BIR E-Invoicing Update: What the New Guidelines Mean for Your Business
On September 22, 2026, the Bureau of Internal Revenue issued new guidelines on electronic invoicing through Revenue Memorandum Circular (RMC) No. 98-2026, effective immediately. Later in October, it followed with separate accreditation rules for e-invoicing service providers under RMC No. 110-2026.
The circular explains the compliance process in more detail. It introduces a Permit to Issue (PTI) Electronic Invoice to be secured before issuing e-invoices, and an EIS Certification to be completed within six months of the PTI. It also clarifies what counts as an electronic invoice, and sets procedures for system downtime and for taxpayers whose classification changes.
The coverage and the deadline stay the same.
Key provisions of the new guidelines
A new permit comes first. Before issuing any e-invoice, covered taxpayers must now secure a Permit to Issue (PTI) Electronic Invoice. The BIR evaluates a complete application within 20 working days, so filing late eats directly into the time left before December 31.
Certification follows the permit. Within six months after the PTI is issued, taxpayers must obtain Electronic Invoicing and Sales Reporting (EIS) Certification. This confirms that the system can extract, process and transmit sales data. In the earlier pilot program, EIS Certification was the primary requirement for participating taxpayers. It is now the second step, completed after the PTI has been secured.
E-invoicing and sales reporting are separate obligations. Issuing e-invoices under Section 237 is distinct from electronic sales reporting under Section 237-A. Sales data needs to go to the BIR only when the BIR directs it, and separate rules for sales reporting will follow.
E-invoice qualifications are more clearly defined. An invoice printed from a system does not count if the system cannot send it electronically to the buyer and report sales data to the BIR. Many businesses using a CAS that simply prints invoices are therefore not yet compliant.
The whole business must be covered. The head office and every branch must issue e-invoices, even if only some branches carry out the covered activity.
JSON is the required format. Data sent to the BIR’s EIS must be in JSON. Other internal structured formats are acceptable as long as they can be converted.
Manual invoices are allowed during system downtime. During outages, connectivity problems or cybersecurity incidents, businesses may issue BIR-authorized manual invoices. These are later replaced by e-invoices that reference them, which means businesses need a documented downtime procedure and a stock of authorized manual invoices.
Reclassification does not end coverage. Taxpayers remain covered even if their EOPT classification changes, unless the BIR expressly reclassifies or exempts them. A drop in size does not automatically take you out of the mandate.
Taxpayers may choose their e-invoicing solution. Businesses may use an in-house system, commercial software, or an E-invoicing Service Provider (ESP). The BIR recently released the accreditation rules for ESPs.
New accreditation rules for e-invoicing service providers
In October 2026, the BIR issued a separate circular setting out how e-invoicing service providers are accredited and regulated. The rules apply to providers rather than to the businesses that issue invoices, taking effect immediately.
Accreditation is required before live use. A provider may not use an e-invoicing solution for live taxpayer transactions unless that specific solution has been accredited by the BIR. Accreditation is valid for five years and is subject to annual compliance reviews.
Some systems fall outside the framework. A system developed in-house, or software run on one taxpayer’s own infrastructure for itself and its branches, generally stays under the existing CAS and POS rules. A system offered to affiliates, subsidiaries, customers or other separate entities is treated as a provider service.
The approval process is thorough. Providers go through staged reviews of their documents, financial capacity, technical design, data privacy and cybersecurity, followed by a live demonstration and interoperability and load testing. They must also hold recognized information-security certifications and show a track record of handling high transaction volumes.
Data must reach the BIR within three days. Invoice and sales data must be sent in real time or near real time, and no later than three calendar days after the transaction. If transmission is interrupted, the data must be queued securely and resent within three days of the system’s restoration.
Taxpayers’ data is protected. Providers may not withhold or restrict access to a taxpayer’s data over unpaid fees, disputes or a change of provider. Hidden charges and excessive exit or migration fees are not allowed.
Taxpayer permits are still required. A provider’s accreditation does not replace the taxpayer’s own PTI Electronic Invoice and EIS Certification, although the provider is expected to help with the PTI application. Taxpayers also remain responsible for accurate invoicing and tax compliance, with limited penalty relief where a transmission failure is caused solely by an accredited provider and the taxpayer acted with reasonable diligence.
Recommended next steps
For businesses covered by the mandate, the new guidelines set out a clear order for getting compliant. Moving from paper or system-printed invoices to electronic invoicing involves three main steps:
1. Apply for the PTI Electronic Invoice at your Revenue District Office. The BIR evaluates a complete application within 20 working days.
2. Begin issuing e-invoices once the PTI is granted, by December 31, 2026.
3. Complete EIS Certification within six months of the PTI date.
Evaluation can take up to 20 working days from a complete application, so businesses planning to issue e-invoices by year-end may find it helpful to file in November or earlier.
Businesses that use, or plan to use, a third-party provider may also wish to confirm that the provider’s solution has been accredited by the BIR.
The Commissioner has the authority to extend the deadline. As of late October 2026, no extension has been announced, and December 31 remains the target date.
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