱900.00 (5%) |
| Delia M. Santos (bookkeeper) | 333-444-555-000 | WI010 | ₱15,000.00 | ₱750.00 (5%) |
| Totals | ₱58,000.00 | ₱2,900.00 |
Under the pre-2014 rule, three payees would have qualified for manual paper filing. Under current rules, this practice must still build a QAP DAT file — the same electronic format a company with hundreds of payees uses — and submit it with BIR Form 1601-EQ by October 31, 2026, the Q3 deadline. Payee count changed nothing about the filing channel; it only changed how few rows the DAT file contains.
Frequently asked questions #
Who is required to file QAP? #
Any withholding agent — individual or corporate — that made a payment subject to expanded withholding tax during the quarter must file QAP, the Quarterly Alphalist of Payees, as a DAT attachment to BIR Form 1601-EQ, regardless of how many payees are on the list or how small the amounts withheld are.
Is there a minimum number of payees before QAP must be filed as a DAT file? #
No. Before 2014, withholding agents with fewer than 10 payees could submit a manual paper alphalist instead. Revenue Regulations No. 1-2014, clarified by Revenue Memorandum Circular No. 5-2014, discontinued that carve-out, so every withholding agent now files QAP electronically as a DAT file no matter how few payees it has.
Do Top Withholding Agents follow a different QAP filing rule than other withholding agents? #
No. Top Withholding Agents (TWAs) file QAP under the same rule as any other withholding agent with expanded withholding tax activity. What changes for a TWA is the volume of payments subject to withholding under Revenue Regulations No. 7-2019, which typically means more payees appear on its QAP, not a separate filing requirement.
Does a withholding agent still need to file QAP if it had zero expanded withholding transactions in a quarter? #
A withholding agent with the Expanded Withholding Tax tax type registered on its BIR Form 2303 generally still files BIR Form 1601-EQ for the quarter, even as a no-payment return, because that obligation follows from registration rather than from having a transaction to report. With no payees to list, the QAP itself has nothing to populate, but confirm the no-payment filing requirement against your own registration profile or a tax professional rather than assuming a blanket skip.
What happens if a required QAP is not submitted? #
Because the alphalist is treated as an integral part of the withholding tax return it attaches to, a missing or unsuccessfully uploaded QAP exposes the withholding agent to the same late-filing and non-submission penalties that apply to the underlying BIR Form 1601-EQ, on top of any deductibility issues the missing attachment creates for the related expense.
Can a withholding agent submit QAP data on paper or on a CD/USB instead of eSubmission? #
No. Revenue Regulations No. 1-2014 and Revenue Memorandum Circular No. 5-2014 discontinued manual and storage-device (CD, DVD, USB) submission of the alphalist. QAP must go through one of the BIR’s electronic channels: attachment via eFPS, eSubmission through the BIR website, or email to the BIR’s dedicated alphalist address using the prescribed DAT format.
Summary #
QAP’s filing obligation turns on activity, not size: any withholding agent with expanded withholding tax payments in a quarter files QAP under Section 2.58 of RR No. 2-98 as amended by RR No. 11-2018, and has done so electronically — with no manual carve-out for small payee counts — since RR No. 1-2014 and RMC No. 5-2014 discontinued paper filing in 2014. Top Withholding Agent status under RR No. 7-2019 changes how many payees show up on that DAT, not whether or how the filing happens, and a quarter with zero transactions still needs the underlying return checked against the withholding agent’s own registration profile. For the exact due-date calendar, see QAP Filing Deadlines; for what a QAP row must contain, see What Is QAP?; for the separate rules on TWA classification and rates, see Who Is a BIR Top Withholding Agent?.