If you are uploading your Annual Income Tax Return attachments through the BIR eAFS system and you see “SMR” in the checklist, it means Statement of Management’s Responsibility. In practical terms, an SMR is required when the financial statements you are submitting to the BIR should be accompanied by a management certification—most commonly for corporations, partnerships, and other taxpayers submitting audited or unaudited financial statements as part of their Annual ITR attachments. The key question is not simply “Do I use eAFS?” but “Am I required to submit financial statements, and do those financial statements need an SMR?”
What is an SMR in eAFS?
An SMR, or Statement of Management’s Responsibility, is a signed statement where the taxpayer’s responsible officers confirm that management is responsible for the preparation and fair presentation of the financial statements.
For corporations, this is not just a formality. It tells the BIR, SEC, banks, investors, and other users of the financial statements that management—not the external auditor—is primarily responsible for the truthfulness, completeness, and accuracy of the financial statements.
The external auditor gives an independent opinion on audited financial statements, but management remains responsible for the numbers, records, disclosures, and internal controls behind those statements. SEC rules on financial statements have long recognized that financial statements filed with the Commission are primarily management’s responsibility, and that they must be accompanied by a Statement of Management’s Responsibility. (ChanRobles)
For eAFS purposes, the SMR is usually included in the AFS PDF file together with the:
- Independent auditor’s report, if audited;
- Statement of financial position;
- Statement of comprehensive income or income statement;
- Statement of changes in equity, if applicable;
- Statement of cash flows, if applicable;
- Notes to financial statements;
- Required schedules; and
- Other required tax attachments.
Is an SMR always required when using eAFS?
No. Using eAFS does not automatically mean an SMR is required. eAFS is only the electronic channel for submitting attachments to a filed income tax return.
An SMR is required only if it is an applicable attachment based on the taxpayer’s classification and the financial statements being submitted.
BIR RMC No. 20-2026 lists the required attachments to Annual ITRs and includes “Unaudited or Audited Financial Statements,” “Notes to AFS,” and “Statement of Management Responsibilities (SMR)” among the attachments that may have to be submitted. The same circular also says that only the applicable attachments are to be submitted by the concerned taxpayer.
So the practical rule is:
| Situation | Is SMR usually required for eAFS? | Why |
|---|---|---|
| Corporation submitting audited financial statements | Yes | SMR is part of the AFS package and required under SEC/BIR practice. |
| Corporation allowed to submit unaudited financial statements | Yes | The unaudited FS must still be supported by management responsibility certification. |
| One Person Corporation submitting financial statements | Yes | SMR is signed under oath by the required OPC officers. |
| Sole proprietor with no required financial statements attachment | Usually no | There may be no FS package requiring an SMR. |
| Individual business taxpayer required to submit audited FS | Usually yes, if included in the FS package | The BIR list includes SMR as an applicable attachment where FS/AFS is submitted. |
| Taxpayer filing Annual ITR with no attachments | No | eAFS submission itself may not be necessary if there are no required attachments. |
Legal basis: why the SMR matters
BIR rules on eAFS attachments
The BIR created and expanded the eAFS system so taxpayers could electronically submit filed ITRs and attachments instead of physically lining up at the Revenue District Office. RMC No. 49-2020 states that taxpayers may submit the filed ITR and required attachments through eAFS, that the files must be scanned and saved as properly named PDFs, and that the system-generated Transaction Reference Number serves as proof of submission in lieu of manual “Received” stamping. (Bir CDN)
RMC No. 43-2021 later prescribed revised guidelines for using eAFS for the submission of duly filed ITRs and required attachments, including BIR Form No. 1709 for related-party transactions. It also emphasized scanning documents and following the prescribed naming convention per document classification. (Bir CDN)
For Calendar Year 2025 filings, BIR RMC No. 20-2026 specifically identified the attachments to the Annual ITR, including audited or unaudited financial statements, notes to AFS, and SMR. It also provided that attachments are submitted electronically through eAFS and that the eAFS-generated confirmation receipt is proof of submission.
SEC rules on financial statements and SMR
For corporations, the SMR is closely tied to the Securities and Exchange Commission’s financial reporting rules. Under Revised SRC Rule 68, the financial statements filed with the SEC are management’s responsibility, and covered corporations must acknowledge that responsibility through an SMR. The SEC-prescribed SMR language historically required management to state that it is responsible for all information and representations in the financial statements and that the statements were prepared in conformity with Philippine generally accepted accounting principles. (Supreme Court E-Library)
For branch offices of foreign corporations licensed to operate in the Philippines, the SMR is signed by the local manager in charge of Philippine operations. (Supreme Court E-Library)
2026 SEC audit threshold change
A major 2026 update affects many small corporations. SEC Memorandum Circular No. 4, Series of 2026 amended the audit threshold under Revised SRC Rule 68. Stock and non-stock corporations with total assets or total liabilities of more than ₱3,000,000 are covered by the audit requirement. Corporations at or below the threshold are generally not required to submit audited financial statements, but must submit financial statements accompanied by an SMR signed under oath.
For stock and non-stock corporations under the threshold, the SMR is signed under oath by the Chairman of the Board, President or Chief Executive Officer, and Treasurer or Chief Financial Officer, all duly authorized by the Board. For One Person Corporations, it is signed by the President and Treasurer.
This means the 2026 rule did not remove the SMR requirement. It actually makes the SMR more important for smaller corporations that no longer need an external audit but still need to file financial statements responsibly.
When exactly should you include the SMR in your eAFS upload?
You should include the SMR in your eAFS submission when any of the following applies:
1. You are submitting audited financial statements
If your Annual ITR attachments include audited financial statements, the SMR should be part of the AFS package.
This commonly applies to:
- Domestic corporations;
- Partnerships treated as corporations for tax purposes;
- Branches of foreign corporations licensed in the Philippines;
- Taxpayers whose gross annual sales, earnings, receipts, or output exceed the BIR audit threshold;
- SEC-registered entities above the applicable audit threshold;
- Entities required by banks, investors, regulators, or contracts to produce audited FS.
For BIR purposes, the Tax Code requires taxpayers whose gross annual sales, earnings, receipts, or output exceed ₱3,000,000 to have their books audited and examined yearly by independent CPAs, with the income tax return accompanied by the required financial/account information attachments. (PwC)
2. You are a corporation submitting unaudited financial statements because you fall below the SEC audit threshold
Small corporations often think “no audit” means “no SMR.” That is not correct.
Under SEC MC No. 4, Series of 2026, corporations with total assets or total liabilities at or below ₱3,000,000 are generally not required to submit audited financial statements, but they must submit financial statements accompanied by an SMR signed under oath.
So if your corporation is below the audit threshold but still submits financial statements to the BIR through eAFS, the SMR remains part of the package.
3. You are a micro entity using simplified financial reporting
SEC MC No. 4, Series of 2026 classifies micro entities as those with total assets or total liabilities at or below ₱3,000,000. It allows micro entities to use either the income tax basis or PFRS for Small Entities, but their financial statements must at least consist of the SMR signed under oath, statement of financial position, statement of income, and notes to financial statements, covering comparative periods if applicable.
This is important for small family corporations, startups, single-owner corporations, and newly incorporated businesses with minimal assets. They may save on audit costs, but they still need properly prepared financial statements and an SMR.
4. You are an OPC filing financial statements
A One Person Corporation is still a corporation. If an OPC submits financial statements, the SMR should be signed under oath by the President or Chief Executive Officer and the Treasurer or Chief Financial Officer, following the SEC’s OPC SMR template.
In practice, many OPCs have the same person acting in multiple capacities. The names and capacities should match the SEC records, GIS, board or OPC records, and the company’s internal appointment documents.
5. You are a Philippine branch of a foreign corporation
For a Philippine branch, the SMR is not signed by a foreign board of directors as if the Philippine branch were a domestic corporation. Under SRC Rule 68 guidance, the statement for a branch office of a foreign corporation is signed by the local manager in charge of Philippine operations. (Supreme Court E-Library)
This is a common issue for foreign companies. If the signing officer is abroad or if authority documents are executed outside the Philippines, the company may need proper notarization, consular acknowledgment, or apostille depending on where the document is executed and how it will be used. For private documents executed abroad, Philippine embassy guidance generally requires local notarization followed by apostille by the competent foreign authority before use in the Philippines. (Philippine Embassy)
Step-by-step guide: how to handle SMR for eAFS
1. Confirm your taxpayer type
Start by identifying what kind of taxpayer you are:
- Individual business taxpayer;
- Professional;
- Domestic corporation;
- One Person Corporation;
- Partnership;
- Non-stock corporation;
- Philippine branch of a foreign corporation;
- Estate or trust;
- Tax-exempt or specially regulated entity.
This matters because the SMR requirement is strongest and clearest for corporations and entities submitting financial statements.
2. Check whether financial statements are required
Ask these practical questions:
- Did you prepare financial statements for the taxable year?
- Are you required to submit audited financial statements?
- If not audited, are you still required to submit unaudited financial statements?
- Are you SEC-registered?
- Are you above or below the ₱3,000,000 asset/liability threshold?
- Are your gross annual sales, receipts, earnings, or output above ₱3,000,000?
- Are you a regulated or public-interest entity that may still require audit regardless of size?
If financial statements are part of your required Annual ITR attachments, include the SMR unless a specific rule clearly says otherwise.
3. Use the correct SMR signatories
| Taxpayer/entity | Common SMR signatories |
|---|---|
| Stock corporation | Chairman of the Board, President/CEO, Treasurer/CFO |
| Non-stock corporation | Chairman/Trustee equivalent, President/CEO, Treasurer/CFO |
| One Person Corporation | President/CEO and Treasurer/CFO |
| Philippine branch of foreign corporation | Local manager in charge of Philippine operations |
| Corporation with delegated authority | Officer/director expressly authorized by the Board, if allowed |
Make sure the names match your SEC records and internal documents. A common bottleneck is when the AFS names one treasurer, but the latest GIS or board records show another.
4. Sign the SMR under oath
“Signed under oath” usually means the SMR must be notarized.
For Philippine notarization, the signatories typically appear before a notary public with competent evidence of identity, such as a government-issued ID. The notarial details should be complete, including the notary’s commission details, document number, page number, book number, and series.
For signatories abroad, allow extra time. Apostille, consular notarization, courier delivery, and wet-signature requirements often delay filings, especially for foreign-owned Philippine companies.
5. Place the SMR in the correct PDF package
For eAFS, the SMR is usually included in the AFS file, not uploaded as a random separate file unless your file organization requires it.
A practical order is:
- SMR;
- Independent auditor’s report, if audited;
- Statement of financial position;
- Statement of comprehensive income or income statement;
- Statement of changes in equity, if applicable;
- Statement of cash flows, if applicable;
- Notes to financial statements;
- Required schedules;
- Other financial statement attachments.
Before uploading, check that all pages are readable, signed pages are included, and the notarized page is complete.
6. Follow the eAFS file format and naming rules
The BIR’s eAFS advisories emphasize PDF format, prescribed naming conventions, and upload requirements. The BIR has also advised taxpayers to check file extensions carefully because files may be rejected if they become invalid files such as “pdf.pdf” or do not follow the required format.
The safest practice is to prepare three main file groups:
| File group | Typical contents |
|---|---|
| ITR file | Filed Annual ITR, filing reference number, tax return receipt confirmation, proof of payment if applicable |
| AFS file | Audited or unaudited FS, notes, SMR, auditor’s report if audited |
| Other attachments | BIR Form 2307, 2316, 2304, SAWT validation, BIR Form 1709, proof of tax credits, other applicable documents |
Keep the TIN digits clean in the filename. Do not insert dashes unless the naming convention specifically allows them.
7. Save the eAFS confirmation receipt
The eAFS-generated Transaction Reference Number or confirmation receipt is your proof of submission. BIR rules recognize the TRN as proof in lieu of manual “Received” stamping, but taxpayers should keep the original documents and present them upon BIR request. (Bir CDN)
For SEC filing, companies that file AFS through BIR eAFS may attach the system-generated confirmation receipt showing the company name, TIN, taxable year, and uploaded file details instead of a manually stamped BIR-received copy.
Deadlines for eAFS submission
For regular Annual ITR attachment filing, BIR guidance generally gives taxpayers a period after filing or after the filing deadline to submit applicable attachments through eAFS. Under RMC No. 20-2026, eBIRForms, eFPS, TSP filers, and manual filers of BIR Form 1701-MS submit applicable attachments through eAFS within fifteen days from the filing deadline, or within fifteen days from filing in case of late filing.
For the 2025 Annual ITR filing season, the BIR extended the filing, payment, and submission of required attachments from April 15, 2026 to May 15, 2026 under RMC No. 30-2026. (Bir CDN) RMC No. 39-2026 clarified that applicable attachments for 2025 Annual ITRs were also to be submitted through eAFS until May 15, 2026. (Bir CDN)
Where taxpayers could not submit through eAFS on or before May 15, 2026 due to system-related issues, RMC No. 46-2026 granted an extension until May 25, 2026 for affected taxpayers, but only for submission of AFS and other attachments—not for filing the Annual ITR itself.
Common mistakes with SMR and eAFS
Missing SMR page
This is one of the most common problems. The taxpayer uploads the audited financial statements but forgets the signed SMR page. This can cause issues later when the BIR, SEC, bank, lender, or investor reviews the filing package.
Unsigned or unnotarized SMR
An SMR signed under oath should not be left as a plain unsigned template. If the rules or template require notarization, upload the notarized version.
Wrong signatories
For corporations, the SMR should be signed by the proper officers. Do not let a bookkeeper, rank-and-file employee, or outside accountant sign as management unless there is a proper corporate authority and the law allows it.
Mismatch between SMR and SEC records
If the SMR names a treasurer who is not the treasurer in the latest GIS, the filing may be questioned. Before finalizing the SMR, compare the signatories against the latest GIS, board resolutions, secretary’s certificate, and SEC records.
Treating “no audit” as “no financial statements”
Under the 2026 SEC threshold rules, some corporations may be exempt from audited financial statements but must still submit financial statements with an SMR. No audit does not mean no compliance.
Uploading the SMR separately without the AFS context
Unless instructed otherwise, the SMR should be part of the financial statements package. Uploading it separately without the FS can create confusion and may make the AFS file look incomplete.
Waiting until the last day
eAFS problems are common near deadlines: password issues, old company email, invalid TIN, file size problems, PDF errors, slow upload, and missing confirmation emails. The BIR’s eAFS advisory specifically addresses registration issues, login issues, file upload problems, and email notification issues, including checking spam folders and contacting the RDO when account details are outdated.
Practical scenarios
Scenario 1: Small domestic corporation with ₱2 million assets
A small corporation has ₱2 million in total assets and ₱500,000 in liabilities. Under SEC MC No. 4, Series of 2026, it may fall below the audit threshold. It may not need audited financial statements, assuming it is not otherwise required to be audited.
But if it submits financial statements, it should include an SMR signed under oath by the proper officers. The SMR becomes the management accountability document replacing the comfort that an external audit would otherwise provide.
Scenario 2: Corporation with ₱5 million liabilities but low income
Even if sales are low, a corporation with total liabilities above ₱3 million may be above the SEC audit threshold. It likely needs audited financial statements, and the SMR should be included in the AFS package for eAFS.
The threshold looks at total assets or total liabilities, not just income.
Scenario 3: OPC with no operations
An OPC with no operations may still have SEC and BIR filing duties. If it submits financial statements or a no-operation financial reporting package, it should check the applicable SEC filing category and include the proper SMR or sworn certification where required.
Scenario 4: Foreign company’s Philippine branch
A Philippine branch of a foreign corporation should not use the exact same SMR format as a domestic corporation if the format assumes a Philippine board of directors. The branch SMR is generally signed by the local manager in charge of Philippine operations. (Supreme Court E-Library)
Scenario 5: Sole proprietor using BIR Form 1701A
A sole proprietor who is not required to submit financial statements may not need an SMR. But if the taxpayer is submitting audited financial statements because of gross sales or other requirements, the SMR or management responsibility page included in the FS package should be uploaded with the AFS file.
Frequently Asked Questions
What does SMR mean in BIR eAFS?
SMR means Statement of Management’s Responsibility. It is a signed statement that management is responsible for the preparation, fairness, completeness, and accuracy of the financial statements.
Is SMR required for all eAFS submissions?
No. SMR is required only if it is an applicable attachment, usually because you are submitting audited or unaudited financial statements. If you have no financial statements to submit, an SMR is usually not required.
Is SMR required if my company is exempt from audit?
Yes, in many corporate cases. Under SEC MC No. 4, Series of 2026, corporations at or below the ₱3 million asset/liability threshold may be exempt from audited FS, but they must submit financial statements accompanied by an SMR signed under oath.
Should the SMR be notarized?
If the applicable rule or template says the SMR must be signed under oath, it should be notarized. In practice, corporate SMRs for financial statements are commonly notarized before submission.
Where do I attach the SMR in eAFS?
Usually, the SMR is included in the AFS PDF file together with the financial statements, notes, schedules, and auditor’s report if audited. It is not normally treated as an isolated document unrelated to the AFS.
Who signs the SMR for a corporation?
For stock and non-stock corporations, the SMR is commonly signed by the Chairman of the Board, President or CEO, and Treasurer or CFO, subject to the applicable SEC template and board authority.
Who signs the SMR for an OPC?
For a One Person Corporation, the SMR is signed by the President or CEO and the Treasurer or CFO, following the OPC SMR template.
Who signs the SMR for a Philippine branch of a foreign corporation?
For a Philippine branch office of a foreign corporation, the SMR is signed by the local manager in charge of operations in the Philippines. (Supreme Court E-Library)
What happens if I forget to upload the SMR?
The BIR or SEC may treat your attachment package as incomplete, or you may face compliance issues later when requesting clearances, filing with SEC, dealing with banks, or undergoing audit. Missing required attachments may also expose the taxpayer to penalties depending on the circumstances.
Is the eAFS confirmation receipt enough proof of SMR submission?
The confirmation receipt is proof that files were uploaded, but it does not prove that the content of the uploaded PDF was complete. Keep the actual uploaded PDF, the TRN or confirmation email, and the original signed/notarized SMR.
Key Takeaways
- SMR means Statement of Management’s Responsibility.
- It is usually required when you submit audited or unaudited financial statements through eAFS.
- eAFS use alone does not automatically require an SMR; the SMR is required only if it is an applicable attachment.
- Corporations exempt from audit may still need financial statements with an SMR signed under oath.
- Under SEC MC No. 4, Series of 2026, the key audit threshold for stock and non-stock corporations is now generally more than ₱3,000,000 in total assets or total liabilities.
- For corporations, the SMR should be signed by the proper officers and notarized when required.
- For Philippine branches of foreign corporations, the local manager generally signs the SMR.
- The SMR is usually included in the AFS PDF file uploaded through eAFS.
- Keep the eAFS confirmation receipt, uploaded PDFs, and original signed/notarized documents for future BIR, SEC, bank, or audit verification.