RMO No. 22-2026: What the BIR's Consolidated Audit Program Changes

Revenue Memorandum Order (RMO) No. 22-2026, issued by the BIR on August 24, 2026, consolidates the audit reforms rolled out earlier in the year into one standing BIR Audit Program. It brings RMO No. 1-2026 (as amended by RMO No. 6-2026 and clarified by RMC No. 14-2026) together with the pre-existing assessment framework under Revenue Regulations (RR) Nos. 12-99, 18-2013, and 22-2020, institutionalizing a risk-based, system-assisted, technology-driven audit process as the Bureau’s permanent reference document rather than a set of scattered issuances.

What is RMO No. 22-2026? #

RMO No. 22-2026 is the BIR’s consolidated and revised set of policies, guidelines, and procedures for its Audit Program, issued August 24, 2026. Rather than introducing a wholly new audit philosophy, it gathers the reforms already in effect since early 2026 — the Single-Instance Audit Framework, system-assisted case selection, and anonymized examiner assignment — into a single reference instrument meant to standardize audit practice across every BIR investigating office: Revenue District Offices, the Large Taxpayers Service, and the National Investigation Division alike.

Why did the BIR need to consolidate these rules? #

Before RMO No. 22-2026, a taxpayer or practitioner tracing the actual rules for a BIR audit had to piece together several separate issuances rather than read one document. RMO No. 1-2026 introduced the post-suspension audit-resumption framework; RMO No. 6-2026 amended parts of it; RMC No. 14-2026 clarified open questions; and the underlying legal basis for assessments still traced back to older regulations — RR No. 12-99 (due process in issuing assessments), RR No. 18-2013 (its 2013 amendments), and RR No. 22-2020 (further revisions to assessment procedure). Consolidation reduces the risk that an examiner or a taxpayer applies an outdated or superseded version of any one piece.

This site’s earlier coverage of RMO No. 1-2026 and the electronic Letter of Authority walked through that framework as it stood in early 2026 — the Single-Instance Audit Framework, the Replacement eLA process, and the REVIE-based LOA Verifier. RMO No. 22-2026 does not discard that groundwork; it absorbs it into a broader, longer-form program document.

What does RMO No. 22-2026 actually consolidate? #

RMO No. 22-2026 pulls together four sets of prior issuances that a taxpayer previously had to read separately. The table below maps what feeds into the consolidated program and what each prior piece contributed.

What is genuinely new versus simply reorganized? #

Based on the available guidance, RMO No. 22-2026 is best read as an institutionalization of the existing framework rather than a rewrite of it. Secondary commentary describes it as strengthening and standardizing the reforms already introduced under RMO No. 1-2026 — extending consistent audit policies, procedures, and internal controls across all investigating offices — rather than replacing the Single-Instance Audit Framework, the eLA concept, or the risk-based selection model with something different. Practitioner summaries note that RMO No. 22-2026 absorbs RMO No. 1-2026 rather than repealing it: RMO No. 1-2026 was the initial, remedial issuance paired with the lifting of the 2025 audit suspension, and RMO No. 22-2026 is the fuller, standing program that issuance pointed toward.

Be candid about the limits of what’s confirmed here: the full text of RMO No. 22-2026 sets out standardized controls, governance, and procedural detail across offices, but the specific line-by-line differences between it and the RMO No. 1-2026/RMO No. 6-2026/RMC No. 14-2026 stack are not something this post can verify sentence-by-sentence without direct access to the full order. If your business is currently under audit, treat RMO No. 22-2026 as confirmation that the Single-Instance Audit Framework and eLA process described in this site’s RMO No. 1-2026 guide remain the operative rules — now under one consolidated reference — rather than assuming some undocumented new requirement applies.

A worked example: tracing which rule applies to an assessment #

A retail distributor in Cebu receives a Formal Assessment Notice (FAN) in September 2026 following an audit that began under an eLA issued in March 2026. Its accountant needs to know which procedural rules govern the assessment’s validity.

• Due-process basis for the assessment itself (Preliminary Assessment Notice requirements, reply periods, and the sequence from PAN to FAN): still traces to RR No. 12-99, as amended by RR No. 18-2013 and RR No. 22-2020 — now referenced within the RMO No. 22-2026 consolidated program rather than cited as three separate regulations.
• How the audit was authorized and scoped (one eLA covering all applicable taxes for the taxable year, system-assisted case selection): governed by the Single-Instance Audit Framework originally set out in RMO No. 1-2026, carried forward under RMO No. 22-2026.
• Any examiner reassignment during the audit: still handled through a Replacement eLA rather than a fresh Letter of Authority, per the same framework.

The distributor’s practical takeaway: nothing about how to respond to the PAN or FAN changed on August 24, 2026 — but citing RMO No. 22-2026 as the umbrella reference, alongside the specific RR provision at issue, is now the more complete and current way to frame a protest or reply.

What should taxpayers and practitioners do differently now? #

1. Cite RMO No. 22-2026 alongside the specific older provision. When protesting an assessment or briefing counsel, reference both the consolidated order and the underlying RR (12-99/18-2013/22-2020) or RMO (1-2026/6-2026) provision actually at issue, since the consolidated order is now the Bureau’s standing reference point.
2. Don’t assume the eLA and Replacement eLA rules changed. Continue applying the verification, scope, and reassignment checks from the general Letter of Authority guide and the RMO No. 1-2026 framework unless a specific provision of RMO No. 22-2026 says otherwise.
3. Track the PAN-to-FAN sequence carefully. The due-process timeline and reply windows that RR No. 12-99, RR No. 18-2013, and RR No. 22-2020 built up over more than two decades remain the backbone of assessment validity; see BIR PAN vs. FAN: The Assessment Process Explained for how that sequence works step by step.
4. Watch for implementing circulars. A consolidation order of this scope often generates follow-up RMCs answering specific implementation questions, the way RMC No. 14-2026 followed RMO No. 1-2026 — expect similar clarifications after RMO No. 22-2026.

Frequently asked questions #

Does RMO No. 22-2026 replace RMO No. 1-2026? #

It absorbs and institutionalizes RMO No. 1-2026 rather than repealing it outright. RMO No. 1-2026 was the initial, remedial issuance paired with the lifting of the 2025 audit suspension, and RMO No. 22-2026 is the fuller, standing program that issuance pointed toward — the Single-Instance Audit Framework and electronic Letter of Authority (eLA) concept from RMO No. 1-2026 continue under the consolidated program.

Do taxpayers need to worry about a new type of audit notice under RMO No. 22-2026? #

Based on available guidance, no. The eLA remains the operative document authorizing a BIR audit; RMO No. 22-2026 standardizes the audit program around the existing eLA process rather than introducing a different instrument.

Does RMO No. 22-2026 change assessment deadlines under RR No. 12-99, 18-2013, or 22-2020? #

Nothing in the available guidance indicates a change to those due-process timelines. RMO No. 22-2026 references the RR No. 12-99/18-2013/22-2020 assessment framework as part of the consolidated program rather than amending its deadlines or procedure.

What prior issuances does RMO No. 22-2026 consolidate? #

RMO No. 22-2026 consolidates RMO No. 1-2026 (as amended by RMO No. 6-2026 and clarified by RMC No. 14-2026) together with the pre-existing assessment framework under Revenue Regulations Nos. 12-99, 18-2013, and 22-2020, into one standing BIR Audit Program document.

Should a tax protest still cite the older regulations, or only RMO No. 22-2026? #

Cite both. Reference RMO No. 22-2026 as the Bureau’s current umbrella reference point, alongside the specific underlying provision actually at issue — whether that is a Single-Instance Audit Framework rule originally from RMO No. 1-2026 or a due-process requirement from RR No. 12-99, 18-2013, or 22-2020.

Summary #

RMO No. 22-2026 gathers RMO No. 1-2026 (as amended by RMO No. 6-2026 and clarified by RMC No. 14-2026) and the RR No. 12-99/18-2013/22-2020 assessment framework into one consolidated BIR Audit Program, issued August 24, 2026. The clearest, best-supported reading is institutional consolidation — standardized controls and a single reference document — rather than a substantive overhaul of the Single-Instance Audit Framework or eLA process. Pair this with the RMO No. 1-2026 eLA guide, the general Letter of Authority guide, and BIR PAN vs. FAN before responding to any audit notice issued under the consolidated program.