RMC No. 39-2026: The May 15, 2026 Deadline for 2025 Annual ITR Attachments via eAFS

RMC No. 39-2026, issued by the BIR on April 23, 2026, clarifies that the deadline for submitting required attachments to the 2025 Annual Income Tax Return (AITR) through the eAFS system is a single, fixed date: May 15, 2026. This applies uniformly to every taxpayer who e-filed within the extended AITR period granted under RMC No. 30-2026 — whether the return itself was filed on April 15, April 16, or May 15, 2026, the eAFS attachment deadline does not move.

Why did the BIR need to clarify this at all? #

RMC No. 30-2026 extended the 2025 AITR filing and payment deadline to May 15, 2026, but it left taxpayers unsure whether their personal eAFS attachment deadline would also shift depending on which day within that window they actually e-filed. RMC No. 39-2026 answers that question directly: it decouples the eAFS attachment deadline from each taxpayer’s individual filing date and fixes it at May 15, 2026 for everyone who filed within the extension.

Under the BIR’s long-standing default rule (most recently reiterated through annual AITR circulars — see What Is the BIR eAFS System for the standing 15-calendar-day mechanic), attachments are ordinarily due within 15 calendar days of the statutory filing deadline, or 15 days from actual filing if filed late. Applied literally during an extension period, that rule would have produced a different eAFS due date for every taxpayer depending on the exact day they e-filed — someone who filed April 15 would owe attachments around April 30, while someone who filed May 15 would owe them around May 30. RMC No. 39-2026 replaces that sliding calculation with one common date for the entire 2025 AITR extension period.

What does RMC No. 39-2026 actually say? #

RMC No. 39-2026 sets out illustrative scenarios covering taxpayers who e-filed their 2025 AITR on or before April 15, 2026 (the original statutory deadline), between April 16 and May 15, 2026, and exactly on May 15, 2026 (the last day of the RMC No. 30-2026 extension). In each scenario, the circular arrives at the same answer: the eAFS attachment deadline is May 15, 2026, regardless of the taxpayer’s actual e-filing date within the extended period.

Grant Thornton’s tax note on the circular, summarizing RMC No. 39-2026’s own illustrative scenarios, puts the operative rule this way:

“The final and uniform deadline for submitting all required attachments through eAFS is 15 May 2026, regardless of the actual date of electronic filing within the extended period.” — Grant Thornton Philippines, tax note on RMC No. 39-2026

Secondary tax alerts summarizing the circular — including coverage from Grant Thornton and other Philippine tax practices — consistently describe its operative effect the same way: taxpayers who e-filed on or before April 15, 2026 may submit attachments through eAFS until May 15, 2026; taxpayers who e-filed after April 15 but on or before May 15, 2026 may likewise submit until May 15, 2026; and even a taxpayer who e-files exactly on May 15, 2026 still has attachments due that same day, not fifteen days later. This account is a paraphrase of secondary reporting on the circular — the exact operative wording of RMC No. 39-2026 should be confirmed against the circular itself (available from the BIR) before it is cited in a formal submission.

How does this relate to RMC No. 30-2026? #

RMC No. 30-2026 is the extension circular; RMC No. 39-2026 is the clarification that tells you what that extension means for your attachments, not a second, independent extension. RMC No. 30-2026 pushed the 2025 AITR filing and payment deadline from the statutory April 15, 2026 date to May 15, 2026. RMC No. 39-2026 then closes the gap RMC No. 30-2026 left open — confirming that the eAFS attachment window does not reopen or restart based on when, within that extended period, a given taxpayer actually filed.

Which attachments does the May 15, 2026 deadline cover? #

The May 15, 2026 eAFS deadline applies to the same package of attachments that normally accompanies the AITR, submitted through the same eAFS portal — it is a timing clarification, not a change to what must be submitted. For a full checklist of what belongs in that package, see BIR Form 1701 Attachments: What to Submit With Your Annual Income Tax Return. Commonly affected documents include:

• Audited Financial Statements (AFS) and the accompanying Statement of Management’s Responsibility, for filers above the ₱3,000,000 gross sales/receipts threshold
• A copy of the filed AITR itself (BIR Form 1701, 1701A, or 1702 series, as applicable)
• BIR Form 2307 certificates and the SAWT summarizing them, where creditable withholding tax is claimed
• BIR Form 1709 (Related Party Transactions), where required
• Other schedules the specific return calls for

Worked example #

A self-employed consultant with gross receipts above ₱3,000,000 for 2025 was ready early and e-filed her BIR Form 1701 on April 15, 2026, the original statutory deadline, well before RMC No. 30-2026 extended the filing window. Because she filed on the original due date rather than waiting for the extension, she might reasonably have assumed her eAFS attachment window followed the standing 15-calendar-day rule and closed around April 30, 2026. Under RMC No. 39-2026, that assumption is wrong: her eAFS deadline for the AFS, Statement of Management’s Responsibility, and SAWT is the same May 15, 2026 date that applies to a colleague who files on May 14, 2026. Filing early did not shorten her attachment window — it gave her more time, not less, to assemble and upload the eAFS package before the fixed May 15, 2026 cutoff.

What happens if attachments are still submitted late? #

Missing the May 15, 2026 eAFS deadline does not undo a timely-filed AITR, but it does expose the attachment package itself to separate compliance consequences. Late or incomplete submission of required ITR attachments can be treated by the BIR as a compliance failure independent of the return’s filing status, potentially triggering penalties under the BIR’s compromise penalty schedule for the specific missing document (such as the AFS or SAWT) even where the tax due was paid on time. Filers who anticipate difficulty meeting May 15, 2026 should prepare the attachment package well ahead of the deadline rather than relying on the extension date as a buffer.

Summary #

RMC No. 39-2026, dated April 23, 2026, fixes May 15, 2026 as the single eAFS deadline for 2025 AITR attachments, closing the ambiguity RMC No. 30-2026’s filing extension created. Whether a taxpayer e-filed on April 15, April 16, or May 15, 2026, the attachment deadline through eAFS does not move — it is May 15, 2026 for everyone who filed within the extended period. What must be submitted has not changed, only when: see What Is the BIR eAFS System for the mechanics of the eAFS portal itself, and BIR Form 1701 Attachments for the full attachment checklist. Filers who already e-filed early should not treat that as license to submit attachments late — the May 15, 2026 date applies regardless.