BIR Lays Out Electronic Invoicing Rules Ahead of December 31 Deadline

By Danhilson O. Vivo | President and CEO, DV Consulting Inc.  25 September 2026 MANILA, Philippines — The Bureau of Internal Revenue has issued Revenue Memorandum Circular No. 98-2026, setting out how covered taxpayers must issue electronic invoices by December 31, 2026. Issued on September 22, the circular clarifies which businesses are covered, what makes an invoice electronic, and the permits and system checks required before and after implementation.

The deadline covers small, medium and large taxpayers engaged in e-commerce or internet transactions; taxpayers under the Large Taxpayers Service; large taxpayers under the Ease of Paying Taxes framework; users of computerized accounting systems or computerized books of accounts with electronic invoicing, and other invoicing software; and other taxpayers the BIR may require. The circular exempts micro taxpayers from the December 2026 mandate. Businesses outside mandatory coverage may adopt electronic invoicing voluntarily, subject to a Permit to Issue Electronic Invoice.

An electronic invoice must come from a duly registered, approved or accredited system in a structured electronic format. It must be transmitted digitally to the buyer, and its data must be capable of electronic extraction, processing and transmission to the BIR. A manually prepared Word or Excel invoice does not qualify. A system-generated invoice printed on paper alone also does not qualify if the system cannot issue and transmit the invoice electronically and report the required data.

Before issuing electronic invoices, a covered business must secure a Permit to Issue, or PTI, Electronic Invoice from its registered Revenue District Office or Large Taxpayer office. A permit to use a computerized accounting system does not, by itself, authorize electronic invoicing. The BIR has up to 20 working days to evaluate a complete PTI application. Within six months after the PTI is issued, the taxpayer must obtain Electronic Invoicing and Sales Reporting, or EIS, Certification. Failure to do so is a ground for revoking the PTI.

The BIR distinguishes issuing electronic invoices from transmitting electronic sales data. The electronic invoicing deadline remains December 31, 2026; the BIR will issue separate implementing policies for electronic sales reporting. A Permit to Transmit will apply only when the Commissioner directs taxpayers to comply with that separate reporting requirement.

For a covered company with registered branches, the requirement extends to its head office and every branch, even if only one location conducts the covered activity. During a system outage, the taxpayer must issue a BIR-authorized manual invoice and, once service is restored, replace it with an electronic invoice that references the manual invoice number.

Businesses should now check their taxpayer classification, map invoicing across branches, confirm their software can produce structured data and deliver invoices digitally, prepare the PTI application, and plan system certification. Allow time for BIR review and staff training before the year-end deadline.

Source: Bureau of Internal Revenue, Revenue Memorandum Circular No. 98-2026 (22 September 2026). https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2098-2026%20redacted.pdf