Philippines Sets Accreditation Rules for E-Invoicing Service Providers
The Philippines’ Bureau of Internal Revenue (BIR) has introduced a mandatory accreditation regime for providers of e-invoicing solutions. The requirement is set out in Revenue Memorandum Circular No. 110-2026, which took effect immediately upon issuance.
Under the circular, any company offering an e-invoicing solution must secure BIR accreditation before deploying that solution commercially. Accreditation is not granted to a provider in general terms: it attaches to the specific system, version, set of interfaces, and deployment configuration that the BIR reviewed and approved. A provider cannot rely on an existing approval to roll out a materially different setup without going back through the process.
Accreditation Standards and Duration
To be accredited, a service provider must demonstrate:
- Technical capability to operate the solution reliably
- Financial sustainability
- Adequate information security
- Business continuity planning
- Successful completion of system testing
Once granted, accreditation remains valid for five years. However, it is not a one-time check: accredited providers remain subject to annual compliance reviews and ongoing monitoring by the BIR for the duration of that period.
Safeguards Against Vendor Lock-In
A central aim of the circular is to prevent taxpayers from being trapped with a single e-invoicing provider. Accredited providers are barred from withholding, deleting, or restricting a client’s access to its own invoicing records on account of:
- Unpaid fees
- Contract disputes
- Contract termination
- A client’s decision to switch to another provider
Providers must instead support the transfer of a client’s data and audit trails without loss of information, without unreasonable delay, and without unreasonable cost.
Fee Transparency Requirements
The circular also imposes disclosure obligations on pricing. Fees charged by accredited providers must be transparent, reasonable, and disclosed to the client before onboarding begins. Any charges tied to exiting the service, retrieving data, or migrating to another provider must be spelled out in the service agreement itself.
Why This Matters
For finance and tax teams selecting an e-invoicing solution, the new rules mean that data access terms, migration conditions, and pricing transparency now form part of the compliance evaluation of a prospective provider, alongside technical fit.
The circular does not shift tax obligations onto the service provider. Even when using an accredited solution, the taxpayer remains responsible for issuing accurate invoices, maintaining proper records, and paying the correct amount of tax.
There’s more you should know about e-invoicing in the Philippines – learn more about the new and upcoming regulations.
