“ZERO SLSP” e-SUBMISSION COMPLIANCE IN THE PHILIPPINES A practitioner-oriented legal guide (updated to 16 June 2025)

1. What is the SLSP?

The Summary List of Sales and Purchases (SLSP) is an electronic schedule that every VAT-registered taxpayer in the Philippines must transmit to the Bureau of Internal Revenue (BIR) after the close of each calendar quarter. It complements the quarterly VAT return (BIR Form 2550Q) by giving the BIR line-item detail of:

Schedule	Contents	Regulatory reference
Schedule 1	Sales/Output VAT per customer (whether VAT-registered or not)	§ 113(B), NIRC; RR 16-2005
Schedule 2	Purchases/Input VAT per supplier	§ 113(B), NIRC; RR 16-2005
Schedule 3	Importations (if any)	§ 114, NIRC; RR 16-2005

The obligation arises from § 113(B) of the National Internal Revenue Code (NIRC), implemented by Revenue Regulations (RR) 16-2005, as amended by RR 1-2012, RR 6-2014, RR 13-2018 and various Revenue Memorandum Circulars (RMCs).

2. Who must submit—and when?

Taxpayer class	Threshold	Filing mode	Due date*
VAT-registered (mandatory or voluntary)	None	e-Submission (eSLSP)	30 days after the close of each quarter
VAT-exempt or non-VAT	Not required	—	—

*A later RMC may extend deadlines during disasters (e.g., COVID-19 RMC 31-2020 and following).

3. The concept of “Zero SLSP”

A Zero SLSP arises when, for a given quarter, the taxpayer:

records no taxable sales, purchases, or importations or
records transactions that are all below the P100,000/customer (sales) or P100,000/supplier (purchases) materiality cut-off (RR 16-2005, § 2.3).

Legally, the obligation to transmit still exists. BIR repeatedly confirmed—most recently in RMC 44-2021—that the SLSP must be filed even if the templates are blank or contain only zeroes. Hence the term “Zero SLSP”.

4. Legal basis and interpretative issuances

Instrument	Key take-aways on Zero SLSP
RR 16-2005	Laid down the duty to file SLSP and retained filing even when no transactions exist.
RR 1-2012	Shifted mandatory filers to e-Submission and reiterated that taxpayers with no transactions must submit “Nil” lists.
RMC 5-2010 & RMC 26-2010	First detailed e-mail-based submission protocol; clarified that a “No Transaction” letter is no longer acceptable—taxpayers must transmit the prescribed XML/Excel file.
RMC 57-2015	Introduced the unified e-Submission portal (esubmission@bir.gov.ph) and the standard filename pattern.
RMC 44-2021	Re-emphasised Zero SLSP filing in view of pandemic-related deadline extensions.

5. Technical compliance workflow for a Zero SLSP

Download the current SLSP Data Entry and Validation (DEV) Module from https://www.bir.gov.ph.
Create a new report:
- Fill-in the taxpayer profile screen (TIN, RDO, business name, quarter).
- Leave the detail schedules empty (do not delete headers).
- The DEV module automatically tags the file as “No entries”.
Validate—the system will still generate a .dat and .txt file.
Compose an e-mail to esubmission@bir.gov.ph (or the latest domain specified in the RMC) with:
- Subject line – SLSP_<TIN>_<QTRYYYY> (e.g., SLSP_123456789_2Q2025)
- Attachments – the validated .dat file (or .txt if using the legacy Excel template) zipped.
- Body – “Zero transactions for the period” (optional but helpful).
Receive the BIR auto-reply: “Your submission has been received and queued for validation; please keep this e-mail as proof.” Keep it with your statutory records.

Tip: The eFPS portal does not currently accept SLSP uploads. Filing the VAT return via eFPS does not satisfy the SLSP requirement—you must still e-mail the SLSP.

6. Penalties for failure, late filing, or wrong format

Violation	Statutory penalty	BIR compromise rates (2025 matrix)
Late or non-submission	§ 250, NIRC – P1,000 per list, max P25,000 per year	P1,000-P5,000 per offense, plus 25 % surcharge and 12 % interest if taxes are under-declared
Wrong format / unreadable file	Treated as non-submission once BIR issues defect notice	Same as above if not cured within 5 days

A repeat violation may trigger the “three-strikes rule” under RMO 7-2015, allowing the BIR to bar the taxpayer from securing tax clearances until compliance.

7. Frequent problem areas & practitioner tips

Problem	Why it happens	How to avoid
Old templates	DEV module updated almost yearly	Check the BIR site every quarter.
Wrong filename	Missing underscores or extra spaces	Copy the pattern in RMC 57-2015 verbatim.
Multiple quarters in one e-mail	BIR servers reject bundles	Send one e-mail per quarter.
Belief that “zero” means no filing	Legacy practice (pre-eSLSP)	Circulate a memo to accounting: always file.
Late submissions for remote branches	Central office unaware of nil activity	Require each branch to report “no activity” by Day 20; head office then files a consolidated Zero SLSP.

8. Interaction with other e-filing reports

Report	Zero-return counterpart?	Effect on SLSP
Quarterly VAT (BIR 2550Q)	Yes	Must file “zero VAT” return and Zero SLSP.
SAWT / QAP	Yes (if no withholding)	Independent; do not combine files.
eBIR eSales OR List	Yes	Separate e-mail required.

9. Data-privacy and record-retention notes

RR 5-2014 requires taxpayers to keep an unaltered copy of every SLSP (including acknowledgements) for 10 years. Because even a Zero SLSP contains the taxpayer’s TIN and business profile, it is “personal data” under the Data Privacy Act of 2012; store it in encrypted form if possible.

10. Looking ahead

The BIR announced—in its 2024 Digital Transformation Roadmap—plans to integrate SLSP uploads into the online VAT return by 2026. Until the system is live and an RMC formally supersedes e-mail submission, taxpayers must continue the present Zero SLSP e-mail routine.

CONCLUSION

In Philippine tax practice, the phrase “Zero SLSP” does not mean no reporting. The law and successive BIR issuances establish an affirmative duty to transmit a blank but properly validated SLSP file within 30 days after every quarter, on pain of monetary penalties and possible denial of tax clearances. Vigilant adherence—through updated templates, correct filenames, punctual e-mails, and documented acknowledgements—protects taxpayers from avoidable assessments and preserves VAT credit integrity.