RMC No. 55-2026: Alphalist Rules for E-Marketplace Operators and DFSPs
Revenue Memorandum Circular (RMC) No. 55-2026, issued by the Bureau of Internal Revenue (BIR) on May 26, 2026, reminds electronic marketplace operators and digital financial services providers (DFSPs) that they are withholding agents — they must withhold one-half percent (0.5%) of gross remittances to sellers, and they must attach the Alphabetical List of Employees/Payees (alphalist) to every corresponding withholding tax return. Missing the alphalist is treated as a filing violation, not a paperwork afterthought.
This guide walks through what RMC No. 55-2026 requires, the monthly/quarterly/annual alphalist deadlines it restates, and a worked example of how a platform remits seller withholding and files the matching DAT-file alphalist.
Build Your Seller QAP Alphalist FREE →What does RMC No. 55-2026 require? #
RMC No. 55-2026 is a compliance reminder, not a new tax. It points back to Revenue Regulations (RR) No. 2-98, RR No. 11-2018, RR No. 16-2023, and RR No. 5-2025, and states that e-marketplace operators and DFSPs must (1) withhold and remit 0.5% of gross remittances to sellers of goods and services, and (2) submit the prescribed Alphabetical List of Employees/Payees as a mandatory attachment to their withholding tax returns.
The circular notes that BIR records show many of these digital entities have not yet complied. Commissioner Charlito Martin R. Mendoza signed the circular and directed all withholding agents — with particular emphasis on e-marketplace operators and DFSPs — to submit alphalists through the BIR eSubmission facility under RR No. 1-2014, to avoid unnecessary penalties.
Who counts as an e-marketplace operator or DFSP under these rules? #
An electronic marketplace operator or digital financial services provider is a platform or facility that controls remittances to sellers or merchants for goods or services sold through that channel, and is therefore a withholding agent under RR No. 16-2023 as amended by RR No. 5-2025. The Tax Code definition of a withholding agent — any person or entity with control over an income payment who is required to withhold — covers these digital intermediaries even when the seller is the one earning the income.
In practice, that means marketplace operators that settle seller payouts, payment gateways and digital financial service providers that remittance-settle merchant proceeds, and similar platforms that deduct or control the flow of funds to online sellers before the seller receives the net amount. Once classified as a withholding agent under these regulations, the platform must withhold 0.5% on covered remittances and report every affected payee on the matching alphalist.
Alphalist deadlines under RMC No. 55-2026 #
RMC No. 55-2026 aligns every alphalist due date with the filing deadline of the return it attaches to — there is no separate “alphalist-only” calendar. The circular restates four deadline buckets:
| Type of return / alphalist | Due date |
|---|---|
| Alphalist for the monthly withholding tax return for value-added tax and percentage tax (e.g., BIR Form 1600-VT / 1600-PT) | 10th day of the following month |
| Quarterly alphalist of payees for creditable withholding tax (CWT) and final withholding tax (FWT) returns (e.g., BIR Form 1601-EQ / 1601-FQ) | Last day of the month following the close of the quarter |
| Annual alphalist for withholding tax on compensation and FWT (BIR Form 1604-C / 1604-F) | January 31 of the succeeding year |
| Annual alphalist for CWT (BIR Form 1604-E) | March 1 of the succeeding year |
These dates match the recurring rules covered in the 2026 BIR tax filing deadlines calendar and the annual alphalist guide for Forms 1604-C, 1604-E, and 1604-F. For a platform that remits seller withholding every quarter, the operational file is the Quarterly Alphalist of Payees (QAP) DAT file attached to BIR Form 1601-EQ or 1601-FQ.
Worked example: a marketplace remits seller withholding for Q2 2026 #
A fictional marketplace, IslaCart PH Inc., remits ₱40,000,000 in gross seller payouts for April–June 2026. Under the 0.5% rate reiterated in RMC No. 55-2026, IslaCart withholds ₱200,000 (₱40,000,000 × 0.005) across its seller base for the quarter.
Assume three sample sellers among hundreds:
| Seller (payee) | Gross remittance (Q2) | Tax withheld at 0.5% |
|---|---|---|
| Ana Mercado Trading | ₱800,000 | ₱4,000 |
| Benito Gadgets Co. | ₱1,200,000 | ₱6,000 |
| Carla Crafts Shop | ₱450,000 | ₱2,250 |
IslaCart must:
- Remit the withheld amounts with the applicable monthly and quarterly withholding returns.
- Issue each seller the corresponding withholding certificate (typically BIR Form 2307 for creditable withholding).
- Include every seller — including Ana, Benito, and Carla — on the quarterly alphalist of payees DAT file, due on or before July 31, 2026 (last day of the month following Q2 close).
- File the validated DAT through the BIR eSubmission facility (or eFPS electronic attachment, if enrolled), then keep the acknowledgement as proof of submission.
A seller-heavy platform that withholds correctly but never files the alphalist still fails RMC No. 55-2026 — the circular treats the alphalist as an integral part of the return, so an incomplete filing is a regulatory violation.
How to submit the alphalist — and what happens if you don’t #
RMC No. 55-2026 directs e-marketplace operators and DFSPs to submit the prescribed alphalist through the BIR eSubmission facility, as already required under RR No. 1-2014. In practice, that means validating the alphalist with the BIR Alphalist Data Entry and Validation Module (or an equivalent DAT workflow that produces a zero-error file), then transmitting it electronically and retaining the system acknowledgement.
Failure to submit the alphalist — or submitting incomplete, inaccurate, or non-prescribed-format data — constitutes a violation of BIR regulations and is subject to the corresponding penalty. Under Section 250 of the NIRC and the compromise framework in RMO No. 7-2015, failure to file or supply a required information return typically carries a ₱1,000 penalty per failure, capped at an aggregate of ₱25,000 per calendar year. Persistent non-submission (for example, missing the annual alphalist for two consecutive years) or submission outside the prescribed format can be treated as willful failure under RMO No. 7-2015 and may not be available for compromise.
Frequently asked questions #
What is RMC No. 55-2026? #
Revenue Memorandum Circular No. 55-2026, issued by the BIR on May 26, 2026, reminds withholding agents — particularly electronic marketplace operators and digital financial services providers (DFSPs) — that they must submit the Alphabetical List of Employees/Payees as a mandatory attachment to their withholding tax returns.
What withholding rate do e-marketplace operators and DFSPs apply to seller remittances? #
Under RR No. 16-2023, as amended by RR No. 5-2025 and reiterated in RMC No. 55-2026, electronic marketplace operators and DFSPs must withhold and remit one-half percent (1/2% or 0.5%) of their gross remittances to sellers or merchants for goods or services transacted through their platform or facility.
When is the monthly alphalist for VAT and percentage tax due under RMC No. 55-2026? #
Under RMC No. 55-2026, the alphalist for the monthly withholding tax return covering value-added tax and percentage tax is due on or before the 10th day of the following month — the same deadline as the return itself.
When is the quarterly alphalist of payees due for CWT and FWT? #
Under RMC No. 55-2026, the quarterly alphalist of payees for creditable withholding tax (CWT) and final withholding tax (FWT) returns is due on or before the last day of the month following the close of the quarter.
How must e-marketplace operators and DFSPs submit the alphalist? #
RMC No. 55-2026 directs withholding agents to submit the prescribed alphalist through the BIR eSubmission facility, as required under RR No. 1-2014. Incomplete or missing alphalists are treated as a violation of BIR regulations and are subject to penalty.
Summary #
RMC No. 55-2026 puts digital platforms on notice: if you remittance-settle sellers as an e-marketplace operator or DFSP, you already owe 0.5% withholding under RR No. 16-2023 / RR No. 5-2025, and you must file the matching alphalist with every related withholding return — monthly (10th day), quarterly (last day of the following month), and annually (January 31 for 1604-C/1604-F; March 1 for 1604-E). Treat the seller alphalist as part of the return itself, validate the DAT before eSubmission, and keep the acknowledgement — that is the compliance story the circular is telling.