Philippines Retains December 31, 2026 Deadline for Mandatory E-Invoicing

On September 22, 2026, the Bureau of Internal Revenue (BIR) of the Philippines issued Revenue Memorandum Circular (RMC) No. 98-2026, setting out guidelines on electronic invoicing under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025. The Circular, effective immediately, confirms that covered taxpayers must issue compliant electronic invoices through a registered invoicing system on or before December 31, 2026.

Who Is Covered by the Mandate

The mandate applies to:

• small, medium, and large taxpayers engaged in e-commerce or internet transactions (micro taxpayers are exempt),
• taxpayers under the jurisdiction of the Large Taxpayers Service (LTS),
• taxpayers classified as Large Taxpayers under the Ease of Paying Taxes (EOPT) Act and RR No. 8-2024,
• taxpayers using a Computerized Accounting System (CAS), Computerized Books of Accounts (CBA) with Accounting Records (with electronic invoicing), or other invoicing software,
• other taxpayers designated by the Commissioner of Internal Revenue.

The obligation covers the taxpayer as a whole, meaning the head office and all branches must issue electronic invoices, even if the covered activity is carried out at only one location. When different invoicing systems are used across branches, offices, or business segments, a separate PTI must be obtained for each system.

Taxpayers outside the mandate may switch to e-invoicing voluntarily, provided they obtain a Permit to Issue (PTI) Electronic Invoice from the relevant Revenue District Office (RDO) or the Large Taxpayer (LT) Office where the taxpayer is registered .

System Requirements

An invoice qualifies as an electronic invoice only if:

• It is generated in a structured electronic format by a registered, approved, or accredited invoicing system
• It is transmitted to the buyer electronically
• Its data can be extracted and transmitted to the BIR for electronic sales reporting

Invoices created in office tools such as Microsoft Word, Microsoft Excel, Google Docs, or Google Sheets are not valid electronic invoices for tax purposes. Neither are invoices generated by a CAS, CBA, POS system, or other software and then printed on paper, if the system cannot issue and transmit invoices electronically to the buyer and report sales data to the BIR. Such documents are treated as system-generated invoices and are subject to the rules for non-electronic invoicing.

For data transmission, the BIR prescribes JSON; other structured formats may be used internally if the data can be converted to JSON.

Taxpayers may use an in-house solution, a commercially acquired system, or an Electronic Invoicing Service Provider (ESP). An ESP must be a juridical entity organized or licensed to do business in the Philippines, with an authorized representative and accountable technical, compliance, data-protection, and security officers in the country. Detailed rules for ESPs will be issued separately.

Permit and Certification

Before issuing e-invoices, taxpayers must obtain a Permit to Issue (PTI) Electronic Invoice from the BIR. This permit is separate from the Permit to Use (PTU) or Acknowledgment Certificate (AC) for CAS, which authorizes the use of a system but does not, on its own, allow the issuance of e-invoices.

Within six months of receiving the PTI, taxpayers must obtain an Electronic Invoicing and Sales Reporting (EIS) Certification confirming that their system can extract, process, and transmit sales data in line with the Circular and the BIR’s technical standards. Failure to obtain it within the deadline may result in the revocation of the PTI.

An electronic invoice issued through an approved system with a PTI – whether delivered electronically or printed afterward – is recognized as valid proof of transaction and substantiation, provided it contains all required information and its validity can be verified.

Operational Rules

• Printed copies: The seller must provide a printed copy of an e-invoice at the buyer’s request. Printouts may also be used for reference or record-keeping, including in B2C transactions where electronic delivery is impracticable, as long as the invoice was generated and can be issued electronically.
• Corrections: An issued e-invoice cannot be deleted, altered, or modified. A decrease in the invoiced amount requires a duly authorized Credit Note/Memo, while an increase requires a new electronic invoice, both referencing the original document. Rules on sales adjustments will be issued separately.
• System downtime: In case of system failure, connectivity or power issues, cybersecurity incidents, force majeure, or similar events, the taxpayer must issue a BIR-authorized manual invoice. Downtime does not suspend invoicing, record-keeping, or reporting obligations. Once the system is restored, manual invoices must be replaced with electronic invoices bearing the manual invoice reference numbers.

Electronic Sales Reporting

The obligation to issue e-invoices is separate from the electronic sales reporting requirement. Covered taxpayers will need to report sales data electronically only after the BIR issues implementing guidelines. Similarly, a Permit to Transmit (PTT) will be required only upon notification or directive from the Commissioner.

What Taxpayers Should Do

• Determine whether the mandate applies to them and, if so, which of their branches and business segments are affected. Because the obligation extends to the entire organization, this assessment should cover all locations, not just the one where the covered activity occurs.
• Review their invoicing system's capabilities. It must generate invoices in a structured data format, deliver them electronically to customers, and support conversion to the JSON format prescribed by the BIR.
• Plan the certification process early, as the EIS Certification must be completed within six months of receiving the PTI.
• Establish written procedures for system outages, covering the issuance of BIR-authorized manual invoices and their subsequent replacement with electronic invoices referencing the manual ones.

Comarch E-Invoicing helps businesses prepare for e-invoicing mandates worldwide, including the upcoming requirements in the Philippines. Contact us to learn how we can support your compliance ahead of the December 31, 2026, deadline.

There’s more you should know about e-invoicing in the Philippines – learn more about the new and upcoming regulations.