Year-End Inventory List: What the BIR Expects Before January 30
If your business keeps stock, materials, real estate units, or construction work in progress, the BIR expects a year-end inventory list within 30 days after you close your books. Here is who it covers, what goes in it, how to submit it, and how to get ready before December 31.
Businesses that keep inventory must submit an annual inventory list to their BIR Revenue District Office (or Large Taxpayers office) not later than 30 days after the close of the taxable year. For a calendar year ending December 31, 2026, that is January 30, 2027 (a Saturday, so plan to submit by Friday, January 29). Under RMC No. 57-2015, as amended by RMC No. 8-2023, the list and industry schedules are submitted in soft copy on a labeled DVD-R or USB flash drive, with a notarized certification. Using the wrong format can mean the BIR treats it as not received.
The year-end rush is close. Between closing entries, alphalists, and the first filings of January, the inventory list is easy to leave until the last week. But the list depends on a physical count taken at year-end, and that count cannot be redone in January. If you plan now, in November, the January 30 submission becomes a formality instead of a scramble.
Who this is for
This requirement is most relevant to businesses that keep inventory, for example:
- Manufacturers with raw materials, goods in process, finished goods, and supplies
- Wholesalers, distributors, and retailers with stock-in-trade (merchandise held for sale)
- Real estate dealers and developers with lots, units, and projects held for sale
- Construction companies and building contractors with projects and materials in progress
RMC No. 57-2015 also requires additional industry schedules from taxpayers with tangible asset-rich balance sheets, which the BIR describes as often having at least half of total assets in working capital assets such as accounts receivable and inventory.
Service-only business with no inventory?
A pure service business that does not hold stock-in-trade, materials, or supplies for sale may generally have nothing to list. Practice varies, though, and some RDOs ask for a nil (no inventory) submission. If you are not sure where your business falls, check with your RDO or ask BGB to review it before January.
What the inventory list is and where the rule comes from
- Revenue Regulations No. V-1 (Bookkeeping Regulations), Section 13. Businesses that pay internal revenue taxes must keep a book of inventories showing, in detail, the quantity, description, unit cost, and total cost of every item of stock-in-trade, materials, supplies, and other goods on their premises at the close of the calendar year or accounting period. Subsequent inventories are due not later than 30 days after the close of the year. The Commissioner may extend this in meritorious cases.
- RMC No. 57-2015 (July 21, 2015). Sets the prescribed formats, adds industry schedules, and requires the data to be reconciled with the financial statements and annual income tax return. It also states that a submission that does not follow the prescribed format is deemed not received and may lead to penalties under Sections 250 and 255 of the Tax Code.
- RMC No. 8-2023 (January 20, 2023). Amends Section 2 of RMC No. 57-2015: soft copies only (printed hard copies removed), saved on a labeled DVD-R or USB flash drive, with the notarized certification in Annex D.
Deadline: calendar year vs. fiscal year
| Accounting period | Inventory as of | Submit not later than |
|---|---|---|
| Calendar year 2026 | December 31, 2026 | January 30, 2027 (Saturday; we recommend Friday, January 29, 2027) |
| Fiscal year ending March 31, 2027 | March 31, 2027 | April 30, 2027 |
| Fiscal year ending June 30, 2027 | June 30, 2027 | July 30, 2027 |
| Any fiscal year | Last day of your fiscal year | 30 days after year-end |
BIR tax calendars have generally moved deadlines that fall on weekends or holidays to the next working day. Do not rely on that for a submission that needs a notarized document and a physical drive. Aim to file a few working days early.
What to include, and the industry schedules
At minimum, your inventory list should show, per item, the description, quantity, unit, unit cost, and total cost, plus your valuation method. Totals should agree with the inventory balance in your books, financial statements, and income tax return. RMC No. 57-2015, as amended, prescribes these formats:
| Annex | For | What it typically asks for |
|---|---|---|
| Annex A | Manufacturing, merchandising, or retail companies | Inventory on hand by item: description, quantity, unit cost, total cost, and valuation method |
| Annexes B and B-1 | Real estate companies | Project-level details, contracted sales, and movement of receivables from beginning to end of year |
| Annex C | Construction industry | Per project: client, contract price, receivable movement, billings and collections for the year, estimated gross profit, and percentage of completion |
| Annex D | All covered taxpayers | Notarized certification, signed by the authorized representative, that the data on the DVD-R or USB is true and correct |
If your business is not in one of these industries but keeps inventory, RMC No. 57-2015 says to use the prescribed format that applies to your existing inventory.
Real estate and construction: start early
Annexes B, B-1, and C need much more data than a simple stock list. Project schedules, contract balances, collections, and percentage-of-completion reports from your engineers all have to be ready and consistent within 30 days of year-end.
How to submit
- Prepare the soft copy of the inventory list and applicable schedules in the prescribed annex format.
- Save it to a DVD-R or USB flash drive and label it properly (for example: registered name, TIN, RDO, and "Inventory List as of December 31, 2026").
- Sign and notarize the certification (Annex D). It must be signed by your authorized representative and certify that the data on the drive is true and correct.
- Submit to the right BIR office: your RDO if you are a non-large taxpayer, or the relevant Large Taxpayers office if you are classified as large.
- Bring authority papers if someone else submits, such as a Special Power of Attorney, Secretary's Certificate, or Board Resolution, as applicable.
- Keep your received copy of the certification or transmittal on file.
Check your RDO's practice
RMC No. 8-2023 specifies a DVD-R or USB soft copy with a notarized certification. Receiving practices can still differ by RDO, for example on preferred media, labeling, or how many copies of the certification to bring. Call or check with your RDO ahead of time.
Year-end checklist
- Now (November): schedule the physical count. Set the count date as close to December 31 as possible, assign counters, and freeze movements during the count.
- Clean up the item master. Fix duplicate codes, units of measure, and obsolete or slow-moving items before the count.
- Count and document. Use count sheets or tags, sign-offs, and photos for high-value items. Note goods in transit, on consignment, or held by third parties.
- Reconcile to the books. Match the count to your general ledger and subsidiary records, investigate variances, and book adjustments before closing.
- Make sure the numbers will agree with your financial statements and annual income tax return. If audit adjustments come later, keep a clear reconciliation.
- Prepare the annex format that fits your industry (A, B and B-1, or C).
- Save the soft copy, notarize Annex D, and prepare any SPA or Secretary's Certificate.
- Submit by January 29, 2027 (calendar year) and file your received copy.
How BGB can help
BGB can help you plan and observe your year-end count, reconcile inventory to your books, prepare the inventory list and the right BIR annex schedules, and coordinate the notarized certification and submission to your RDO. If you are not sure whether your business needs to file at all, we can review that too. Call us at (02) 8631-8618 or connect with BGB.
Frequently asked questions
Who has to submit the annual inventory list?
Businesses that keep inventory, such as manufacturers, wholesalers, distributors, retailers, real estate dealers and developers, and construction companies and building contractors. Section 13 of Revenue Regulations No. V-1 requires businesses to keep a book of inventories, and RMC No. 57-2015, as amended by RMC No. 8-2023, sets the format and adds industry schedules for taxpayers with tangible asset-rich balance sheets.
When is the deadline for the 2026 inventory list?
Not later than 30 days after the close of the taxable year. For calendar-year taxpayers closing on December 31, 2026, that is January 30, 2027. January 30, 2027 falls on a Saturday. BIR tax calendars have generally moved weekend deadlines to the next working day, but we recommend submitting by Friday, January 29, 2027.
What if we use a fiscal year?
The 30-day rule still applies, counted from the end of your fiscal year. For example, a fiscal year ending June 30 means the inventory list is due by July 30.
Do we still need to submit printed hard copies?
Under RMC No. 8-2023, the inventory list and schedules are submitted in soft copy only, saved on a properly labeled DVD-R or USB flash drive, together with a notarized certification (Annex D). Some RDOs may have their own receiving practices, so confirm with your RDO before submission day.
What happens if we use the wrong format?
RMC No. 57-2015 states that a submission that does not follow the prescribed format is deemed not received by the BIR and may be a ground for penalties under the Tax Code (Sections 250 and 255).
We are a service business with no inventory. Do we need to file?
Generally, the inventory list is for businesses that actually keep inventory. A pure service business with no stock-in-trade, materials, or supplies held for sale may generally have nothing to list. Some RDOs, however, ask for a nil (no inventory) submission. If you are unsure, check with your RDO or ask us to review your situation.
Official sources & references
- Revenue Regulations No. V-1 (Bookkeeping Regulations), Section 13, Records of Inventories, as quoted in RMC No. 57-2015
- RMC No. 57-2015 (July 21, 2015), Submission of Inventory List and Other Reporting Requirements: full text (PDF)
- RMC No. 8-2023 (January 20, 2023), Revised Provision on the Submission of Inventory List and Other Reporting Requirements Pursuant to RMC No. 57-2015: BIR (PDF) · annexes A to D via KPMG Philippines
- Bureau of Internal Revenue: bir.gov.ph
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