2316 substituted filing: yes or no
At the bottom of BIR Form 2316 there is a box for substituted filing. Signing it means you are telling BIR that your employer's filing replaces your own annual return. This guide explains who can sign it, who must not, and what you do if you cannot. You will end up knowing whether you file a BIR Form 1700 or not.
What it means
Individuals who receive purely compensation income, regardless of amount, from only one employer in the Philippines for the year, with the tax withheld correctly (tax due equals tax withheld), are not required to file the annual return, BIR Form 1700. In its place, the employer's Certified List of Employees Qualified for Substituted Filing, filed with the BIR office and stamped "Received", counts as the filing (RR 11-2018, section 2.83.4).
Who qualifies
You qualify only if all of these are true (RR 11-2018, section 2.83.4):
- Your income was purely compensation. - You had one employer in the Philippines in the calendar year. - The tax withheld equals the tax due.
Who does not qualify
Situation · Substituted filing? · Source; Two or more employers in the year, at once or one after another · No · RR 11-2018, section 2.83.4(A); Tax withheld does not equal tax due, so there is a balance to pay or a refund · No · RR 11-2018, section 2.83.4(B); Other non-business, non-professional income on top of salary, not subject to final tax · No · RR 11-2018, section 2.83.4(C); One employer and tax correct, but your spouse falls under (A), (B) or (C) · No · RR 11-2018, section 2.83.4(D); Non-resident alien engaged in trade or business in the Philippines · No · RR 11-2018, section 2.83.4(E)
How it works in practice
If you qualify, you sign the 2316 right away to show you want substituted filing and return it to the employer for the employer's signature. The employer gives you the original and sends the duplicate to the BIR office by February 28 with the certified list (Annex F) (RR 11-2018, section 2.83.1). Since RMC 29-2024, BIR no longer accepts copies without the employee's signature for employees qualified for substituted filing (RMC 29-2024). Read the details in 2316 employee signature.
What happens if you do not qualify
You file BIR Form 1700 on or before April 15 of the following year, and the 2316 forms part of it. You get two copies of the certificate, the original and duplicate, as proof of compensation and tax credit (RR 11-2018, section 2.83.1). Tax withheld is credited there; the return may show a balance or a refund. For anything about your own return, ask your RDO or a CPA.
Should I tick it?
Follow the rule, not the employer's habit. A 2316 ticked for an employee who had two employers is wrong on its face. Sign it only if every condition above holds. Not sure? Ask HR whether you are in the certified list, and ask your RDO if you cannot settle it.
Questions
Is substituted filing the same as the 2316 being my ITR? It is the closest thing. The employer's stamped certified list is treated as your filing, and the 2316 is your proof of pay and tax (RR 11-2018, section 2.83.4).
I changed jobs in the middle of the year. Can I tick the box? No. Two employers, even one after the other, means you file your own return (RR 11-2018, section 2.83.4(A)).
I have a freelance side income. Do I tick it? No, if the side income is non-business, non-professional income not subject to final tax; and the rule covers purely compensation only (RR 11-2018, section 2.83.4(C)). For business or professional income, ask your RDO or a CPA which return you file.
What if my employer withheld too little or too much? If tax due does not equal tax withheld, you are outside substituted filing (RR 11-2018, section 2.83.4(B)). You file the return and the difference is settled there.
Does PhilForms submit the list to BIR? No. PhilForms fills the 2316; your employer submits.
PhilForms is not affiliated with BIR or any agency and does not give tax advice.
Last checked 2026-10-16. Not affiliated with BIR, SSS, PhilHealth, Pag-IBIG or any government agency.