Payroll, HR & labor compliance
Alphalist of employees and BIR Form 1604-C: an employer's guide
How to prepare the annual alphalist of employees and BIR Form 1604-C, the January 31 deadline, schedules, validation and reconciling with 1601-C and 2316.
BIR Form 1604-C is the *Annual Information Return of Income Taxes Withheld on Compensation*. Employers file it with an alphalist of employees, a list of every employee paid during the year with their compensation, non-taxable and taxable amounts, and the tax withheld. The deadline is generally on or before January 31 of the following year. The alphalist is usually submitted in the BIR's prescribed electronic format after validation.
The 1604-C is where a year of payroll data meets the BIR in one file. If the monthly 1601-C returns and the year-end annualization were right, the alphalist is straightforward. If not, January becomes a reconciliation project.
What the alphalist contains
For each employee:
- Name, TIN and period of employment
- Gross compensation, separated into non-taxable and taxable components
- Previous employer compensation and tax, where applicable
- Total tax due, tax withheld and any adjustments from annualization
- Whether the employee is a minimum wage earner and whether they qualify for substituted filing
Employees are organized into schedules, for example separating minimum wage earners and employees who separated during the year. Follow the BIR's current alphalist schedules and format for the year being reported.
Step by step
- Close the payroll year. All December payrolls approved, annualization done, refunds or shortfalls settled.
- Generate the alphalist from the payroll system for each employer TIN.
- Validate using the BIR's validation tool or format checks. Fix TIN errors, missing names and mismatched totals.
- Reconcile the alphalist with the twelve 1601-C returns and the 2316s. Totals for taxable compensation and tax withheld should agree.
- Prepare and file 1604-C through the applicable channel.
- Submit the alphalist in the required electronic format and keep the acknowledgment.
- Archive the final files, reconciliations and acknowledgments for audit.
Reconciliation table
| Check | Source A | Source B | Expected |
|---|---|---|---|
| Tax withheld | Sum of twelve 1601-C returns | Alphalist total tax withheld | Equal, or differences explained by documented adjustments |
| Taxable compensation | Payroll year-to-date | Alphalist total | Equal |
| Per employee | Alphalist row | Employee's 2316 | Identical figures |
| Headcount | Payroll employee list for the year | Alphalist rows | Everyone paid during the year appears once |
A year-end timeline that avoids the January rush
| When | Task |
|---|---|
| October | Chase missing TINs and previous-employer 2316s; review employee tax data |
| November | Trial annualization; review 13th month pay and bonuses against the ₱90,000 exemption |
| December | Final payroll with annualization; settle refunds and shortfalls |
| First week of January | Close the payroll year; reconcile with twelve 1601-C returns |
| Mid-January | Generate and validate the alphalist; distribute 2316s for signature |
| By January 31 | File 1604-C and submit the alphalist; give 2316s to employees |
Working backward from the deadline makes the dependencies visible. Most alphalist problems are really data problems that could have been fixed in October.
Common alphalist problems
- Invalid or missing TINs, especially for new hires
- Employees appearing twice after a branch or company transfer
- Separated employees missing from the schedule
- Previous employer amounts recorded in payroll but not in the alphalist
- Rounding differences between monthly returns and annual totals
- Group companies combined in one file instead of one per employer TIN
Multi-company groups
Each legal entity files its own 1604-C and alphalist. Employees who transferred between companies in the group during the year appear in each employer's alphalist for the period they were paid there, and the new employer needs the previous one's 2316. Set up intercompany transfers in your HRIS and payroll so this happens automatically. See payroll for multiple branches and companies.
Generating the alphalist from payroll software
The cleanest alphalist is generated from the same data as every cutoff, the 1601-C summaries and the 2316s. Cirquolus Payroll keeps withholding, 13th month pay and annualization in one system with payroll approvals, so year-end reports start from approved records.
Frequently asked questions
When is the deadline for BIR Form 1604-C?
Generally on or before January 31 of the year following the reporting year. Confirm the current deadline and submission channel with the BIR.
What is an alphalist of employees?
It is the annual list of all employees paid during the year, with their compensation and tax withheld, submitted with BIR Form 1604-C.
Do I include resigned employees in the alphalist?
Yes. Everyone who received compensation from the employer during the year is included, in the applicable schedule.
What happens if the alphalist does not match the 1601-C returns?
The BIR may question the difference. Reconcile before filing and document any adjustments, such as annualization refunds.
Bring this workflow to a Cirquolus demo.
Show us your current process, companies and branches. We will map it to the modules you need and propose a realistic rollout.