Introduction #
The Bureau of Internal Revenue (BIR) of the Philippines has moved decisively toward mandatory electronic invoicing. With the issuance of Revenue Regulations (RR) No. 11-2025 and its amendment via RR No. 26-2025 (dated October 16, 2025), the compliance deadline for covered taxpayers has been extended to December 31, 2026.
This article explains what the E-Invoicing / Electronic Invoicing System (EIS) requirements mean for Philippine businesses, who is covered, what the technical requirements are, and how AccountingSuite is positioning itself to support early adopters.
Important distinction: E-Invoicing under the BIR’s EIS is separate from BIR CAS registration. These are two distinct compliance areas. A business may be CAS-registered and still be required to comply with EIS – and vice versa.
Legal Background: RR No. 11-2025 and RR No. 26-2025 #
RR No. 11-2025
RR No. 11-2025 established the framework for the mandatory issuance of electronic invoices by covered taxpayers and set out transitory provisions for compliance.
RR No. 26-2025 (October 16, 2025)
RR No. 26-2025 amends the transitory provisions of RR No. 11-2025 and extends the compliance period for electronic invoice issuance to December 31, 2026.
According to the BIR, this extension provides covered taxpayers with additional time to adjust their systems and transition to electronic invoicing. The regulation is effective immediately upon publication.
The Commissioner of Internal Revenue retains the authority to further extend the compliance period if necessary.
Who Is Covered? #
RR No. 26-2025 groups covered taxpayers into three categories, each with different obligations and timelines.
Category 1 – Extended until December 31, 2026 #
The following taxpayers are granted an extension until December 31, 2026 to comply with electronic invoicing requirements:
- Small, Medium, and Large Taxpayers engaged in e-commerce or internet transactions (Micro Taxpayers are exempted)
- Taxpayers under the Large Taxpayers Service (LTS)
- Taxpayers classified as Large Taxpayers under RA No. 11976 and RR No. 8-2024
- Users of Computerized Accounting Systems (CAS), Computerized Books of Accounts (CBA) with accounting records (with electronic invoicing), and other invoicing software
Note for AccountingSuite users: If you use a CAS or CBA with electronic invoicing, you fall under Category 1 and are covered by the December 31, 2026 deadline.
Category 2 – Required once the BIR system is established #
These taxpayers will be required to issue electronic invoices once a system for storing and processing the required data to be transmitted to the BIR is established (subject to separate regulation):
- Exporters under Sections 106 and 108 (excluding those under Section 3(A)(4) of RR No. 11-2025)
- Registered Business Enterprises (RBEs) availing of tax incentives under Section 304(D) (excluding those under Section 3(A)(4) of RR No. 11-2025)
- POS system users
- Others as may be required by the Commissioner
Category 3 – Electronic Sales Reporting System #
These taxpayers will be required to comply with the Electronic Sales Reporting System requirements once the corresponding BIR system is established (subject to separate regulation):
- Small, Medium, and Large Taxpayers engaged in e-commerce or internet transactions (Micro Taxpayers exempted)
- Taxpayers under LTS
- Taxpayers classified as Large Taxpayers under RA No. 11976 and RR No. 8-2024
- Users of CAS, CBA with electronic invoicing, and other invoicing software
- Exporters of goods and services
- Registered Business Enterprises under Section 304(D)
- POS system users
- Others as may be required by the Commissioner
What Is the December 31, 2026 Deadline? #
The December 31, 2026 deadline applies to taxpayers in Category 1. By this date, covered taxpayers must be capable of issuing electronic invoices in the format and through the transmission channel prescribed by the BIR.
Key implications:
- Businesses must adjust their accounting and invoicing systems to generate BIR-compliant electronic invoices.
- Systems must be capable of transmitting invoice data to the BIR through the prescribed API.
- The extension does not remove the obligation – it only moves the deadline.
4. Technical Requirements: JSON, JWS, and API Transmission #
The BIR’s EIS framework is built on modern, secure data-exchange standards. Based on published guidance and early adopter documentation, the technical requirements include:
| Component | Requirement |
|---|---|
| Data format | JSON (JavaScript Object Notation) |
| Security / signature | JWS (JSON Web Signature) using RS256 (RSA SHA-256) |
| Transmission | API-based transmission to the BIR |
| Transmission window | Within 3 calendar days of invoice issuance |
| Certification | EIS Certification and Permit to Transmit issued by the BIR |
These requirements mean that a simple PDF invoice is not sufficient. The system must produce structured, cryptographically signed data and transmit it programmatically to the BIR.
Status note: The BIR format and API are still being finalized for general rollout. Taxpayers who have already received BIR notification, an EIS Certification, or a Permit to Transmit are effectively early adopters.
EIS vs. Electronic Sales Reporting System #
These are related but distinct obligations:
- EIS (Electronic Invoicing System) – governs the issuance of electronic invoices to customers and the transmission of invoice data to the BIR.
- Electronic Sales Reporting System – governs the reporting of sales data to the BIR, typically for taxpayers using POS systems or similar sales-capture tools.
A taxpayer may be subject to one or both, depending on its classification and the systems it uses.
AccountingSuite’s Position #
AccountingSuite supports e-invoicing for multiple countries, and we are actively monitoring the Philippine EIS rollout.
Our current position:
- The BIR format and API for the Philippines EIS are still being finalized for general rollout.
- We work with early adopters. If you have already received:
- a BIR notification, an EIS Certification, or a Permit to Transmit.
- Contact us – we will prioritize your integration.
- Full support will be available once the BIR opens the format/API for all covered taxpayers.
We are committed to ensuring that AccountingSuite users are ready for the December 31, 2026 deadline.
Preparation Checklist for Covered Taxpayers #
Use this checklist to prepare for EIS compliance:
- Determine your category – Are you in Category 1, 2, or 3 under RR No. 26-2025?
- Confirm your CAS/CBA status – E-Invoicing is separate from CAS registration.
- Assess your current invoicing system – Can it produce JSON and JWS (RS256) output?
- Verify API capability – Can your system transmit data to the BIR within 3 calendar days?
- Check for BIR notification – Have you received an EIS Certification or Permit to Transmit?
- Contact your software provider – Confirm their EIS roadmap and timeline.
- Document your compliance plan – Include milestones leading to December 31, 2026.
- Monitor BIR issuances – The Commissioner may issue further regulations or extensions.
Frequently Asked Questions #
Is the December 31, 2026 deadline final?
It is the current deadline under RR No. 26-2025. The Commissioner may further extend it if necessary.
Does E-Invoicing replace BIR CAS registration?
No. They are separate compliance areas. You may need both.
Are Micro Taxpayers required to comply?
Micro Taxpayers are exempted from the e-commerce/internet transaction category under Category 1.
What if I already have a Permit to Transmit?
You are an early adopter. Contact AccountingSuite to prioritize your integration.
What happens if I miss the deadline?
Penalties may apply under the Tax Code and related regulations. Consult your tax advisor.
Key Takeaways #
- Deadline: December 31, 2026 for Category 1 taxpayers.
- Legal basis: RR No. 11-2025, as amended by RR No. 26-2025.
- Technical standard: JSON + JWS (RS256) + API transmission within 3 calendar days.
- E-Invoicing ≠ CAS registration – two distinct compliance areas.
- Early adopters with BIR notification, EIS Certification, or Permit to Transmit should contact AccountingSuite for prioritized integration.
- Full support will be available once the BIR finalizes the format/API for general rollout.
Need Help? #
If you have questions about EIS compliance or want to discuss your integration needs, contact us. We’re here to help you prepare for December 31, 2026.
Disclaimer: This article is for informational purposes only and does not constitute tax or legal advice. Consult a qualified tax professional regarding your specific situation. Regulatory details are based on RR No. 11-2025 and RR No. 26-2025 as published by the BIR.