Quick answer

Act promptly, but do not simply append the missing pages to the old upload.

First determine where the omission occurred:

SEC eFAST: If the original financial statements were accepted and you later discovered missing pages, schedules, notes, or attachments, prepare one complete corrected PDF and file it for the same fiscal year using the appropriate “Amendment” submission type. If the SEC reverted the original filing, it is considered not filed or received; correct the stated defect and resubmit according to the reversion notice.
BIR eAFS: If the AFS was omitted from the income-tax-return attachments, submit the complete prescribed file group within the applicable filing period. If the first submission already generated a Transaction Reference Number (TRN), the deadline has passed, or the portal will not accept another upload, obtain written instructions from the taxpayer’s RDO, Large Taxpayers office, or other BIR office with jurisdiction. Do not assume that an unacknowledged second upload automatically replaces the first.
Both agencies: SEC and BIR filings are separate obligations. Correcting one does not automatically correct the other.

If the omission is only a scanning or transmission mistake and the original signed AFS is otherwise complete, the correction may be limited to rebuilding and resubmitting the complete file. If information was omitted from the signed financial statements themselves—or any figure, note, disclosure, accounting treatment, or auditor’s opinion must change—management and the independent CPA must first determine the proper accounting, audit, approval, and reissuance steps. Never alter, splice, backdate, or reuse a signed auditor’s report for financial statements that the auditor did not approve.

Identify exactly what was omitted

Compare the uploaded file—not merely the office copy—with the final signed set. Common omissions include:

The Statement of Management’s Responsibility for Financial Statements;
The independent auditor’s report;
A statement of financial position;
A statement of profit or loss and other comprehensive income;
Statements of changes in equity or cash flows;
Notes to the financial statements;
Comparative information;
Required schedules, supplementary tax information, or industry-specific forms;
Signatures, notarization, or required certifications;
Proof of BIR filing or receipt required for the SEC submission;
Applicable non-stock corporation or foundation forms; or
Entire pages lost during scanning, merging, or PDF conversion.

Classify the problem before taking further action.

The signed AFS was complete, but the uploaded copy was incomplete

This is usually a document-assembly problem. Use the unchanged, complete signed set to create a new legible PDF. Confirm with the CPA that no financial information or auditor-issued document has changed.

The signed AFS itself omitted information or contains an error

This is a substantive correction. Management should give the CPA the underlying records and a written description of the issue. Depending on materiality and the circumstances, the correction may require revised financial statements, updated notes, new management representations, fresh signatures, a newly dated or reissued auditor’s report, and corporate approvals.

The AFS and income tax return no longer agree

If the correction changes taxable income, tax due, credits, or information reported in the annual income tax return, determine with the taxpayer’s tax adviser whether an amended return and additional payment are required. Correcting an attachment does not amend the figures in an income tax return.

Confirm whether an independent audit was required

For SEC purposes, Section 177 of the Revised Corporation Code generally requires corporations doing business in the Philippines to submit annual financial statements audited by an independent CPA. If the corporation’s total assets or total liabilities are less than ₱600,000, the financial statements may instead be certified under oath by its treasurer or chief financial officer, subject to SEC rules and special regulatory requirements.

For BIR purposes, the applicable test is different. Section 232 of the Tax Code, as amended by the TRAIN Law, requires an annual CPA audit where gross quarterly sales, earnings, receipts, or output exceed ₱3 million. Other laws, a special regulator, financing documents, or the entity’s circumstances may nevertheless require audited statements.

Do not use the SEC threshold to decide the BIR obligation, or vice versa.

Prepare a defensible corrected set

Before resubmission:

Freeze and preserve the original filing. Save the exact PDF submitted, portal status, confirmation email, QR code or TRN, and any reversion or deficiency notice.
Reconcile the complete document. Check page numbers, cross-references, comparative amounts, note references, totals, signatures, dates, and the fiscal period.
Involve the CPA where necessary. Inform the auditor if anything beyond the electronic copy or scanning sequence has changed. Do not independently edit an auditor’s report or audited document.
Obtain the required approvals and signatures. Follow the corporation’s governance requirements and any rules applicable to listed companies, entities vested with public interest, foundations, financial institutions, or other specially regulated entities.
Create one clean master PDF for the SEC. The SEC eFAST filing guide requires financial statements and their necessary attachments to be submitted as a single PDF. Use portrait orientation where applicable, complete margins, and clear black-and-white scans at the stated 100–150 dpi standard. Check every page after merging.
Prepare BIR files separately. Follow the BIR’s prescribed document grouping and naming convention. SEC’s single-PDF requirement does not replace the BIR eAFS file classifications.
Document the correction. Prepare an internal memorandum identifying:
- The original submission date and reference number;
- The omitted material;
- How and when the omission was discovered;
- Whether any figures or disclosures changed;
- Who reviewed the correction; and
- The date and reference number of the corrective submission.

A concise explanation may also be included when requested by the regulator. Do not upload an improvised affidavit or cover letter unless required or relevant.

How to correct an SEC eFAST filing

If the filing is still only “Uploaded”

An item under the Uploaded tab has not yet been submitted to the SEC. Replace the incomplete file, verify the form type, fiscal period, and submission type, and then complete the submission. Do not rely on an upload record as proof of filing.

If the filing was “Reverted”

Under the SEC eFAST User Guide, a reverted or rejected report is considered not filed or received.

Take these steps:

Open and preserve the complete reversion notice.
Correct every listed reason, not only the most obvious defect.
Rebuild the complete PDF.
Use the fiscal year-end shown in the auditor’s report as the period covered.
Resubmit through the same eFAST filing process and follow the form or submission-type instruction in the notice. Because a reverted filing is treated as not filed, do not assume that “Amendment” is appropriate unless the system or SEC instructs you to use it.
Confirm that the corrected document appears under Submitted Forms.
Monitor the MC 28-registered email address and eFAST account for a new notice, acceptance, reversion, or QR code.

The SEC states that the original submission date is the reckoning date only if the filing is compliant. An incomplete filing that is reverted should not be treated as preserving the filing date.

If the filing was accepted and the corporation later discovers the omission

Submit the complete corrected set for the same fiscal year and choose “Amendment”, the submission type the SEC identifies for financial statements resubmitted because of corrections or revisions.

Do not:

File only the omitted pages as a separate AFS;
Change the fiscal year to the correction date;
Submit under another company’s eFAST profile;
Describe a substantively revised set as merely a clearer scan; or
Assume that the amended filing eliminates any consequence of the original deficiency.

A QR code proves receipt through the system. It is not a conclusive ruling that the financial statements contain no substantive deficiency or misstatement.

How to correct a BIR eAFS omission

BIR eAFS is the facility for electronically submitting annual income tax return attachments. A successful submission generates a TRN and email confirmation, which serve as proof of submission under RMC No. 49-2020. Taxpayers must retain the original documents for production when requested.

If no successful submission was completed

Log in to the official BIR eAFS portal and submit the complete required files using the current classifications and naming convention. Confirm that the correct TIN, branch code, taxable year, and document-group identifier appear in each filename.

If a TRN was issued but the AFS was omitted

A TRN proves that files were received; it does not establish that every required attachment was included.

If the applicable submission period remains open and the portal permits the corrective upload, submit the complete correctly named file group and preserve the new TRN and confirmation. Then verify the treatment of the second submission with the taxpayer’s RDO or Large Taxpayers office.

If the portal does not permit another upload, or the filing period has expired:

Write promptly to the office with jurisdiction over the taxpayer.
Identify the taxpayer, taxable year, original TRN, submission date, and omitted document.
Attach or offer the original confirmation and complete corrected set.
Ask for the authorized corrective filing channel and written confirmation of receipt.
Follow any instruction to re-upload, email, or present hard copies.

Use only an official BIR address or channel. Do not send confidential financial statements to an address obtained from an unofficial post or prior-year contingency announcement.

If the income tax return must also change

File the amended AITR through the applicable BIR filing facility and settle any resulting tax, interest, surcharge, or other amount properly assessed under current rules. Afterwards, submit the financial statements and other attachments that correspond to the amended return. Keep both the original and amended filing confirmations.

An omitted attachment alone does not necessarily require an amended AITR if the filed return’s figures remain correct.

Observe the original deadlines

The SEC eFAST guide states that financial statements are generally due within 120 calendar days after the end of the fiscal year. A separate annual SEC schedule may govern corporations with a 31 December year-end, while listed, public-interest, or specially regulated entities may have other deadlines. Check the current SEC circular and eFAST announcements applicable to the particular fiscal year.

A correction does not create a new 120-day period. File it as soon as the complete and properly approved set is ready.

For BIR filings, follow the deadline governing the relevant AITR and attachments. Special extensions are limited to the taxpayers and circumstances stated in the issuance. For example:

RMC No. 39-2026 set 15 May 2026 as the deadline for the specified 2025 AITR filings and attachments.
RMC No. 46-2026 gave qualifying taxpayers affected by eAFS system issues until 25 May 2026 to submit or resubmit. It did not extend the AITR deadline and did not create a standing extension for later years.

Do not rely on those dates for another taxable year or for a fiscal-year taxpayer unless the issuance expressly applies.

Preserve evidence

Keep the following in a secure compliance file:

The exact incomplete file originally submitted;
The final complete signed AFS;
The corrected PDF actually resubmitted;
SEC submission emails, status screenshots, QR codes, and reversion notices;
BIR TRNs, confirmation emails, AITR filing confirmations, and proof of payment;
A page-by-page comparison or correction memorandum;
Relevant accounting records and reconciliations;
Communications with the CPA, SEC, BIR, or special regulator;
Board, officer, or committee approvals, where applicable;
Evidence of portal errors, including dated screenshots and official advisories; and
Proof that lenders, shareholders, or other recipients were given a corrected copy when necessary.

Do not delete or overwrite the first submission. Keeping both versions helps establish that the omission was detected and corrected transparently.

Common mistakes to avoid

Uploading only the missing pages instead of a complete replacement set;
Editing a signed PDF without the CPA’s knowledge;
Reusing an auditor’s signature or report for changed statements;
Selecting the wrong company profile, fiscal year, form type, or submission type;
Treating an SEC upload as complete while its status remains “Uploaded”;
Ignoring an SEC reversion because an earlier automated email was received;
Assuming an SEC correction also updates the BIR record;
Assuming a BIR TRN proves that the file was complete;
Using an expired filing extension or contingency email procedure;
Filing an amended AFS that no longer agrees with the AITR;
Sending confidential documents through an unofficial email address; or
Waiting for a regulator to discover the omission.

When professional help is urgent

Consult the independent CPA and Philippine counsel or tax adviser promptly when:

The omission affects the auditor’s opinion, taxable income, tax due, retained earnings, capital, solvency, or regulatory ratios;
The signed statements—not merely the scan—were incomplete or inaccurate;
A lender, investor, shareholder, procuring entity, or regulator relied on the incomplete set;
The corporation is listed, vested with public interest, or subject to BSP, Insurance Commission, CDA, PEZA, BOI, or another special regulator;
The SEC or BIR has issued a notice, assessment, subpoena, show-cause order, or compliance directive;
The original deadline has passed;
The filing has been reverted more than once;
The portal will not accept the correction;
There may have been an unauthorized alteration or false certification; or
The same error affects prior years or other filings.

Repeated failure to submit required corporate reports may support the SEC’s placement of a corporation under delinquent status under Section 177 of the Revised Corporation Code. Submitting a correction voluntarily and promptly is important, but it does not guarantee that penalties or other consequences will be waived.

Frequently asked questions

Can we submit only the pages that were omitted?

For SEC eFAST, no. Submit a single PDF containing the complete financial statements and all necessary attachments. For BIR eAFS, submit the complete applicable document group under the current naming and grouping rules.

Must the CPA issue a new auditor’s report?

Not necessarily when the signed audited set was complete and only the uploaded scan omitted pages. If any financial information, note, disclosure, date, or presentation in the signed set changes, the CPA must determine the additional audit work and report required.

Does an omitted AFS automatically require an amended income tax return?

No. An amended AITR is generally necessary when information reported in the return must change. If the return is correct and only an attachment was omitted, the corrective action may be limited to completing the attachment submission, subject to BIR instructions.

Should an accepted SEC filing be resubmitted as “Annual” or “Amendment”?

Use Amendment when a previously accepted AFS is resubmitted because of a correction or revision. If the first filing was reverted, it is treated as not filed; follow the SEC notice and system instructions rather than assuming that Amendment applies.

Does a QR code or TRN prove full compliance?

It proves system receipt. It does not prevent later review, reversion, verification, or a finding that the documents were incomplete or materially deficient.

Will resubmission erase a late or incomplete filing?

Not automatically. Corrective filing completes or improves the record, but the regulator may still evaluate timeliness, completeness, responsibility, and any request for relief based on the governing law and documented facts.

Official references

This article provides general Philippine legal and compliance information, not legal, tax, accounting, or audit advice for a particular filing. Requirements may depend on the entity, fiscal year, regulator, documents, and portal status. Official sources were checked as of 20 July 2026.