REVENUE MEMORANDUM CIRCULAR NO. 107-2025 issued on November 24, 2025 suspends all ongoing field audits and related field operations, such as issuance of Letter of Authority (LOA), Mission Order (MO), examination and verification of taxpayers’ books of accounts, records, and other related transactions, until the order is lifted by the Commissioner of Internal Revenue.
However, the issuance of Assessment Notices, Warrants, and Seizure Notices shall continue under the exceptions outlined in Section IV. Additionally, taxpayers may voluntarily pay their known deficiency taxes without needing approval from the appropriate revenue officials.
This order applies to all operating offices of the BIR that conduct field audits and related
field operations, including but not limited to:
a. Large Taxpayers Service (LTS);
b. Revenue Regions (RRs);
c. Revenue District Offices (RDOs);
d. National and Regional Investigation Divisions;
e. Assessment Divisions;
f. VAT Audit Unit (LTS);
g. VAT Audit Sections;
h. Office Audit Sections;
i. All other offices, committees, and task forces authorized to conduct examinations, verification of taxpayers’ books of account, records, and other related transactions or investigations.
During the suspension period, the issuance of written orders to audit or investigate taxpayers’ internal revenue liabilities is suspended, except in the following circumstances:
a. Investigation of cases prescribing within six (6) months from the date of this Order;b. Processing and verification of estate tax 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 stamp tax returns related thereto;
c. Examination or verification of internal revenue tax liabilities of taxpayers retiring from business;
d. LOAs/MOs necessary for active criminal probes conducted by duly authorized enforcement units through verified intelligence reports, inter-agency referrals, thirdparty data validation, or risk-scoring anomalies that require immediate audit action
where delay would prejudice the government’s case;
e. Claims for refund where the issuance of an LOA is statutorily required; and
f. Other matters/concerns where deadlines have been imposed or under the orders of the Commissioner.
All concerned offices, committees, and task forces must submit an inventory of allpending or unserved LOAs, revalidated or expired LOAs, and supplementary or related LOAs, MOs, including their status, to the Office of the Commissioner within fifteen (15) working days from the effective date of this Order.
No revalidation, extension, replacement, or supplementary LOA and MO shall be issued during the suspension period unless it falls under the exceptions in Section IV.
The Technical Working Group/Review Committee on LOA Integrity and Audit Reforms is directed to evaluate existing policy frameworks, identify operational and systemic vulnerabilities, recommend a revised, integrity-based LOA issuance protocol, and integrate digital safeguards and uniform audit standards.
The Committee shall submit its recommendations within the period prescribed by the Commissioner.