Taxpayers seeking further advice regarding the recent suspension of all audit and other field operations by the Bureau of Internal Revenue (BIR) may turn to a new clarification issued by the agency for enlightenment.
Revenue Memorandum Circular (RMC) No. 109-2025 clarifies specific provisions of RMC 107-2025 dated November 24, 2025, which suspends all audit and other field operations by the revenue collection agency.
RMC 109-2025, released December 12, is a seven-page document providing further details on the scope of the audit suspension, including which cases are not covered under the suspension.
Earlier, the BIR announced the suspension of all field audits and related operations of the BIR beginning November 24 following “numerous complaints from taxpayers, stakeholders, and internal units regarding irregularities and inconsistencies, and to protect the integrity of audit operations.”
The suspension aims to correct these issues to develop a “transparent, standardized, and modernized audit framework,” RMC 107-2025 explained.
In the latest clarificatory circular, the BIR states that all taxpayers with ongoing audits or investigations based on duly issued Letters of Authority (LOAs) or Mission Orders (MOs)—individuals, corporations, estates, and business owners—are covered by this suspension, except for certain cases outlined in Section IV of RMC 107-2025.
Specific audit actions currently suspended include examining books, verifying records, conducting audit-related onsite visits, and any other steps taken under an LOA or MO. The RMC aims to suspend face-to-face meetings with taxpayers and onsite visits to taxpayers’ premises, explained the BIR.
As to specific activities suspended, they cover all ongoing and upcoming field audits and related field operations as well as the issuance of LOAs, MOs, Tax Verification Notices, and other notices related to examining and verifying taxpayers’ books of accounts, records and other related transactions.
Also suspended is the issuance of the Subpoena Duces Tecum, which is necessary to carry out an audit, said RMC 109-2025.
At the same time, the order amplifies on Section IV of RMC 107-2025 regarding the exceptions to the coverage of the suspension. Audit of cases, including the issuance of assessment notices, warrants and seizure notices, shall not be suspended under the following circumstances:
• Cases prescribing within six months from November 24, 2025
• Processing and verification of estate returns, donor’s tax returns, capital gains tax returns, and withholding tax returns on the sale of real properties or shares of stocks, together with the documentary state tax returns related to One-Time Transactions cases
• Examination or verification of tax liabilities of taxpayers retiring from business
• LOAs and MOs necessary for active criminal probes or risk-scoring anomalies that require immediate audit action
• Claims for refund where the issuance of an LOA is statutorily required
• Other matters or concerns where deadlines have been imposed or under the orders of the Commissioner of Internal Revenue
Besides further illuminating why auditing of the above cases are not suspended, RMC 109-2025 answers a number of related issues such as whether criminal tax cases are covered by the suspension; how taxpayers can voluntarily settle their deficiency taxes; and if the issuance to taxpayers of reminder letters and follow-up letters for compliance demands is also suspended under the RMC.
Finally, the new circular reiterates that normal audit activities will only resume once the revenue commissioner officially lifts the suspension order.
The BIR has previously said a comprehensive review of existing policies and procedures on audit operations will be conducted “to prevent exposure to potential abuse and operational weaknesses and to strengthen the credibility and defensibility of the BIR’s audit process.”
