How to Prepare the BIR Alphalist: A Practical 2026 Guide for PH Businesses

If you withheld any tax during the year — from an employee's salary or a supplier's invoice — the BIR expects you to prove it, name by name. That proof is the Alphalist. And every January, the same question lands in finance inboxes across the country: how do you actually prepare the BIR Alphalist without the file bouncing back?

This guide walks through what the Alphalist is, the two main types, how the withholding codes work, the file format the BIR requires, the 2026 deadlines, and the errors that most often get a submission rejected.

In summary: The BIR Alphalist is a per-payee schedule of everyone you withheld tax from, filed as an attachment to an annual return — the Alphalist of Employees with Form 1604-C, the Alphalist of Payees (EWT) with Form 1604-E. You prepare it as a validated .DAT file in the BIR's free Alphalist Data Entry Module (ADES). For 2025 income, 1604-C is due 31 January 2026 and 1604-E by 1 March 2026.

What is the Alphalist?

The Alphalist (short for "alphabetical list") is a structured, per-payee schedule of everyone from whom your business withheld tax during the taxable year. Think of it as the detailed backup to your annual withholding return: the return shows the totals, and the Alphalist shows who those totals belong to — each person or entity, their TIN, the income you paid them, and the tax you withheld and remitted.

The BIR uses it as a reconciliation tool. It cross-checks the monthly withholding taxes you remitted against the annual figures on each employee's or supplier's record. If your monthly remittances (via forms like 1601-C or 1601-EQ) don't tie out to your year-end Alphalist, that mismatch is exactly the kind of discrepancy that can trigger a review.

The Alphalist is not filed on its own. It is an attachment to an annual information return, and which return depends on the type of Alphalist.

What's the difference between the Alphalist of payees and employees? (The two main types)

There are two lists most SMEs need to prepare, and they usually sit with different teams.

1. Alphalist of Employees — attached to BIR Form 1604-C. This covers everyone you had an employer-employee relationship with during the year and withheld tax on compensation from. It is typically owned by HR or payroll. Inside it, employees are grouped into schedules by status — for example, regular employees, those who were terminated during the year, minimum-wage earners exempt from income tax, and those with a previous employer within the same year. Their compensation has to be broken out (basic pay, overtime, 13th-month and other non-taxable amounts) so the taxable figure is clear.

2. Alphalist of Payees — attached to BIR Form 1604-E. This covers income payments to third parties that were subject to Expanded Withholding Tax (EWT) — professionals, independent contractors, lessors, and other suppliers. It usually sits with accounting or finance, because it is built from your accounts-payable and disbursement records rather than payroll.

There is also a third list, the Alphalist of Payees subject to Final Withholding Tax, attached to Form 1604-F — used for income payments where the withholding is final (certain fringe benefits, dividends, royalties, and interest). Many smaller businesses only deal with 1604-C and 1604-E, but if you make final-tax payments, 1604-F applies too.

How do ATC (withholding) codes work in the Alphalist?

Every line in an EWT Alphalist has to carry an ATC (Alphanumeric Tax Code). The ATC tells the BIR what kind of payment it was and, implicitly, the correct withholding rate that should have applied.

Each code maps to a specific income-payment type. For example, professional fees paid to an individual carry a different ATC than rentals, and rentals carry a different one again from payments to contractors. The code also distinguishes an individual payee from a corporate one. Because the rate is baked into the code, using the wrong ATC effectively reports the wrong tax — so this is one of the most important fields to get right.

The practical rule: assign the ATC at the moment you record the payment and compute the withholding, based on the nature of the expense and whether the payee is an individual or a company. Don't leave it to be guessed at year-end. Always confirm the current code and rate against the BIR's published ATC table, since these are periodically updated.

What is the Alphalist Data Entry / DAT file format?

Here is where the mechanics get specific. You do not submit the Alphalist as a spreadsheet or PDF. The BIR requires a validated .DAT file, and there is only one sanctioned way to produce it: the BIR's free Alphalist Data Entry and Validation Module (ADES), a Windows desktop application you download from the BIR website. Always use the latest version (v7.x or newer).

The workflow is roughly:

1. Install the current Alphalist Data Entry Module.
2. Enter your details as the withholding agent (TIN, registered name, contact information).
3. Enter each payee or employee line — TIN, name, income amounts, tax withheld, ATC (for payees) or employment status (for employees).
4. Run validation. The module checks TIN formats, mandatory fields, and whether the math adds up. It will refuse to generate a file until every error is cleared.
5. Generate the .DAT file, which follows a strict naming convention (for example, H1604C<TIN><YYYYMMDD>.DAT for the 1604-C list).
6. Email the .DAT file to esubmission@bir.gov.ph with the required subject-line format (TIN, form type, taxable year).

Submission is only complete when the BIR emails back a Validation Report — often called the "Ticket." Keep it; that is your proof of filing. Separately, the annual return itself (1604-C, 1604-E or 1604-F) is filed through eBIRForms or eFPS.

What are the 2026 Alphalist deadlines?

For the 2025 taxable year filed in 2026:

• Form 1604-C + Alphalist of Employees: on or before January 31, 2026.
• Form 1604-E + Alphalist of Payees (EWT): on or before March 1, 2026.

Late or inaccurate submissions can draw penalties under Section 250 of the Tax Code. Note too that EWT payees also appear in your Quarterly Alphalist of Payees (QAP) filed with the 1601-EQ during the year — so the year-end list should reconcile to those quarterly submissions, not contradict them.

What common errors get Alphalists rejected?

• Missing or dummy TINs. Placeholder values like 000-000-000 are rejected on sight. Every line needs a valid TIN.
• Name formatting problems. Special characters, misplaced name suffixes, or fields in the wrong order will fail validation.
• Totals that don't reconcile with your monthly 1601-C / 1601-EQ remittances (or with employees' Form 2316).
• Omitted terminated employees who received compensation earlier in the year.
• Wrong employee status codes or misclassified minimum-wage earners.
• Incorrect ATC codes, which silently report the wrong withholding rate.

Most of these trace back to one root cause: the Alphalist is assembled by hand at year-end from data that was never captured cleanly in the first place.

How does software assemble the Alphalist automatically?

This is the difference between a painful January and a quiet one. When your accounting system captures the TIN, payment type, ATC, and tax withheld at the point each payment or payroll run is recorded, the year-end Alphalist becomes an export rather than a re-keying project.

That is the approach we built into LedgerQ. It assembles the Alphalist directly from your recorded payments and payroll, carrying the correct ATC codes through from when the transaction was booked — so totals reconcile to what you actually remitted, with no manual re-entry. LedgerQ is built BIR CAS-ready for Philippine businesses, and our AI assistant Sebee can answer questions about a payee's classification or a specific withholding entry as you go. (LedgerQ is BIR CAS-ready; it is not itself the BIR's Alphalist Data Entry module — you still generate and submit the official .DAT file through ADES.)

If year-end withholding compliance has been eating your team's January, book a demo and we'll show you how LedgerQ prepares the underlying data for you.

Frequently asked questions

Do I still need to file an Alphalist if I only have a few employees? Yes. If you withheld tax on compensation during the year, the Alphalist of Employees is required regardless of headcount, and it is submitted with Form 1604-C.

Can I just submit an Excel file instead of a .DAT file? No. The BIR only accepts the validated .DAT file produced by its Alphalist Data Entry and Validation Module (ADES). A spreadsheet on its own will not be accepted.

What is the difference between the 1604-E Alphalist and the QAP? The QAP (Quarterly Alphalist of Payees) is filed with your quarterly 1601-EQ during the year, while the 1604-E Alphalist is the annual consolidation of those EWT payees. Your year-end list should reconcile to the quarterly ones.

How do I know my Alphalist was actually accepted? Submission is confirmed only when the BIR emails back a Validation Report or "Ticket" after you send your .DAT file to esubmission@bir.gov.ph. Keep that email as your proof of filing.

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Related guides: Filing BIR Form 2550 (VAT) · BIR RELIEF & the SLSP DAT file · BIR CAS accounting software