On 18 July 2025, the Bureau of Internal Revenue issued Revenue Memorandum Circular No. 074-2025, adopting the updated Checklist of Documentary Requirements (CDR – July 2025) for registration-related frontline services.
RMC No. 74-2025
While framed as a checklist update, the revised CDR represents a broader compliance shift affecting corporations, OPCs, foreign corporations, digital service providers, branches, and even accounting systems registration.
CDR – 2025c
The update signals a clear policy direction: formalization, digitization, and strict documentary discipline.
Below is a structured comparison of the general prior practice versus the New CDR 2025 framework.
Old Practice vs. New CDR (July 2025)
| Area | Old Practice (General Observed Practice) | New CDR 2025 (RMC 074-2025 & Annex) |
| Processing of Incomplete Applications | Some RDOs allowed conditional acceptance pending submission of missing documents. | Explicit “NO PROCESSING” rule. Incomplete applications will be returned and not processed. RMC No. 74-2025 |
| OPC Authorization | SPA sometimes accepted when sole stockholder authorized representative. | Written Resolution required for OPC. SPA cannot substitute corporate authorization. RMC No. 74-2025 |
| Secretary’s Certificate | Assistant Corporate Secretary signatures sometimes tolerated. | Must be signed by duly appointed Corporate Secretary. Assistant signature not acceptable. RMC No. 74-2025 |
| Board Resolution Content | Generic resolutions occasionally accepted. | Must specify purpose of transaction and name of authorized representative across filings. CDR – 2025c |
| ORUS Integration | Hybrid manual/online filing; inconsistent implementation. | ORUS embedded in business registration, branch registration, TIN issuance, books registration, NRDSP registration, and updates. CDR – 2025c |
| Computerized Books (CAS/CBA) | PTU required but enforcement varied. | Requires PTU/Acknowledgment Certificate, SAF electronic file submission, and sworn affidavit of completeness. CDR – 2025c |
| Loose Leaf Permits | Sworn statements required but rarely scrutinized. | Sworn statement must specify serial numbers, 15-day binding commitment, and 5-year preservation undertaking. CDR – 2025c |
| NRDSP Registration | No dedicated framework; processed under general foreign corporation rules. | Dedicated CDR (F11DSP). Mandatory online registration via ORUS as NRFC – Digital Service Provider. CDR – 2025c |
| Branch Registration | Address documentation required; varying RDO flexibility. | Must clearly indicate complete business address; additional documents if business line differs from head office. CDR – 2025c |
| Change in Accounting Period | Letter request with SEC filing generally sufficient. | Requires SEC Amended By-Laws filing, sworn Non-Forum Shopping declaration, and sworn undertaking to file separate return. CDR – 2025c |
| Registration Updates | Many changes required RDO appearance. | Multiple updates now FREE via ORUS (address, additional line of business, 8% option, tax types, etc.). CDR – 2025c |
What This Means in Practice
The New CDR 2025 is not merely procedural. It introduces:
1. Strict Formal Corporate Compliance
Corporate separateness is now rigorously enforced. OPCs must pass written resolutions; Assistant Corporate Secretary signatures are insufficient; generic authorizations risk rejection.
2. Zero-Tolerance for Documentary Deficiencies
The BIR expressly adopts a strict “no incomplete processing” rule anchored on RA 11032. Pre-filing review is no longer advisable—it is necessary.
3. Increased Affidavit and Sworn Undertaking Requirements
Particularly in:
- Computerized books
- Loose leaf permits
- Accounting period changes
This reflects heightened audit defensibility standards.
4. Accelerated Digital Migration
ORUS is now central to:
- Registration
- Books of accounts
- NRDSP compliance
- Information updates
Corporations unfamiliar with ORUS may encounter delays if internal processes are not updated.
Compliance Recommendation for Corporations
In light of the New CDR:
- Standardize BIR-specific Board Resolutions
- Review Corporate Secretary appointment validity
- Prepare CAS/SAF compliance documentation in advance
- Audit existing loose leaf undertakings and binding practices
- Train compliance teams on ORUS workflow
Concluding Observation
The July 2025 CDR update reflects a broader regulatory message:
Registration compliance is no longer clerical — it is procedural governance.
For corporations undergoing expansion, restructuring, branch registration, digital service operations, or accounting system updates, documentary precision will now directly affect operational timelines.
This guide provides a general overview of the above transactions at the time of writing only and is not intended to be a comprehensive legal advice. This should also not be taken as an opinion on the topic. For more details and information, you may coordinate with any GVES Law Partner regarding the matter.
Atty. Ludanielle N. Legarde is a Partner of GVES Law.