How to Submit BIR Form 1604-C and Alphalist in 2026 (A Step-by-Step Guide)

January 31, 2026 is the non-negotiable deadline for submitting BIR Form 1604-C and the Alphalist of Employees for the taxable year 2025. And the filing process isn’t simple.

It requires year-end payroll annualization, using multiple BIR software tools, and strict validation checks. Even small mistakes, like an incorrect TIN, mismatched totals, or an improperly named file, can lead to rejected submissions, penalties, or closer attention from the BIR.

This guide is designed for HR teams, payroll officers, and business owners who want to file for the first time. We’ll walk you through step-by-step instructions and real troubleshooting tips based on actual filing issues, so you can confidently stay compliant without second-guessing every step.

All employers who withheld taxes on compensation during 2025 are required to file BIR Form 1604-C together with the Alphalist of Employees on or before January 31, 2026.

If you miss the deadline or submit incorrect or inconsistent information, you may be subject to penalties under Section 250 of the National Internal Revenue Code (NIRC).

What are the possible penalties? 

• Financial penalties for late filing: This may include surcharges and interest imposed on late or non-filed annual information returns.
• Compromise penalties for incorrect or incomplete data: Errors such as invalid TINs, mismatched totals, or inconsistencies with your monthly BIR Form 1601-C filings can result in compromise penalties, even if you file on time.
• Increased risk of a BIR audit: When your 1604-C totals do not reconcile with your Alphalist, Form 2316, or monthly remittances, it may trigger further review or a full tax audit.

Form 1604-C acts as the annual reconciliation of all compensation taxes withheld during the year, so the BIR treats accuracy just as seriously as timeliness. One mistake can undo months of correct monthly filings. This is why many employers prepare early or choose to automate the process to avoid last-minute errors, penalties, and unnecessary risks.

While these forms are submitted together, they serve different but connected purposes in your annual tax compliance.

• BIR Form 1604-C is like the cover sheet. It summarizes all compensation paid to employees and all taxes withheld during the year.
• The Alphalist of Employees is the detailed report behind that summary. It lists every employee, their total compensation, non-taxable benefits, and the exact tax withheld.

From the BIR’s perspective, these forms serve an important role: they reconcile the monthly withholding taxes reported in your BIR Form 1601-C. This ensures that what you withheld from employees throughout the year matches what you declare annually.

If you prefer filing BIR Form 1604-C and the Alphalist manually, it’s essential to follow each step carefully. This section walks you through the entire process, showing you exactly what data to prepare, which software to use, and how to validate everything before submission.

Even if you plan to automate later, understanding the manual process will help you avoid mistakes and double-check results.

Before you can start filling out forms, you must complete year-end payroll annualization. This means you have to:

• Calculate each employee’s total annual compensation
• Compare actual tax due vs. tax already withheld
• Adjust for any discrepancies in taxable and non-taxable income

Without this step, your 1604-C totals and Alphalist entries will be inaccurate.

Meanwhile, here’s a checklist of required data per employee:

• Full-year payroll register
• Year-to-date totals for taxable and non-taxable income (13th-month pay, benefits, allowances)
• Total tax withheld for the year
• Government contributions (SSS, PhilHealth, and Pag-IBIG)

You need two separate BIR tools to complete the manual filing:

1. Offline eBIRForms Package, used to prepare and submit BIR Form 1604-C.
2. Alphalist Data Entry and Validation Module, used to create the Alphalist .DAT file

After downloading, install both tools on a Windows computer. 

Tip: Always check the latest version (v7.x.x or newer). Using an outdated tool can lead to validation errors or failed submissions.

This is where most users encounter errors. The Alphalist Data Entry Module allows you to encode every employee’s details and generate the .DAT file required by the BIR.

Steps to create the DAT file:

1. Open the Alphalist software and create a new file
2. Enter employer information (TIN, registered name, contact details)
3. Add each employee and input:
   • Total taxable compensation
   • Non-taxable income
   • Total tax withheld
   • Employment status and TIN

The BIR uses cryptic column codes. Here’s a simple translation to make your life easier:

Schedule 1 (Employees Subject to Withholding Tax)

Schedule 2 (Employees Not Subject to Withholding Tax)

Translating the codes helps prevent validation errors and ensures totals in your DAT file match the 1604-C form.

Once all data is entered:

1. Click Validate in the Alphalist software
2. The system will check for errors such as:
   • Invalid TINs
   • Mismatched totals
   • Missing required fields
3. A successful validation message confirms the file is ready for submission

With your Alphalist DAT file validated, you can now fill out BIR Form 1604-C using the eBIRForms Offline Package. This form is the summary of all compensation and taxes withheld for the year.

Steps to complete 1604-C:

1. 1. Open eBIRForms and select BIR Form 1604-C
   2. Enter employer information:
      • Tax Identification Number (TIN)
      • Registered name and address
      • Contact details
   3. Enter total compensation and tax withheld:
      • Use the grand totals from your validated Alphalist DAT file
      • Ensure every total matches exactly, including taxable income, non-taxable income, and tax withheld.

1. Save your filled form before validation.

Once you have completed BIR Form 1604-C in the eBIRForms Offline Package, follow these steps:

1. Validate your form
   • Click Validate in the eBIRForms software.
   • The system will flag any missing or incorrect entries.
   • Fix all errors before proceeding to submission.
2. Submit 1604-C electronically
   • Click Submit/Send to file the form online.
   • You will receive a confirmation message or acknowledgment indicating that your submission was successful.
   • Save a PDF or screenshot of this confirmation for your compliance records.

The Alphalist .DAT file is submitted separately from the 1604-C form:

• Attachment: Only include the validated .DAT file.

File naming: Use the BIR-prescribed naming convention, commonly structured like:
H1604C<TIN><YYYYMMDD>.DAT

• Replace <TIN> with your company’s TIN and <YYYYMMDD> with the submission date.
• Email submission: Send the DAT file to the BIR eSubmission address ([email protected])
• Acknowledgment: You may receive an email confirmation indicating that the file was successfully received and validated. Save this email as proof of submission.

Even when you follow every step, filing BIR Form 1604-C and the Alphalist can trigger validation errors. These errors are usually easy to fix once you understand what they mean and how to correct them.

Filing BIR Form 1604-C can be straightforward, but there are common pitfalls you need to be aware of and avoid:

1. Forgetting Terminated Employees. Some employers leave out employees who resigned early in the year. This matters because the Alphalist must include all employees who received compensation during the taxable year, even if they left in January.
2. Mismatching 1601-C Totals. This happens when the sum of all monthly BIR Form 1601-C remittances does not match the total tax withheld on 1604-C. Note that the BIR uses 1604-C to reconcile monthly withholding, and any mismatch can trigger validation errors or a review.
3. Incorrect Employee Status Codes. This means using the wrong code for employees, such as R (Regular) or C (Casual). Wrong codes can lead to errors in tax computation and form rejection.
4. Errors in Non-Taxable Income. This involves miscalculating benefits that are exempt from tax, such as 13th-month pay or allowances under the ₱90,000 threshold. Incorrectly including or excluding non-taxable income will throw off your totals and may require corrections.
5. Ignoring BIR Form 2316. The Alphalist totals don’t match what’s on employees’ Form 2316. To avoid this, ensure that all compensation and tax figures in the Alphalist exactly match each employee’s Form 2316.

For additional step-by-step guidance on annualization and related BIR compliance, visit Sprout’s Compliance Hub. It covers payroll, freelancers, and supplier payments to help HR teams and business owners stay accurate and compliant.

Filing BIR Form 1604-C and the Alphalist manually can be stressful, time-consuming, and prone to errors. Now that you’ve seen how complicated the process is, there’s a simpler, faster, and safer way: automating your payroll and compliance with Sprout Payroll.

With Sprout Payroll, you can complete your year-end filings in just a few clicks, without worrying about manual calculations or software glitches. It automates all the complexity of BIR Form 1604-C and Alphalist preparation, from annualizing payroll to generating fully validated DAT files ready for submission. 

Late submission can result in surcharges, interest, and compromise penalties under Section 250 of the NIRC. The BIR may also flag your company for review or audit.

As of 2026, the latest version is v7.x.x. Always download the official module from the BIR website to ensure you’re using the most current version.

Yes. If errors are discovered after submission, you can file an amended 1604-C through eBIRForms. Make sure to indicate it as “AMENDED” and provide the correct totals from your Alphalist.

1604-C covers compensation income, while 1604-F applies to final withholding taxes.

The deadline for submitting the Alphalist (BIR Form 1604-C) is typically January 31 of the following year, which covers the previous year’s compensation and taxes. See our step-by-step BIR 1604-C Alphalist filing guide for detailed instructions.