Philippines services
If you run a business in the Philippines, you’ve probably been getting mixed signals on e-invoicing this year. Software vendors push urgent “get BIR-accredited now” emails. Your RDO points you back to the old Computerized Accounting System framework.…
If you run a business in the Philippines, you’ve probably been getting mixed signals on e-invoicing this year. Software vendors push urgent “get BIR-accredited now” emails. Your RDO points you back to the old Computerized Accounting System framework. Deloitte and PwC have said the BIR hadn’t finalized its policy or gotten the system fully operational.
On September 22, 2026, the BIR closed most of that gap. It issued RMC 98-2026, the implementing circular for BIR e-invoicing under RR No. 8-2022 and RR No. 11-2025 (which operationalizes Sections 237 and 237-A of the Tax Code as amended by the CREATE MORE Act, RA 12066), as amended by RR No. 26-2025.
The December 31, 2026 deadline hasn’t moved. What’s new is a real definition of a compliant electronic invoice, which systems qualify, and the registration steps to get there.
We work with around 500 SME clients across the Philippines. Until this circular, what actually counts as compliant was the most common question we heard. Here’s the updated read, based on the signed circular itself.
Group 1: firm deadline of December 31, 2026.
Group 2: no firm deadline yet, pending a BIR system capable of receiving the data.
Micro Taxpayers remain explicitly exempt under Section 4 of RR 11-2025, and RMC 98-2026 confirms this by excusing them from the December 31, 2026 requirement.
There’s also a tax incentive worth knowing about. Under Section 3(D), taxpayers who comply with both electronic invoicing and electronic sales reporting get an additional allowable deduction, on top of the ordinary deduction under Section 34(A)(1):
It can only be claimed once, in the taxable year the system is completed or paid for, and system imports are tax-exempt.
For months, the framework above looked tidy on paper but thin on operational detail. RMC 98-2026 spells out exactly what qualifies. An invoice counts as an Electronic Invoice only if it satisfies all three:
Invoices created manually using Microsoft Word, Microsoft Excel, Google Docs, or Google Sheets don’t qualify, no matter how polished the output looks to the buyer.
On file format: the BIR’s existing Electronic Invoicing and Sales Reporting (EIS) system runs on JSON. Other structured formats are fine for internal use, but the required sales data still needs to convert to, and transmit in, the JSON format the BIR prescribes. This doesn’t change the invoice information you’re already required to show under Section 113 of the Tax Code and RR No. 7-2024; it adds a few details most businesses already track anyway, like discounts and withholding taxes.
A printed copy is still allowed. You can print and furnish the electronic invoice to the buyer for reference or record-keeping, including in B2C transactions where electronic transmittal isn’t practical, as long as the original invoice was actually generated and issued electronically.
The rule was never that paper is forbidden. It’s that paper can’t be the only thing that exists.
Issuing electronic invoices under Section 237, and electronic sales reporting under Section 237-A, remain separate obligations. You only need to comply with electronic sales reporting once the BIR issues separate implementing rules for it, which hasn’t happened yet.
RMC 98-2026 also introduces two concrete registration steps, arguably the most actionable part of the whole circular.
1. Permit to Issue (PTI) Electronic Invoice, required before you issue a single electronic invoice.
2. EIS Certification, which validates that your system can actually extract, process, and transmit sales data.
Practically, the December 31, 2026 deadline isn’t the only date that matters. The PTI application and EIS Certification both need runway before it, not on it.
Most of the confusion in the market has sat in three places.
An electronic invoice is not just a PDF that looks digital. Emailing PDFs instead of printing paper invoices doesn’t make you compliant. The invoice data itself has to be structured and transmittable, not just delivered electronically.
Having a CAS does not mean you are already compliant. RDO officers often default to the CAS framework since that’s what they know. RMC 98-2026 is explicit: invoices from a CAS, CBA, POS system, or other software that get printed on paper aren’t electronic invoices unless the system can both electronically transmit the invoice to the buyer and report the sales data to the BIR. If it can’t do both, ordinary non-electronic invoicing rules apply, accredited CAS or not.
Electronic invoice issuance and electronic sales reporting are different obligations. The first, invoice issuance, is what the December 31, 2026 deadline covers. The second, sales reporting under Section 237-A, follows once the BIR issues separate implementing rules. RMC 98-2026 makes that separation explicit.
RMC 98-2026 answers a lot, but a few things are still pending separate issuances:
None of this is a criticism of the BIR. Rolling out a mandate this complex in phases is reasonable. It just means RMC 98-2026 is the current rulebook, not necessarily the last version of it.
If you’re in the immediate compliance group (LTS, large taxpayer under EoPT, e-commerce, or CAS user): RMC 98-2026 is no longer a framework to prepare for, it’s a specification to build against. The question isn’t “which BIR-accredited solution do I buy,” it’s “does my current system meet the three-part definition, and have I started the PTI application.” If the answer to either is no, that’s the gap to close before the deadline.
If you have multiple branches: compliance applies to your business as a whole, not branch by branch. Head Office and every branch are covered together, and different invoicing systems per branch each need their own PTI.
If you’re borderline or unsure (Medium taxpayer, basic accounting software, not under LTS, not e-commerce): you’re likely in the no-firm-date group. The most useful thing to do now is data hygiene: clean chart of accounts, accurate buyer TIN capture, consistent invoice fields, proper transaction tagging.
If your classification changes later, say Medium to Large, or you get enlisted in the Large Taxpayers Service, you get at least six months to comply with the new requirements. Moving down in classification doesn’t undo an existing obligation.
If you’re a Micro Taxpayer: you remain exempt under Section 4 of RR 11-2025. Nothing in RMC 98-2026 changes that. Adopting voluntarily still requires securing a PTI from your RDO first.
If your RDO gives an answer that doesn’t match RMC 98-2026: that’s a lag between a new circular and field-level rollout, not a reason to follow it. The written rule governs when there’s a conflict.
RMC 98-2026 finally gives businesses a real definition to build against, but it adds real registration steps too: a PTI application, a BIR review period, and an EIS Certification deadline that can put your permit at risk if missed. Confirming where your invoicing setup stands against all of that is a technical and procedural check most finance teams haven’t had to make before.
This is the kind of gap we help clients close as part of ongoing tax compliance work: reviewing what a client’s system actually produces against what the BIR now requires, and walking through the PTI and EIS Certification process itself. If you want a second opinion on where your invoicing setup stands, get in touch with us and we can walk through it with you.
Does RMC 98-2026 change the December 31, 2026 e-invoicing deadline?
No. RMC 98-2026 doesn’t move the deadline set by RR No. 26-2025. It defines what counts as a compliant electronic invoice and the registration steps to get there, not when compliance is due.
What is a Permit to Issue (PTI) Electronic Invoice, and do I need one?
It’s the BIR’s authorization to issue electronic invoices through a specific, approved software or system. If you’re required to issue electronic invoices, you need a PTI before you start, and a separate PTI for each distinct invoicing system you use across branches. You then have six months from PTI issuance to complete EIS Certification, or the BIR can revoke the PTI.
If I already have an accredited Computerized Accounting System, do I still need to do anything?
Possibly. An accredited CAS doesn’t automatically meet the RMC 98-2026 definition, and it doesn’t substitute for a PTI Electronic Invoice. Check whether your system can actually issue and transmit invoices electronically and report sales data to the BIR before assuming you’re covered.
Do I also need to comply with electronic sales reporting by December 31, 2026?
No. RMC 98-2026 governs electronic invoice issuance under Section 237. Electronic sales reporting under Section 237-A follows on a separate timeline the BIR hasn’t yet finalized, and a Permit to Transmit is only required once the Commissioner specifically directs you to comply.
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