The Philippines Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 98-2026, providing detailed implementation rules for the country’s electronic invoicing framework.
Issued on 22 September 2026, the Circular confirms that the 31 December 2026 compliance deadline remains in place for the first group of covered taxpayers. It also provides practical guidance on electronic invoice requirements, the new Permit to Issue Electronic Invoice (PTI), EIS Certification, corrections, branches and system downtime.
The Circular builds on Revenue Regulations No. 11-2025, as amended by Revenue Regulations No. 26-2025.
Who Must Comply by 31 December 2026?
The 31 December 2026 electronic invoicing deadline applies to:
- Small, Medium and Large Taxpayers engaged in e-commerce or internet transactions, while Micro Taxpayers remain exempt;
- taxpayers under the jurisdiction of the Large Taxpayers Service (LTS);
- taxpayers classified as Large Taxpayers under the Ease of Paying Taxes Act and RR No. 8-2024; and
- taxpayers using a Computerized Accounting System (CAS), computerized books with electronic invoicing, or other invoicing software.
Other taxpayers may also be required to comply where specifically directed by the Commissioner of Internal Revenue.
Exporters, Registered Business Enterprises benefiting from tax incentives, POS users and certain other taxpayers are also covered by the broader framework, but their implementation may depend on further BIR system developments and regulatory issuances where they are not already included in the categories above.
What Qualifies as an Electronic Invoice?
RMC No. 98-2026 clarifies that simply preparing an invoice digitally or sending a PDF by email is not sufficient.
A compliant electronic invoice must be generated through a registered, approved or accredited accounting or invoicing system in a structured electronic format. The invoice must be capable of electronic issuance and delivery, while the underlying data must be electronically extractable and processable.
Invoices manually prepared therefore do not qualify.
A PDF or printed representation may still be provided to the customer, provided that the underlying invoice satisfies the electronic invoicing requirements.
A New Requirement: Permit to Issue Electronic Invoice
Before issuing electronic invoices, a covered taxpayer must obtain a Permit to Issue Electronic Invoice (PTI Electronic Invoice) from the relevant BIR Revenue District Office or Large Taxpayer Office.
The PTI is separate from an existing Permit to Use (PTU) or Acknowledgement Certificate for a Computerized Accounting System. An existing CAS registration therefore does not by itself authorize electronic invoice issuance.
The BIR is expected to process a complete PTI application within 20 working days, making the permit process an important part of implementation planning.
EIS Certification Must Follow the PTI
After obtaining the PTI, the taxpayer must obtain Electronic Invoicing and Sales Reporting (EIS) Certification within six months.
The certification process validates the system’s ability to extract and process the required invoice and sales data in line with BIR requirements. Failure to obtain certification within the prescribed period may result in revocation of the PTI.
Businesses should therefore design their invoicing systems with both current electronic invoicing requirements and future BIR reporting requirements in mind.
Electronic Invoicing and Electronic Sales Reporting Are Separate Obligations
One of the most important clarifications under RMC No. 98-2026 is that electronic invoicing and electronic sales reporting are separate obligations.
The 31 December 2026 deadline applies to the issuance of compliant electronic invoices by taxpayers currently within the mandatory scope.
It does not establish 31 December 2026 as the general mandatory start date for electronic sales data transmission to the BIR.
Mandatory Electronic Sales Reporting will apply once the BIR establishes the relevant system and issues the corresponding implementing rules.
Rules for Corrections and Adjustments
An issued electronic invoice should not simply be deleted, overwritten or modified.
Where an adjustment reduces the invoiced amount, an authorized Credit Note or Credit Memo must be issued. Where an adjustment increases the amount, a new electronic invoice must be created.
Businesses should ensure that their ERP and accounting processes support these correction flows rather than allowing amendments to the original invoice.
What Happens During System Downtime?
Where electronic invoicing cannot be used because of system downtime, connectivity issues, power interruptions, cybersecurity incidents or similar circumstances, taxpayers may issue a BIR-authorized manual invoice.
Once the electronic invoicing system becomes available again, the corresponding electronic invoice must be generated with reference to the manual invoice number.
Businesses should therefore maintain a compliant manual fallback process.
Branches Must Also Be Considered
Where a taxpayer falls within the mandatory scope, the requirement generally extends to its head office and registered branches.
If different branches or business units operate separate invoicing systems, separate PTIs may be required.
Businesses with multiple Philippine locations should therefore review their system structure before submitting their PTI applications.
What Remains Pending?
The Philippine electronic invoicing framework is still developing.
Most importantly, the BIR has not yet activated the general mandatory electronic sales reporting requirement. Separate implementing rules and procedures will govern that phase.
Further guidance is also expected for Electronic Invoicing Service Providers (EISPs), which will be particularly relevant for businesses using third-party invoicing platforms or middleware.
