One-Time Abatement for Micro Taxpayers under BIR RR No. 4-2026 and RMC No. 84-2026: what is covered, what counts toward the P80,000 threshold, what to file and pay, and when

Revenue Regulations No. 4-2026 lets a micro taxpayer (gross sales for the year below P3,000,000, as defined under RR No. 8-2024) apply to have delinquent accounts, assessments and open stop-filer cases that existed as of 31 December 2025 abated, taxes and penalties included, where the delinquent or assessed basic tax or penalties for a taxable year are not more than P80,000 (Sections 2 to 4). The application is filed on paper with the taxpayer's Revenue District Office, one per taxable year, with a P5,000 abatement fee per application, until 31 December 2026 unless the Secretary of Finance extends the period (Sections 6 to 8). Revenue Memorandum Circular No. 84-2026, dated 23 July 2026, answers 29 questions on how the rules apply. This Drop reads both issuances section by section with the BIR's own worked examples and a worksheet that applies the RMC's arithmetic; it is a reading, not tax advice and not a determination, since the Certificate of Existence of Outstanding Tax Liability/ies and BIR records control coverage and the Revenue District Office decides each application.

P80,000per taxable year: the most that delinquent or assessed basic tax or penalties may total for a covered application (RR Section 4)

P5,000abatement fee per application, one application per taxable year, paid on BIR Form No. 0605 within five working days of filing (RR Section 7; RMC Q7, Q14)

31 Dec 2026last day to file, unless the Secretary of Finance extends the period; the filing date, not the approval date, decides timeliness (RR Section 8; RMC Q24)

Status of the issuances. RR No. 4-2026 is dated 18 June 2026 on its signature page and is listed by the BIR as issued on 22 June 2026. Section 10 provides that it takes effect fifteen days after publication in the Official Gazette or on the BIR website, whichever comes first; the publication date, and so the exact date of effectivity, is not stated in the issuances retrieved for this Drop. RMC No. 84-2026 is dated 23 July 2026 and states that it takes effect immediately. As of 6 September 2026 no extension of the availment period and no later issuance touching RR No. 4-2026 appeared in the BIR's 2026 listings; check the BIR website before relying on any date here.

Key findings

The program covers delinquent accounts, assessments (preliminary or final, disputed or not) and open stop-filer cases that existed as of 31 December 2025, including those of micro taxpayers who have ceased business (RR Section 3). Only obligations whose statutory due dates fell on or before 31 December 2025 are covered; the annual income tax return for taxable year 2025, due in 2026, is not (RMC Q14).
The P80,000 threshold is applied per taxable year to the aggregate of all tax types, withholding taxes included (RR Section 4; RMC Q14, Q19). According to the RMC, unpaid basic tax and compromise penalties count toward it while surcharges and interests do not, yet surcharges and interests incidental to a basic tax that is abated are abated with it (RMC Q12, Q18). Payments made on or before 31 December 2025 are applied first to interests, surcharges and compromise penalties and any remainder to basic tax (RMC Q21).
Each taxable year needs its own application on BIR Form No. 2121, filed on paper with the taxpayer's RDO (head-office RDO for taxpayers with branches), its own P5,000 fee on BIR Form No. 0605 (ATC MC350 for individuals, MC351 for non-individuals; tax type code "MA"), and its own Certificate of Existence of Outstanding Tax Liability/ies, which the issuing office releases within two working days of the request (RR Sections 6, 7; RMC Q2, Q3, Q5, Q6, Q7, Q14).
Three five-working-day clocks run in sequence: the fee is paid within five working days of filing; proof of payment is submitted within five working days of payment (missing this voids the application, which may be re-filed within the period); and the RDO issues the Certificate of Availment within five working days of receiving and verifying the proof (RR Sections 7, 9; RMC Q7, Q26).
Filing suspends collection enforcement for the covered taxable year while a complete application is pending, does not withdraw a pending administrative appeal, and triggers no field audit; the Certificate of Availment closes only the covered cases for the year it names, is not a tax clearance, and gives rise to no refund or tax credit (RMC Q10, Q22, Q25, Q26, Q28). The RMC lists nine grounds on which an application may be denied (Q23).

Who is a micro taxpayer for this program (RR Section 2; RMC Q1, Q4)

Micro taxpayer: A taxpayer whose gross sales for the year is less than Three Million Pesos (P3,000,000.00), as defined under RR No. 8-2024. For mixed income earners, gross sales covers only business income, excluding compensation income earned under an employer-employee relationship (RR Section 2(a)).
How classification is determined: By the classification reflected in the Internal Revenue Integrated System - Taxpayer Registration System (IRIS-TRS) as of 31 December 2025. Taxpayers may verify it through the BIR Online Registration and Update System (ORUS) "BIR-Registered Business Search and Taxpayer Classification Inquiry" facility at orus.bir.gov.ph/search/businessname, or by coordinating with their Revenue District Office (RMC Q1). The controlling fact is the recorded classification, not a taxpayer's own computation of gross sales.
Mixed income earners: A taxpayer earning both compensation income and business income may avail, as long as the taxpayer is classified as a micro taxpayer and the liability sought to be abated is covered under Sections 3 and 4 of the RR (RMC Q4).
Ceased businesses: The program expressly includes open stop-filer cases of micro taxpayers who have ceased business operations, meaning the point when operations stopped (RR Sections 1, 2(d), 3(c)).

Other terms defined in RR Section 2

Delinquent account: The amount of tax due on or before 31 December 2025 from a taxpayer who failed to pay it within the time prescribed, arising from a self-assessed tax or from a deficiency assessment that has become final and executory.
Assessment, whether preliminary or final, disputed or not: A tax assessment in a Preliminary Assessment Notice or Final Assessment Notice, or reiterated in a Final Decision on Disputed Assessment, issued on or before 31 December 2025 and not yet final and executory.
Stop-filer case: A case where a registered taxpayer failed to file and/or submit the required tax return and other tax information within the prescribed due date.

What is covered: the nine case types and where the certificate comes from (RR Sections 3, 4; RMC Q3)

Section 3 applies the abatement to all delinquent accounts, assessments and open stop-filer cases as of 31 December 2025. Section 4 lists the cases of micro taxpayers with delinquent or assessed basic tax or penalties of not more than P80,000 that may be applied for abatement. For each, the RMC's Q3 table names the office that issues the Certificate of Existence of Outstanding Tax Liability/ies (CEOTL), which the taxpayer requests before filing and which the office issues within two working days.

Covered case types under RR No. 4-2026 Section 4, the application form line each maps to (BIR Form No. 2121, Part II), and the CEOTL issuing office per the table in RMC No. 84-2026 Q3. The RMC's table splits RATE and fraud cases and abatement-application cases into their own rows, so it has ten rows against the RR's nine paragraphs.
RR Section 4 case	Form line	CEOTL issuing office (RMC Q3)
(a) Delinquent accounts	Item 14	Regional Collection Division
(b) Cases with administrative protest pending in the Regional Office, RDO, Legal Service through the Appellate Division, Collection Service, Enforcement Service and other National Office offices	Item 15	Office of the Regional Director through the Regional Assessment Division; Revenue District Office; Appellate Division; Collection Service; Enforcement and Advocacy Service; or other National Office offices (for cases with preliminary or final assessment, unprotested or with pending protest)
(c) Tax cases disputed before the Department of Justice and the courts (MTC, RTC, CTA, CA, SC), including decided cases not yet final and executory	Item 16	Legal Division of the Regional Office, or Litigation Division in the National Office
(d) Tax collection cases filed with the courts	Item 17	Legal Division of the Regional Office, or Litigation Division in the National Office
(e) Cases with a pending request for compromise settlement under evaluation by the TWG-NEB, TWG-REB, NEB or REB	Item 18	Regional Collection Division (the RMC's row covers pending compromise settlement or abatement applications under RR Nos. 13-2001 and 30-2002)
(f) Cases with a pending request for abatement under RR No. 13-2001	Item 19	Regional Collection Division (same row; the RMC's table also names RR No. 30-2002, which Section 4(f) of the RR does not)
(g) Criminal violations not yet filed in court, other than RATE Program and other tax fraud cases	Item 20	Revenue District Office
(g) RATE Program and other tax fraud cases not yet filed in court, where the Commissioner or an authorised representative allows availment on meritorious grounds	Item 20	Legal Division of the Regional Office, or Prosecution Division in the National Office (certifying that no case has been filed in court)
(h) "Accounts Payable or Due to BIR" accounts recorded or acknowledged in the taxpayer's books of accounts	Item 21	Regional Collection Division (certifying that the payable does not appear in the records as a delinquent account)
(i) No basic tax due, but the threshold amount involves penalties due (the RMC Q3 table adds: except interest and surcharge accessory to a deficiency tax assessment)	Item 22	Revenue District Office
Open stop-filer cases (RR Section 3(c))	Item 22 where only penalties are due	Revenue District Office

Section 4 states that the P80,000 threshold refers to the total basic tax liabilities and/or penalties arising from violations of the NIRC covering all of these cases for a taxable year. Two clarifications from the RMC: taxes from one-time transactions such as a sale of real property, a sale of shares or a donation are covered if the person statutorily liable is a micro taxpayer, the liability is within Section 4 and the certified liability as of 31 December 2025 does not exceed P80,000 (Q11); and RATE and other tax fraud cases are as a rule not covered, but may be if the Commissioner or an authorised representative allows it on meritorious grounds, with the written approval submitted with the application (Q13).

The P80,000 threshold: what counts and what does not (RR Section 4; RMC Q12, Q14, Q18, Q19, Q20, Q21)

Section 4 of the RR speaks of "delinquent or assessed basic tax or penalties" of not more than P80,000. The composition rule below is the RMC's reading and is attributed to it.

Threshold composition per RMC No. 84-2026, applied per taxable year to all tax types together.
Amount	Counts toward P80,000?	Abated if the application is approved?	Citation
Unpaid basic tax, all tax types for the year, withholding taxes included	Yes	Yes, if within the threshold	RMC Q12, Q18, Q19
Compromise penalties (Annex A of RMO No. 7-2015, as amended)	Yes	Yes	RMC Q12, Q18
Open case penalties for unfiled returns	Yes	Yes	RMC Q12, Q14, Q15 (the Q14 and Q15 illustrations test open case penalties against the threshold year by year)
Surcharges	No	Yes, when incidental to a basic tax that is abated	RMC Q12, Q18
Interests	No	Yes, when incidental to a basic tax that is abated	RMC Q12, Q18
Payments made on or before 31 December 2025	Applied first against interests, surcharges and compromise penalties, then any remainder against basic tax; the basic tax after that application is what is measured. Amounts already paid are neither refunded nor credited.		RMC Q21, Q22

One taxable year at a time. The threshold, the application and the P5,000 fee are all per taxable year; a taxpayer may choose which years to apply for, and years without an application or fee remain subject to the regular enforcement process (RMC Q14).
All unpaid deficiency taxes for the taxable year must be included in the application; leaving any out is a ground for denial (RMC Q20). A taxpayer with basic taxes of P80,000 income tax, P50,000 VAT and P2,500 expanded withholding tax for one year (P132,500 in total) exceeds the threshold and may not apply for the income tax alone (RMC Q19, Q20).
Unpaid penalties aggregating P100,000 for a taxable year do not qualify (RMC Q15).

Threshold worksheet (a reading of the issuances, not a determination)

Enter the amounts shown on your Certificate of Existence of Outstanding Tax Liability/ies for one taxable year. This worksheet applies the arithmetic stated in RMC No. 84-2026 (Q12, Q14, Q18, Q19 and Q21) to the figures you enter and shows the amount those rules would count and whether it is at or below the P80,000.00 threshold in Section 4 of RR No. 4-2026. It is a reading of the issuances, not tax advice and not a determination by the BIR or by the publisher. The CEOTL and the BIR's records control whether your liabilities are covered, and the Revenue District Office decides the application on the grounds listed in RMC Q23. The threshold is only one requirement, alongside classification as a micro taxpayer as of 31 December 2025 in IRIS-TRS, timeliness, coverage under Section 4, a complete application, payment of the fee and the absence of misrepresentation. Nothing you enter leaves your browser; the worksheet asks for no name, TIN or address.

Unpaid basic tax for the taxable year, all tax types together (pesos)

Compromise penalties, including open case penalties (pesos)

Surcharges (pesos)

Interests (pesos)

Payments made on or before 31 December 2025 that the amounts above do not yet reflect (pesos; leave 0 if the CEOTL figures are already net of payments)

Enter figures and choose "Apply the RMC's arithmetic". The result will show the allocation of any payment (RMC Q21), the amount the RMC's rules would count (unpaid basic tax plus compromise penalties after that allocation; RMC Q12, Q18) and whether that amount is at or below P80,000.00 (RR Section 4).

The BIR's worked examples, as printed in RMC No. 84-2026

These illustrations are the BIR's own, reproduced with their figures as printed and their Q&A numbers. Conclusions in this table are the RMC's.

Illustrations in RMC No. 84-2026 (all figures in pesos).
Q&A	Facts as printed	Amount the RMC counts toward P80,000	The RMC's conclusion
Q8	Delinquent income tax, TY 2020: basic tax 65,000; interests and surcharge 25,000; total 90,000. A compromise offer of 10,000 was paid under a still-pending compromise settlement application.	The RMC applies no threshold test in Q8; it illustrates the treatment of the earlier compromise payment	The 10,000 is not refunded, credited or applied against the fee but is deducted from the basic tax due; the 5,000 fee is still paid; on payment and approval, outstanding liabilities of 80,000 (90,000 minus 10,000) are cancelled.
Q9	Income tax, TY 2021: basic tax 45,000, already paid in full under a pending RR No. 13-2001 abatement application; surcharge and interest 40,000; compromise penalties 43,500; total 128,500.	43,500 compromise penalties (the basic tax was already paid; interests and surcharge are excluded)	Under Section 4(i) the compromise penalties are tested against the threshold and are below 80,000, so the RMC states the taxpayer is qualified; the basic tax paid remains valid and is not refunded or credited; the 5,000 fee is still paid; 83,500 (128,500 minus 45,000) is cancelled.
Q14	Mr XYZ ceased a water refilling business in 2021 without cancelling his registration. Open case penalties: 15,000 (TY 2021); 20,000 each for TY 2022, 2023, 2024 and 2025; 7,000 (TY 2026).	Tested year by year; each of 2021 to 2025 is below 80,000	He may avail for 2021 to 2024, and for 2025 if those penalties arose from returns due in 2025, but not for 2026, which did not exist as of 31 December 2025. Assuming 2025 qualifies: five applications, five fees of 5,000 (25,000 in total), five Certificates of Availment, and penalties totalling 95,000 cancelled.
Q15	Unpaid penalties from open cases and Tax Code violations totalling 100,000 for the entire taxable year.	100,000	Not qualified: the aggregate exceeds the threshold.
Q17, scenario 1	After filing unfiled returns, TY 2021 liabilities still due as of 31 December 2025 per the CEOTL: basic tax 50,000; surcharge 12,500; interest 15,000; compromise penalties for non-filing 10,000; total 87,500.	60,000 (50,000 plus 10,000)	Within the threshold; the RMC states Mr XYZ is qualified, provided all other requirements are met.
Q17, scenario 2	Basic tax 95,000; surcharge 23,750; interest 28,500; compromise penalties for non-filing 10,000; total 157,250.	105,000 (95,000 plus 10,000)	Exceeds the threshold; not qualified.
Q18	ABC Corporation, TY 2023: basic deficiency tax 60,000; surcharge 15,000; interest at 12 percent per annum 24,000; compromise penalty 15,000; total 114,000.	75,000 (60,000 plus 15,000)	Within the threshold; on payment of the 5,000 fee and approval, the assessed tax with its incidental interest and surcharge and the non-filing penalty, 114,000 in all, are cancelled.
Q19, Q20	Ms NKS, TY 2019, per the FLD/FAN: basic tax 80,000 income tax, 50,000 VAT, 2,500 expanded withholding tax (total 132,500); interest 47,700.	132,500 aggregate basic tax	Exceeds the threshold; not qualified. She may not apply for the income tax assessment alone (Q20, which cross-refers to "Q15" as printed although the facts are Q19's).
Q21	NX Inc., TY 2023: basic tax 120,000; surcharge 18,000; interest 22,000; compromise penalties 10,000; total 170,000. A partial payment of 90,000 on 31 December 2025.	80,000 basic tax after the payment is applied 18,000 to surcharge, 22,000 to interest, 10,000 to compromise penalties and 40,000 to basic tax	Outstanding basic tax as of 31 December 2025 does not exceed 80,000; the RMC states NX Inc. is qualified, provided all other requirements are met; on approval the 80,000 basic tax is cancelled.
Q22	NT Corporation, TY 2023: basic tax 60,000; surcharge 9,000; interest 11,000; total 80,000. A partial payment of 40,000 on 13 November 2025 applied 9,000 to surcharge, 11,000 to interest and 20,000 to basic tax.	40,000 outstanding basic tax	Within the threshold even before the payment; the payment is not refunded and is not a tax credit.

How to apply, step by step (RR Sections 6, 7, 9; RMC Q2, Q3, Q5, Q6, Q7, Q26)

Check the classification. The classification recorded in IRIS-TRS as of 31 December 2025 governs; verify it through the ORUS classification inquiry or with the RDO (RMC Q1).
Request the CEOTL. For each covered case, request the Certificate of Existence of Outstanding Tax Liability/ies from the issuing office the RMC's Q3 table names (see the table above). The issuing office issues it within two working days of the request. The CEOTL shows the outstanding liability as of 31 December 2025, the tax types and taxable years, and other information needed to determine qualification, and it is controlling for whether liabilities are covered (RMC Q3).
Complete BIR Form No. 2121, one per taxable year. Specify the tax types and basic amount due, excluding interest, for each covered case in Part II, Items 14 to 22, with the total at Item 23; where a case involves several tax types, indicate all of them and enter the aggregate amount for that case. Tick the ATC in Item 4: MC350 for individuals, MC351 for non-individuals (the form prints "Corporate"). Failure to specify tax types and basic amounts for any covered case results in denial (RR Section 6; RMC Q5, Q6). The RMC names the form as BIR Form No. 2121; the form as posted is headed "One-Time Abatement for Micro Taxpayers Application Form" and does not print a number.
File on paper with the RDO where the taxpayer is registered, with the complete documents listed below; taxpayers with multiple branches file with the RDO of the head office. Only applications with complete documentary requirements are received and processed. All information is subject to verification against the Bureau's records (RR Section 6; RMC Q2, Q5).
Pay the P5,000 fee within five working days of filing on BIR Form No. 0605, electronically or manually in accordance with RR No. 4-2024 as clarified by RMC No. 87-2024: ATC in Item 6, tax type code "MA" in Item 8 regardless of the tax types involved, and P5,000 in Item 21. The stamped "Received" copy of the application is sufficient basis for payment; no prior approval of Form 0605 is required (RR Section 7; RMC Q6, Q7).
Submit proof of payment to the RDO within five working days of payment. Failure to do so automatically voids the application, without prejudice to re-filing within the availment period (RR Section 7; RMC Q7, Q23).
Receive the Certificate of Availment, issued by the RDO within five working days from receipt and verification of the proof of payment, signed by the Revenue District Officer or, in his absence, the Assistant Revenue District Officer, with a control number recorded in the RDO's registry. It is the basis for the Authority to Cancel Assessment (RR Section 9; RMC Q26).

The fee is non-refundable. If the application is withdrawn or denied, the P5,000 is applied as partial payment of the taxes or penalties sought to be abated (RR Section 7; RMC Q7, Q23). Payments made on covered cases prior to the effectivity of the Regulations are not refundable (RR Section 5).

Documents to submit (RMC Q2)

The two lists are printed separately in the RMC and are reproduced separately here.

Individual micro taxpayer

Three copies of the duly accomplished One-Time Abatement for Micro Taxpayers Application Form (BIR Form No. 2121).
Photocopy of any valid government-issued ID (for example PhilSys, passport, driver's licence) showing name, address and birthdate.
Duly notarised Special Power of Attorney authorising the representative to process the application, if filed through an authorised representative.
Photocopy of any valid government-issued ID of the authorised representative.
Certificate of Existence of Outstanding Tax Liability/ies.
Copy of the PAN, FAN, FLD or FDDA with the corresponding details of assessments, if applicable.
Letter of withdrawal of an application for compromise or an application for abatement, duly received by the Regional Collection Division, if applicable.

Non-individual micro taxpayer

Three copies of the duly accomplished One-Time Abatement for Micro Taxpayers Application Form (BIR Form No. 2121).
Duly notarised board resolution or, for a one person corporation, written resolution, or secretary's certificate authorising the representative to process the application.
Photocopy of any valid government-issued ID of the sole stockholder of the OPC or of the corporate secretary.
Photocopy of any valid government-issued ID of the authorised representative.
Certificate of Existence of Outstanding Tax Liability/ies.
Copy of the PAN, FAN, FLD or FDDA with the corresponding details of assessments, if applicable.
Letter of withdrawal of an application for compromise or an application for abatement, duly received by the Regional Collection Division, if applicable.

For RATE and other tax fraud cases not yet filed in court, the written approval of the Commissioner or an authorised representative is submitted in addition (RMC Q13). This page does not host the form; obtain it from the BIR's issuance listing linked under Sources.

What availment does and does not do (RMC Q8, Q9, Q10, Q16, Q17, Q22, Q25 to Q29)

Pending administrative appeal (Q10): Filing is not a deemed withdrawal of a pending appeal against a PAN, FAN/FLD or FDDA. Resolution of the appeal is suspended while the application is pending; after the Certificate of Availment, the Authority to Cancel Assessment for the abated tax and penalties is issued; on denial, voidance or withdrawal, the suspension is lifted and the appeal resumes.
Collection enforcement (Q25): Suspended for the covered taxable year from the filing of the application with the complete requirements and while it remains pending; warrants and other measures are not implemented during evaluation. The suspension is lifted on denial, voidance or withdrawal.
Unfiled returns (Q16, Q17): Where open case liabilities qualify and there are no unpaid taxes due, the taxpayer may avail without filing the unfiled returns. A taxpayer who wishes to update and rectify records, active or ceased, may file the appropriate unfiled returns without that filing precluding availment.
Pending compromise or abatement applications (Q8, Q9): A taxpayer with a pending compromise settlement application, or a pending abatement application under RR No. 13-2001, may avail for the liabilities covered by that application after filing a withdrawal with the Regional Collection Division and submitting the received copy. Amounts paid under the earlier application are not refunded, credited or applied against the P5,000 fee; a compromise offer paid is deducted from the basic tax due, and basic tax paid under an RR No. 13-2001 application remains valid. The fee is still paid. Where a compromise docket is already with the TWG-REB, REB, TWG-NEB, NEB, the Accounts Receivable Monitoring Division or another office, the physical docket need not be returned to the RDO (Q8).
Refunds and credits (Q22): No refund or tax credit arises from availment. Amounts paid on covered cases on or before 31 December 2025 are applied against the liability but are not refunded or credited.
What the Certificate of Availment is and is not (Q26): Proof that the taxpayer has been determined to be qualified, has complied with the documentary requirements, has paid the fee, and that the covered liabilities are approved for abatement. It closes only the covered cases for the taxable year it names. It is not a tax clearance and does not by itself bar assessment of liabilities not covered, within the periods under Sections 203 and 222 of the Tax Code, provided that no penalties are imposed anew for open cases or violations under RMO No. 7-2015 that were already abated.
Closing a business registration (Q27): The Certificate may support an application for closure or cancellation of business registration, whose processing is not held in abeyance for cases already covered; but issuance of a Certificate does not by itself trigger closure, even for a micro taxpayer no longer operating, without the proper application under RMC No. 047-2026.
Audit (Q28): The application is evaluated solely on the documents submitted; RDO verification is limited to classification, the outstanding liability as of 31 December 2025, payment of the fee and compliance with the requirements. No field audit or new investigation is initiated by reason of the application; filing neither suspends nor waives audits or assessments for taxable years or cases not covered.
Confidentiality (Q29): Information disclosed in the application is covered by the confidentiality provisions of Section 270 of the NIRC.

Grounds for denial (RMC Q23)

The RMC states that an application for abatement "may only be denied on any of the following grounds". This is the RMC's statement of the grounds, not a guarantee about how any application will be decided.

Taxpayer classification: the applicant is not a micro taxpayer as of 31 December 2025.
Timeliness: the application was filed after 31 December 2026, unless the availment period has been extended by the Secretary of Finance on the Commissioner's recommendation.
Out of scope: the assessed tax or penalty did not exist as of 31 December 2025, that is, it arose from an obligation whose statutory due date fell after that date.
Out of coverage: the tax or penalty is not within the cases covered under Section 4 of the RR.
Threshold exceeded: the aggregate of all applicable covered cases exceeds P80,000.
Non-payment of the abatement fee within five working days from filing.
Incomplete application: tax types and basic amount due not specified for any covered case.
Lack of required approval: for RATE and other fraud cases not yet filed in court, the approval of the Commissioner or an authorised representative was not obtained.
Material misrepresentation or falsified information, in which case any availment already granted is void ab initio and the covered liabilities are revived, without prejudice to civil and criminal liability.

Non-submission of proof of payment within the prescribed period is not a ground for denial but automatically voids the application, without prejudice to re-filing within the availment period. Section 7 of the RR and RMC Q7 state that period as five working days from payment; the closing paragraph of Q23 prints "five (5) days" as printed in the source. Failure to include all unpaid covered liabilities for the taxable year is also a ground for denial (Q20).

Questions answered from the issuances

Is this a tax amnesty?: No. Both issuances call it a one-time abatement, and RMC No. 84-2026 grounds it in the Commissioner's authority under Section 204(B) of the Tax Code to abate or cancel a liability where administration and collection costs do not justify collection, in relation to the taxpayer classification under Section 21(B) as amended by Republic Act No. 11976 and implemented by RR No. 8-2024. No amnesty law is cited in either issuance.
Until when may an application be filed?: Until 31 December 2026, unless the Secretary of Finance extends the period on the recommendation of the Commissioner of Internal Revenue (RR Section 8; RMC Q23). An application filed on or before that date is timely even if it is processed or approved later (RMC Q24). As of 6 September 2026 no extension and no superseding issuance appeared in the BIR's 2026 listings; check the BIR website before relying on the date.
Does a taxpayer who stopped operating years ago and never filed returns have to file them first?: Not where the open case liabilities qualify and there are no unpaid taxes due (RMC Q16). The taxpayer may file them to regularise records without losing the ability to avail (Q17). The RMC's Q14 illustration walks through a water refilling business that ceased in 2021.
Can several years be covered?: Yes, with a separate application, a separate P5,000 fee and a separate threshold test for each taxable year (RMC Q14).
Are taxes on a one-time transaction, such as a property sale or a donation, covered?: Yes, if the person statutorily liable is a micro taxpayer, the liability is within Section 4 and the certified liability as of 31 December 2025 does not exceed P80,000 (RMC Q11).
Does filing stop collection?: Collection enforcement for the covered taxable year is suspended from the filing of a complete application and while it is pending, and resumes on denial, voidance or withdrawal (RMC Q25).
Will filing trigger an audit?: No field audit or new investigation is initiated by reason of the application; audits or assessments for uncovered years or cases are neither suspended nor waived (RMC Q28).

Sources

Bureau of Internal Revenue. Revenue Regulations No. 4-2026 (printed "No. 004-2026"), Prescribing Guidelines and Procedures for the Availment of a One-Time Abatement of Taxes and/or Penalties for Micro Taxpayers. Signed by Secretary of Finance Frederick D. Go on the recommendation of Commissioner of Internal Revenue Charlito Martin R. Mendoza; signature page dated 18 June 2026; listed by the BIR as issued 22 June 2026. Full text (PDF); Digest (PDF); application form listed with the RR on the BIR's 2026 Revenue Regulations page. Retrieved 6 September 2026.
Bureau of Internal Revenue. Revenue Memorandum Circular No. 84-2026, Clarifying Certain Provisions of Revenue Regulations No. 004-2026, dated 23 July 2026, 16 pages, 29 questions and answers. Full text (PDF); Digest (PDF); listed on the BIR's 2026 Revenue Memorandum Circulars page. Retrieved 6 September 2026.

Rules are quoted and paraphrased from RR No. 4-2026 and RMC No. 84-2026 with a section or Q&A citation on each, and each issuance is linked to the copy published by the Bureau of Internal Revenue. Policy Desk is a publisher on DropRegion and is not affiliated with, and this page is not endorsed by, the Bureau of Internal Revenue.

Methodology

Policy Desk retrieved the full texts, digests and application form from the BIR's published files. The full texts are scanned; their text was extracted by optical character recognition and checked against the text-native digests and the page images, including the date stamps, the CEOTL issuing-office table and the form's item numbers. Every rule was transcribed with its section or question number and re-checked in a verification pass independent of the drafting, which also re-added every figure in the RMC's illustrations.

The worksheet applies only the arithmetic the RMC states: unpaid basic tax and compromise penalties are counted, surcharges and interests are excluded (Q12, Q18), payments on or before 31 December 2025 are applied first to interests, surcharges and compromise penalties and then to basic tax (Q21), all tax types are aggregated (Q19), one taxable year at a time (Q14), and the result is compared with P80,000 (RR Section 4). It computes in the browser and stores nothing. Two printing defects in the source are reported as printed rather than corrected: RMC Q20 cross-refers to "Q15" while applying Q19's facts, and the closing paragraph of Q23 prints "five (5) days" where Section 7 and Q7 say working days. The reading is Policy Desk's and is not endorsed by the BIR or by DropRegion.

Limitations

The publication date of RR No. 4-2026, and so its exact effectivity date under Section 10, is not established from the issuances retrieved.
The Drop covers RR No. 4-2026 and RMC No. 84-2026 only. RR No. 8-2024 (taxpayer classification), RMC No. 047-2026 (closure of registration), RR No. 13-2001, RR No. 30-2002, RMO No. 7-2015 and the compromise rules are cited only as the two issuances cite them.
Whether a particular taxpayer's liabilities are covered is determined by the CEOTL and the BIR's records, and each application is decided by the RDO; nothing here is a determination for any reader.
This is a reading of two government issuances, not tax advice, and it makes no recommendation to file or not to file.
The BIR's 2026 listings were last checked on 6 September 2026 for an extension of the period or a later issuance; none was found, but the listings change.
The full texts are scanned documents read by OCR; the header, stamps, the Q3 table and all figures were checked against page images, and no material number was ambiguous.

Freshness

Freshness class F2. Checked and verified 6 September 2026 against both issuances. Events that would change this Drop: an extension of the availment period by the Secretary of Finance; a later Revenue Regulations, Revenue Memorandum Circular or Revenue Memorandum Order touching RR No. 4-2026; a correction to either issuance; and 31 December 2026 itself, after which the Drop must state that the period has ended unless extended. Next scheduled check: first week of October 2026, then monthly. Checking a source is not the same as changing this Drop; the version panel records changes.

Version

v1.1, 6 September 2026: seven corrections from the first evaluation (Q8 row no longer shows a counted figure the RMC does not print; Section 5 wording restored; RMC Q3 wording tagged in case (i); open case penalties cited to Q14 and Q15; "not tax advice" stated on the worksheet and in its result; front layer shortened; section ids and JSON-LD language tag). No rule or figure changed.

v1, 6 September 2026: first evaluated version. Drop ID D-20260906-3005. Corrections and later versions will be listed here.