The Philippines

This article was updated on 22 October 2026 to reflect the new accreditation framework for Electronic Invoicing Service Providers (ESPs) under Revenue Memorandum Circular No. 110-2026, dated 12 October 2026. The BIR is accepting applications from 16 to 30 October 2026 under its tax advisory. This update also clarifies the distinction between mandatory electronic invoice issuance by 31 December 2026 and electronic sales reporting, which is subject to separate implementing rules under RMC No. 98-2026.

What are the Philippines’ e-invoicing rules?

The Philippines is introducing structured electronic invoicing for specified taxpayers under the Bureau of Internal Revenue (BIR). The affected taxpayers must be able to issue compliant electronic invoices by 31 December 2026, while electronic sales reporting to the Electronic Invoicing/Receipting System (EIS) has a separate implementation trigger.

The reform aims to standardise invoice data and support more effective tax checks. Electronic invoices are issued to buyers through approved systems; transmission of sales data to the BIR is governed by separate reporting rules.

Under RMC No. 98-2026, the specified taxpayer groups must issue compliant electronic invoices on or before 31 December 2026. This issuance duty under Tax Code Section 237 is distinct from electronic sales reporting under Section 237-A, which will require separate BIR implementing rules or instructions. RMC No. 110-2026 adds accreditation requirements for commercial e-invoicing solutions.

Affected businesses must assess their invoicing systems, obtain the relevant BIR Permit to Issue (PTI) Electronic Invoice, and secure EIS Certification within six months of the PTI. Businesses using an external provider should also assess the provider’s accreditation status.

How has e-invoicing developed in the Philippines?

The legal basis for electronic invoicing began with the TRAIN Law, Republic Act No. 10963, in December 2017. Later amendments, including the EOPT Act and CREATE MORE Act, changed invoicing and electronic reporting provisions. The current taxpayer requirements are set out in RR No. 11-2025, as amended, and RMC No. 98-2026.

The BIR began piloting its Electronic Invoicing/Receipting System (EIS) in 2022 with selected large taxpayers. The pilot was distinct from the later broader legal mandate.

The Ease of Paying Taxes (EOPT) Act, Republic Act No. 11976, approved on 5 January 2024, made the invoice the principal sales document for goods and services. Official Receipts may still serve as proof of payment. Transitional rules in RR No. 11-2024 allow qualifying unused Official Receipts to be converted into invoices until the stocks are consumed.

Republic Act No. 12066, the CREATE MORE Act, was approved on 8 November 2024. It amended Tax Code Sections 237 and 237-A and provides a one-time additional deduction for the cost of setting up an electronic sales reporting system: 100% for micro and small taxpayers, and 50% for medium and large taxpayers, subject to statutory conditions. RR No. 26-2025 extended the e-invoice issuance deadline to 31 December 2026, while RMC No. 98-2026 separated that duty from future mandatory sales reporting.

The Philippine framework currently requires covered taxpayers to generate and send structured electronic invoices directly to buyers. The BIR EIS supports separate electronic sales reporting through prescribed data transmissions. It is not an invoice clearance model, and compulsory near-real-time reporting is not universally applicable as at 22 October 2026. RMC No. 98-2026 makes reporting contingent on further instructions.

What is the Philippines’ e-invoicing compliance timeline?

The main milestones concern separate requirements: the invoice issuance deadline, the future electronic sales reporting trigger, and the October 2026 service-provider accreditation framework. The table below distinguishes these measures.

Legal framework

The electronic invoicing and reporting regime in the Philippines is governed by statutory acts passed by the Philippine Congress, complemented by implementing Revenue Regulations issued by the Department of Finance and the BIR.

Statutory hierarchy and legal bases

1. Primary tax statutes

   • National Internal Revenue Code (NIRC) of 1997, as amended

   • Section 237: Issuance of Receipts or Sales or Commercial Invoices

   • Section 237-A: Electronic Sales Reporting System

   • Republic Act No. 10963 (TRAIN Law)

   • Republic Act No. 11976 (Ease of Paying Taxes Act)

   • Republic Act No. 12066 (CREATE MORE Act)

2. Revenue regulations and BIR circulars

• RR No. 8-2022 (original EIS rules)

• RR No. 9-2022 (admissibility of electronic sales documents)

• RR No. 7-2024, as amended by RR No. 11-2024 (EOPT invoicing rules)

• RR No. 11-2025, as amended by RR No. 26-2025 (rollout provisions)

• RMC No. 98-2026 (taxpayer e-invoicing)

• RMC No. 110-2026 (ESP solution accreditation)

Primary legislation

• Republic Act No. 10963 (TRAIN Law): Established the earlier statutory framework for electronic invoicing and sales reporting. The current scope and timetable must be read with subsequent amendments and RMC No. 98-2026.

• Republic Act No. 11976 (Ease of Paying Taxes Act): Approved on 5 January 2024, it made invoices the principal sales document for goods and services and classified taxpayers as micro (below PHP 3 million), small (PHP 3 million to below PHP 20 million), medium (PHP 20 million to below PHP 1 billion) and large (at least PHP 1 billion).

• Republic Act No. 12066 (CREATE MORE Act) (implementing RR No. 11-2025): Amended Tax Code Sections 237 and 237-A. The one-off additional deduction for qualifying electronic sales reporting setup costs is 100% for micro and small taxpayers and 50% for medium and large taxpayers, subject to statutory conditions.

Revenue regulations and administrative orders

• Revenue Regulations No. 8-2022: Contains the original EIS and electronic sales transmission framework, including the three-calendar-day rule for taxpayers already required to report. Current reporting triggers must be read with RMC No. 98-2026.

• Revenue Regulations No. 9-2022: Provides rules for admissibility and validation of electronic sales documents in the EIS context. The regulation does not establish a new, general denial of input VAT or income tax deductions for every invoice not yet reported to the EIS.

• Revenue Regulations No. 11-2024: Amends the transitional provisions of RR No. 7-2024 under EOPT, including conditions for converting unused Official Receipts into invoices until the stock is exhausted.

• Revenue Regulations No. 26-2025: Extends the initial deadline for specified covered taxpayers to comply with electronic invoice issuance requirements to 31 December 2026. Separate rules will govern electronic sales reporting.

• RMC No. 98-2026: Sets e-invoicing rules, including PTI, EIS Certification within six months and deferral of PTT pending reporting instructions.

• RMC No. 110-2026: Sets immediate-effect mandatory accreditation for commercial e-invoicing solutions offered by ESPs; certificates are solution-specific and valid for five years subject to annual review.

Authorities and other key players

Public authorities oversee implementation, while Electronic Invoicing Service Providers supply solutions that must now meet BIR accreditation rules.

Department of Finance (DOF)

The Department of Finance oversees national fiscal policy. Revenue Regulations are issued by the Secretary of Finance on the recommendation of the BIR Commissioner under the Tax Code.

Bureau of Internal Revenue (BIR)

The Bureau of Internal Revenue administers taxpayer-level invoicing requirements, PTI approvals, EIS Certification and the new accreditation scheme for commercial e-invoicing solutions.

Large Taxpayers Service (LTS)

The Large Taxpayers Service is a BIR unit responsible for covered large taxpayers. Taxpayers within its jurisdiction fall within the electronic invoice issuance mandate and apply for the relevant PTI through their BIR Large Taxpayers Office.

Electronic Invoicing Service Providers (ESPs) and BIR accreditation

Under RMC No. 110-2026, dated 12 October 2026 and effective immediately, Electronic Invoicing Service Providers (ESPs) must obtain a BIR Electronic Invoicing Solutions Accreditation Certificate before commercially deploying or activating covered solutions. Accreditation applies to the specific software version, interfaces and deployment set-up approved by the BIR, rather than to every product offered by a provider.

Accreditation is valid for five years, subject to annual review and renewal at least 60 calendar days before expiry. Applicants face financial, technical, security, interoperability and stress tests. Under RMC No. 110-2026, ESPs must show that, in each of the preceding three years, they operated or supported systems capable of processing at least five million transactions annually and supporting at least 1,000 active accounts each year. The BIR advisory sets the initial application period at 16–30 October 2026. Taxpayer PTI and EIS Certification duties remain separate. Systems developed and used exclusively in-house may fall outside ESP accreditation, subject to the circular’s exact conditions. Accredited service providers: coming soon, subject to BIR verification.

Who must issue e-invoices in the Philippines?

The 31 December 2026 deadline applies to specified taxpayer groups, not all Philippine businesses. It concerns the issuance of structured electronic invoices; mandatory EIS sales-data reporting follows separate BIR directions. RMC No. 98-2026 confirms the distinction.

Who must comply by 31 December 2026?

Under RR No. 26-2025 and RMC No. 98-2026, the following covered non-micro taxpayers must be able to issue structured electronic invoices by 31 December 2026 and obtain the relevant PTI Electronic Invoice. Electronic sales reporting remains a separate obligation. Coverage is applied to the taxpayer as a whole, including its branches.

1. Large taxpayers: Taxpayers supervised by the BIR Large Taxpayers Service and those classified as large under EOPT, generally with gross annual sales of at least PHP 1 billion.

2. E-commerce taxpayers: Small, medium and large taxpayers engaged in e-commerce or internet transactions. Micro taxpayers are excluded from this deadline, including when they engage in e-commerce.

3. Accounting and invoicing software users: Taxpayers using Computerised Accounting Systems (CAS), Computerised Books of Accounts (CBA) with accounting records involving electronic invoicing, or other invoicing software, subject to the micro taxpayer exception.

4. Additional taxpayers: Other taxpayers expressly required by the Commissioner. Exporters and registered business enterprises not already falling into the four priority groups are covered in later stages subject to the conditions and future rules in RR No. 26-2025.

The four priority groups listed above are subject to the 31 December 2026 e-invoice issuance deadline. Exporters and registered business enterprises outside these groups are subject to later implementation conditions under RR No. 26-2025. Electronic sales reporting remains a separate obligation.

Excluded and deferred taxpayers

• Micro taxpayers: Taxpayers with annual gross sales below PHP 3 million are excluded from the 31 December 2026 electronic invoice issuance deadline under RMC No. 98-2026, including in the e-commerce category. They remain subject to ordinary invoice rules and may adopt electronic invoicing voluntarily after securing the required PTI. The exemption concerns this initial invoice issuance mandate and does not settle future reporting scope.

• Other small and medium taxpayers: Taxpayers not engaged in e-commerce and not otherwise within the initial named groups may be outside the 2026 issuance rollout. Exporters and registered business enterprises in the later categories of RR No. 26-2025 await the prescribed system and further BIR issuances. Classification alone does not establish an exemption if another coverage criterion applies.

• Voluntary issuers: Taxpayers outside mandatory coverage may issue electronic invoices after securing a PTI Electronic Invoice from the relevant BIR office. The detailed application rules and system coverage follow RMC No. 98-2026.

Commercial transaction mapping

For a covered taxpayer, the electronic invoice issuance duty can apply to sales to businesses, public bodies and consumers, as well as to relevant cross-border sales. The rules do not create a separate B2G network or a universal BIR clearance step.

• Business-to-business (B2B): A covered seller must issue a compliant electronic invoice to a business buyer, with the particulars required by the general invoicing rules.

• Business-to-government (B2G): Covered sellers must issue compliant invoices for supplies to public buyers. The cited BIR measures do not prescribe a distinct national B2G e-invoicing exchange or Peppol obligation.

• Business-to-consumer (B2C): Covered sellers must be capable of issuing electronic invoices. In retail situations where electronic transmission is impractical, the buyer may receive a printed copy of an invoice originally generated electronically in compliance with RMC No. 98-2026.

• Cross-border supplies and foreign businesses: The issuance rules apply to covered Philippine taxpayers, including where transactions are cross-border. Export activity alone is part of a later contingent phase for taxpayers not otherwise within the initial groups. Registration and applicability to non-resident foreign suppliers require a separate assessment; the cited rules do not establish a universal foreign-supplier e-invoicing duty.

What are the electronic invoicing requirements?

Under RMC No. 98-2026, a valid electronic invoice must originate in a registered, approved or accredited system, contain structured electronic data, be electronically transmitted to the buyer and permit electronic extraction for future BIR reporting. An invoice manually prepared in Word, Excel or similar office software does not qualify. Businesses may use internal systems or commercial solutions; where a third-party service is used, RMC No. 110-2026 adds solution accreditation. Reporting the invoice to the BIR is a separate obligation.

Mandatory invoice data payload

1. Invoice identification

   • BIR-compliant invoice serial number and date of issue

2. Supplier and buyer details

   • Registered supplier details and TIN, including branch information where applicable

   • Customer name, address and TIN where required by the relevant invoicing rules

3. Transaction and tax details

   • Description, quantity and price of goods or services

   • Applicable VAT category and VAT amount, including zero-rated and exempt sales where relevant

   • Discounts or withholding-tax data where relevant to the sale

4. Format distinction

   • The buyer-facing invoice must meet the structured electronic invoice criteria in RMC No. 98-2026.

   • JSON is the existing BIR EIS sales-reporting data format, not a universal requirement for every buyer-facing invoice.

   • The cited BIR invoicing rules do not prescribe a cryptographic signature or dynamic QR validation code as a universal invoice field.

Invoice content and structural integrity

Invoice content is governed by Tax Code Sections 113 and 237 and RR No. 7-2024, as amended. The structured e-invoice must contain the applicable information for the transaction, including seller, buyer and VAT details where required.

• A sequential, system-generated invoice number.

• The seller’s registered name, business name (where relevant), registered address and Taxpayer Identification Number (TIN), with branch details where applicable.

• The buyer’s name, address and TIN when required under RR No. 7-2024, section 3, including for a VAT-registered buyer in a sale of PHP 1,000 or more. Other invoice conditions depend on the transaction and taxpayer status.

• For VAT-registered sellers, a breakdown of taxable, VAT-exempt and zero-rated sales, where relevant, with applicable VAT shown separately in line with the invoicing rules.

• The date of the transaction.

• Applicable withholding tax indicators where the customer acts as a designated withholding agent.

Permit to Issue (PTI) Electronic Invoice

Covered taxpayers must obtain a Permit to Issue (PTI) Electronic Invoice before issuing electronic invoices. A CAS Permit to Use or Acknowledgement Certificate does not replace the PTI. Applications go to the relevant Revenue District Office or Large Taxpayers Office; the BIR has 20 working days from receipt of complete documents to assess the application. The taxpayer must secure EIS Certification within six months of PTI issuance, failing which revocation is possible. The Permit to Transmit (PTT) is required only when electronic sales reporting is separately directed. RMC No. 98-2026.

Invoice adjustments and corrections

Under RMC No. 98-2026, issued electronic invoices must not be deleted or changed. A reduction is documented through an authorised credit note or memo referencing the original invoice, while an increase requires a new electronic invoice. Further detailed rules on sales adjustments may follow in a separate BIR issuance.

Transition away from Official Receipts under the EOPT Act

Under the EOPT Act and RR No. 11-2024, a valid invoice, rather than a stand-alone Official Receipt, is the principal sales document for goods and services. Unused Official Receipts may, however, be converted into invoices and issued until the stocks are exhausted if the prescribed changes and data requirements are met.

Official Receipts can continue to be used as supplementary proof of payment. An unconverted Official Receipt is not a substitute for the required VAT invoice. A duly converted Official Receipt meeting the conditions of RR No. 11-2024 can operate as a valid invoice and may support input VAT claims.

Storage and statutory archiving

Under Tax Code section 235, as amended by the EOPT Act, and RR No. 7-2024, section 4, books of accounts and supporting accounting records, including invoices, must generally be retained for five years from the statutory return deadline or actual late filing date, as applicable. Where an audit, protest, tax credit or refund claim remains pending and records are material, retention extends until final resolution. Computerised records must be kept in electronic form. ESPs have additional access and preservation duties under RMC No. 110-2026.

Contingency and system downtime protocols

RMC No. 98-2026 requires BIR-authorised manual invoices when a covered taxpayer cannot issue electronic invoices owing to outages or similar disruptions. Once the system is restored, the manual invoices must be replaced with corresponding electronic invoices referencing the original manual invoice numbers. Record-keeping obligations remain in force.

When does electronic sales reporting apply?

Electronic invoicing concerns creating and sending a structured invoice to the buyer. Electronic sales reporting concerns transmitting sales information to the BIR’s Electronic Invoicing/Receipting System (EIS). Under RMC No. 98-2026, the two duties are legally separate; the 31 December 2026 deadline applies to invoicing, while mandatory EIS reporting requires further BIR rules or directions.

Data payload and syntax standards

For electronic sales reporting, the existing BIR EIS uses encrypted sales data in JavaScript Object Notation (JSON), as described in RR No. 8-2022. RMC No. 98-2026 allows taxpayers to use other structured formats within their invoicing systems as long as relevant information can be extracted and converted to the BIR-prescribed reporting format. PDF or image files alone do not replace the required structured sales data.

A sales reporting payload may contain the following transaction fields, subject to the current BIR technical specification:

• Header information: System ID, transmission timestamp, and taxpayer identification parameters.

• Line-item specifics: Product or service categorisation, item quantity, unit price, discounts, and item-level tax classification.

• Aggregated metrics: Total net consideration, zero-rated balances, exempt totals, total VAT charged, and total invoice value.

When does the three-day EIS reporting rule apply?

The EIS framework in RR No. 8-2022 is a post-issuance sales reporting mechanism rather than an invoice-clearance model. Its transmission time limit is relevant to taxpayers already subject to the applicable reporting requirement. The new December 2026 invoice issuance mandate is separate.

RR No. 8-2022 provides for sales data to be transmitted in real time or near real time, within three calendar days of the transaction for taxpayers required to report. However, RMC No. 98-2026 states that additional taxpayers become subject to electronic sales reporting only after separate BIR rules or instructions. The three-day limit is therefore not an automatic reporting deadline for every invoice issued by the December 2026 cohort.

Sales data transmission system and permits

A Sales Data Transmission System enables taxpayers required to report sales to send records to the BIR EIS. For the December 2026 invoicing cohort, RMC No. 98-2026 requires EIS Certification within six months of the PTI; a Permit to Transmit becomes necessary only when the BIR directs electronic reporting.

1. EIS Certification: Covered invoice issuers must have their systems tested and certified within six months of receiving their PTI Electronic Invoice. RMC No. 98-2026 identifies the EIS Certification Portal as the source of the applicable specifications.

2. Permit to Transmit (PTT): This permit is needed for live electronic sales reporting only once the Commissioner issues the applicable notification or directive. It is not automatically required for all taxpayers by 31 December 2026. RMC No. 98-2026.
   

Data payload and syntax standards

In accordance with Section 3 of RR No. 8-2022, the Philippine EIS operates on structured, machine-readable data payloads. Sales data transmitted to the central government platform must conform strictly to the JavaScript Object Notation (JSON) file format. Unstructured files, images, or standard text files will be rejected automatically by the BIR transmission gateway.

The JSON payload captures critical invoice metadata, including:

• Header information: System ID, transmission timestamp, and taxpayer identification parameters.

• Line-item specifics: Product or service categorisation, item quantity, unit price, discounts, and item-level tax classification.

• Aggregated metrics: Total net consideration, zero-rated balances, exempt totals, total VAT charged, and total invoice value.

Statutory transmission window (The 3-day rule)

Unlike strict clearance systems that block an invoice from being delivered to the buyer until the state assigns an authorisation token, the Philippine framework establishes a post-issuance continuous transaction control mechanism.

Under RR No. 8-2022, covered taxpayers must transmit their sales data to the BIR EIS in real time or within three calendar days from the date of invoice issuance. This provides operational resilience for commercial enterprises, allowing billing engines to operate smoothly even during temporary network interruptions, provided the sales data is synchronised within the three-day statutory envelope.

Sales data transmission system and licensing

To initiate electronic sales reporting, taxpayers must develop or configure a dedicated sales data transmission system capable of communicating with the BIR API. The system onboarding follows a strict two-tier compliance track:

1. EIS Certification (EIS CERT): The taxpayer submits their sales transmission application and underlying software modules to the BIR for automated technical validation, ensuring the system correctly generates JSON payloads matching BIR Schemas.

2. Permit to Transmit (PTT): Following successful test transmissions and certification, the BIR issues an official Permit to Transmit, granting the taxpayer production API credentials to begin live sales data feeds into the national database.

How does the e-invoicing and EIS architecture work?

The Philippine model is not an invoice-clearance system. Covered sellers issue structured electronic invoices directly to customers; a distinct EIS platform is used for sales reporting under the applicable rules. ESPs delivering commercial systems face additional solution-level accreditation under RMC No. 110-2026.

Component breakdown

1. Supplier invoicing system: A registered, approved or accredited system generates structured electronic invoices for customers. For electronic sales reporting, relevant data must be capable of conversion to BIR-prescribed JSON. Commercial ESP-operated solutions are subject to RMC No. 110-2026.

2. Buyer channel: The customer receives the electronic invoice through email, an online platform, a mobile app, QR-based access or another permitted electronic channel. A printed copy can be provided on request, including in certain B2C cases. RMC No. 98-2026 IV(4), (7).

3. BIR EIS reporting platform: Under the separately applicable reporting rules, authorised taxpayers transmit structured JSON sales data to the BIR. The EIS is not described in RMC No. 98-2026 as a universal pre-issuance invoice clearance service. RR No. 8-2022; RMC No. 98-2026.

Admissibility of electronic sales documents

RR No. 9-2022 governs the admissibility and validation of sales documents for taxpayers using the EIS. The rules apply within that system’s scope and do not change the separate timing of the future general sales-reporting rollout under RMC No. 98-2026.

• Taxpayers duly authorised to use EIS generally need not submit printed sales invoices when electronic records suffice. The BIR can still require physical copies or inspect systems in specified audit, fraud, missing-information or export-refund cases under RR No. 9-2022.

• Within the scope of RR No. 9-2022, EIS-validated purchase information is relevant to input VAT and allowable expense substantiation. The article must not imply that every Philippine buyer loses deductions today if a supplier has not reported a transaction to the EIS, since general reporting remains subject to future BIR rules.

• Under RR No. 9-2022, purchases in EIS scope that are not reflected in reported supplier sales may be treated as possible unreported sales and investigated. The regulation does not declare all unmatched purchases automatically invalid without investigation.

What are the penalties for e-invoicing non-compliance?

Different consequences may apply to failures to issue required invoices, late or missing sales reporting where an obligation is active, false tax declarations and breaches of ESP accreditation. These should be assessed separately rather than presented as a single automatic sanction scale.

Non-compliance sanction profile

1. Invoice issuance offences

• Tax Code Section 264(a) provides, on conviction, a PHP 1,000–50,000 fine and possible imprisonment for the specified invoice offences.

1. Electronic sales reporting

• RR No. 8-2022 provides for penalties for missing or late reports where the reporting duty applies, but no universal PHP 10,000–50,000 per-audit amount has been verified.

1. Tax fraud and other tax breaches

• Penalties depend on the precise act and applicable provisions; a 50% fraud surcharge is not the default response to every data error.

1. ESP accreditation breaches

• The BIR may order correction, limit new clients, suspend or revoke accreditation under RMC No. 110-2026.

Disallowance of input VAT and corporate expense deductions

RR No. 9-2022 sets EIS-specific substantiation rules for purchases within its scope. However, the absence of a universal e-sales reporting obligation under RMC No. 98-2026 means it would be misleading to state that all buyers automatically lose input VAT or income tax deductions when suppliers do not report sales into EIS. The applicable invoicing and deduction requirements must be assessed case by case.

Monetary fines under the tax code

• Failure to issue legally required invoices: Under Tax Code Section 264(a), specified failures or material invoice defects may result, upon conviction, in a fine of PHP 1,000 to PHP 50,000 and imprisonment of two to four years. This is a statutory criminal penalty, not a routine automatic administrative charge.

• Failure to report sales data: RR No. 8-2022 provides for penalties when mandatory electronic sales reporting is late or omitted. The applicable offence, amount and reporting trigger must be established from the relevant BIR rules; a universal fine under Section 275 cannot be assumed.

• Deliberate tax evasion or fraud: Depending on the conduct and evidence, the Tax Code may impose civil surcharges and criminal sanctions, including under Section 254. A 50% fraud surcharge must not be described as an automatic penalty for using uncertified software or for every under-reported amount.

Administrative sanctions: Oplan Kandado

Under Tax Code Section 115, the BIR may suspend business operations in defined circumstances, subject to legal conditions. A failure to use an accredited ESP or a late EIS transmission is not by itself established in the sources reviewed as an automatic five-day closure. Separately, RMC No. 110-2026 permits corrective action or suspension/revocation of an ESP’s accreditation.

How can businesses prepare for the 2026 deadline?

Covered businesses should prioritise the 31 December 2026 invoice issuance deadline, the separate PTI and EIS Certification stages, and, where they use third-party solutions, the new RMC No. 110-2026 accreditation requirements. They should not assume a universal sales-reporting go-live date.

Six-step system readiness roadmap

1. Execute an operational scope audit

Taxpayers should check their EOPT size category, LTS status, e-commerce activity and the use of CAS/CBA or other invoicing software. The RMC No. 98-2026 micro taxpayer exception applies to the December 2026 deadline. Covered head offices and branches must comply as a taxpayer group. Export activity alone may fall into a later stage unless the taxpayer is also covered by an initial category.

2. Standardise invoicing templates to uniform Invoices

Under RR No. 11-2024, invoices are the principal sales document for goods and services, but qualifying unused Official Receipts converted into invoices can continue to be issued until fully consumed. Billing systems should preserve valid serial numbers and show VAT and other invoice data as required.

3. Cleanse customer and supplier master data

Before issuing structured electronic invoices, businesses should review required supplier and customer tax details against their BIR registration records. Data accuracy also matters for future reporting, but universal EIS error patterns cannot be inferred from the rules.

• Registered seller details match BIR records, and buyer details are obtained where required.

• The seller’s TIN and relevant branch details are recorded in the format required for the taxpayer and transaction.

• Applicable registered names, business styles and addresses are recorded in the invoicing system.

4. Prepare structured invoice data and EIS readiness

IT teams should make sure that the system creates structured invoices, transmits them electronically to buyers and can extract sales data for EIS Certification. RMC No. 98-2026 permits various structured internal formats, provided data can be converted to the BIR-prescribed format for reporting. Live reporting and its three-day rule apply when directed.

5. Obtain PTI and EIS Certification; assess provider accreditation

Apply for the appropriate PTI Electronic Invoice with the relevant BIR office before issuing electronic invoices. The PTI does not replace a CAS registration. Secure EIS Certification within six months of the PTI date, otherwise PTI revocation is possible. The PTT is needed only when the BIR activates the applicable sales-reporting requirement. If buying or using an ESP-operated solution, verify the solution-specific BIR accreditation required by RMC No. 110-2026; it does not replace the taxpayer’s own PTI and EIS Certification. RMC No. 98-2026 governs the taxpayer sequence.

6. Assess CREATE MORE deductions

Under RR No. 11-2025, section 3(D), implementing the CREATE MORE Act, qualifying taxpayers that both issue electronic invoices and electronically report sales may claim a one-off additional deduction for the cost of setting up the electronic sales reporting system: 100% for micro and small taxpayers, or 50% for medium and large taxpayers. The deduction is available only once, in the tax year the system is completed or final payment is made. Buying an e-invoicing subscription alone does not establish eligibility.

Conclusion

The Philippines requires specified taxpayers to use structured electronic invoices by 31 December 2026 under the TRAIN, EOPT and CREATE MORE legal framework and the applicable BIR regulations. It is an electronic invoice issuance requirement, not a general invoice pre-clearance system.

Under RR No. 26-2025 and RMC No. 98-2026, covered businesses must obtain a PTI Electronic Invoice and prepare for EIS Certification within six months of permit issuance. A Permit to Transmit and live sales-data reporting apply only when separately directed by the BIR. Businesses using an external ESP solution must also check the accreditation rules introduced by RMC No. 110-2026.

Electronic invoice validity, BIR reporting and claims for input VAT or income tax deductions must be assessed under their respective rules. Companies should confirm which obligations apply to their systems and transactions, keep the required records and verify any ESP’s solution-specific accreditation status. RMC No. 98-2026 and RMC No. 110-2026 define the relevant taxpayer and provider duties.