1. Executive Overview
1.1 What is changing. The Bureau of Internal Revenue (BIR) introduced a mandatory e-invoicing framework via Revenue Regulation No. 11-2025 (25 Feb 2025). The Electronic Invoicing System (EIS) replaces manual, paper-based steps with secure, automated processes for creating, transmitting, validating, and reporting invoices and related fiscal documents.
1.2 How it works. The EIS is a centralized digital platform: eligible taxpayers must issue and transmit Sales Invoices, Official Receipts, Service Billings, Debit/Credit Notes/Memos using BIR-approved software, in a JSON data format that integrates directly with BIR systems for near real-time exchange and error minimization.
1.3 When to act. The rollout begins March 2026 for high-volume and priority taxpayer groups (Stage 1), with additional populations onboarding as BIR systems are ready (Stage 2). Organizations should engage now to secure software certification, obtain a Permit to Transmit (PTT), and align branch operations.
2. Scope and Phased Rollout
2.1 Stage 1 (from March 2026): High-volume and priority taxpayers.
- Online/digital sellers (e-commerce, marketplaces, digital services).
- Large Taxpayers Service (LTS) registrants.
- Major corporations (annual sales > PHP 1 billion, per Ease of Paying Taxes Act).
- Digital accounting users (BIR-approved computerized books and invoicing systems).
2.2 Stage 2 (date: BIR readiness dependent).
- Exporters of goods (Sec. 106) or services (Sec. 108), unless exempt.
- Incentivized enterprises under Sec. 304(D), unless exempt.
- POS-based retailers and other groups designated by the BIR Commissioner.
2.3 Branch rule (very important). If head office or any branch falls within covered categories, all locations must issue e-invoices. Planning, onboarding, and training should explicitly include branch-level processes and systems to avoid gaps.
3. Documents in Scope and Core Data Model
3.1 Document types. Sales Invoices, Official Receipts, Service Billings, Debit Notes/Memos, and Credit Notes/Memos.
3.2 JSON schema (mandatory fields).
- Document ID – unique identifier linked to the underlying transaction.
- Timing – issue date and precise timestamp.
- Party details – seller and buyer legal names, addresses, BIR registration numbers.
- Line items – goods/services description and quantities/units.
- Monetary summary – taxable bases, charges, discounts, adjustments, VAT or other tax details, and grand totals.
3.3 Canonical payload principle. The JSON serves as the authoritative representation used for validation, analytics, and audit—attachments may support, but do not substitute for, the structured data.
4. Security and Trust (JWS Digital Signatures)
4.1 JSON Web Signature (JWS). Each invoice payload is digitally signed by the taxpayer using a private key; the BIR validates integrity and authenticity using corresponding public keys.
4.2 Why it matters.
- Tamper detection ensures data has not been altered in transit or storage.
- Non-repudiation supports audit trails and dispute resolution.
- Interoperability aligns with international e-invoicing security practices.
5. End-to-End EIS Processing Flow
5.1 Create. Generate the JSON e-invoice in a BIR-certified solution (native ERP/AP or third-party platform).
5.2 Sign. Apply the JWS to the JSON payload.
5.3 Transmit.
- Manual: Upload via Electronic Sales Reporting System (eSRS); or
- Automated: Use API for immediate transmission.
5.4 Acknowledge/Remediate. Receive BIR confirmation (acceptance) or error notices for correction and resubmission.
5.5 Deadline. Submit within three (3) calendar days of the transaction to maintain compliance and ensure timely reporting.
6. Getting Accredited: Certification, PTT, and Software Capabilities
6.1 Access & onboarding.
- Register on the EIS Certification Portal (eis-cert.bir.gov.ph).
- Provide company approvals/authorizations and official IDs for authorized representatives.
- Confirm valid BIR registration numbers to unlock platform access.
6.2 Software approval. Your invoicing system must pass BIR testing and demonstrate:
- JSON generation aligned with the EIS schema and validation checks.
- JWS signing and cryptographic verification support.
- API integrations and stable connectivity to BIR gateways.
6.3 Permit to Transmit (PTT). After certification and verification, obtain the PTT to begin production transmission to EIS/eSRS.
7. Record-Keeping, Archiving, and Audit
7.1 Retention periods. Keep electronic records for ten (10) years from the last entry.
7.2 Hybrid archiving (years 1–5). Maintain printed backups for the first five (5) years to complement digital storage.
7.3 Digital-only archiving (after year 5). Purely electronic storage is permissible from year six, provided documents are readable, retrievable, and intact (including signatures, validation responses, and transmission logs).
7.4 Evidence package. Retain original JSON, JWS signature artifacts, BIR acknowledgments, error/repair logs, and system audit trails for examination.
8. Organizational Implications and Branch Readiness
8.1 Enterprise coverage. If any entity or branch qualifies under Stage 1/2 criteria, treat the entire network (head office + branches) as in scope for issuance capability and policy alignment.
8.2 Operating model. Align Tax, Finance, IT, and Operations on roles/responsibilities: who generates, who signs, who transmits, who reconciles, and who manages exceptions.
8.3 Controls and monitoring. Establish pre-send schema/rule checks, post-send acceptance monitoring, and exception queues for repairs within the 3-day submission timeline.
9. Compliance Timeline, Enforcement, and Incentives
9.1 Timeline.
- 2025: Regulation launched; certification pathways open.
- March 2026: Stage 1 go-live for priority taxpayers.
- Stage 2: Phased onboarding once BIR readiness is confirmed.
9.2 Enforcement. Late or incomplete adoption can lead to penalties, rework, and operational disruption (e.g., payment delays, bid disadvantages).
9.3 Incentives (as introduced under tax measures).
- Full cost deductions for eligible smaller firms.
- Partial deductions/credits for larger firms.
- Import waivers/operational reliefs tied to early compliance.
