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, the compliance deadline for covered taxpayers was set at December 31, 2026.

On September 22, 2026, the BIR issued Revenue Memorandum Circular (RMC) No. 98-2026, which prescribes the detailed policies and guidelines for the issuance of electronic invoices under RR No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025. This Circular is the operative document that taxpayers must follow to achieve compliance.

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, RR No. 26-2025, and RMC No. 98-2026 #

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) amended the transitory provisions of RR No. 11-2025 and extended the compliance period for electronic invoice issuance to December 31, 2026.

RMC No. 98-2026 (September 22, 2026) prescribes the actual policies and guidelines for implementation. This Circular is the document that defines what an electronic invoice is, who must issue one, how to obtain authority to issue one, and what technical and operational rules apply. All covered taxpayers must adhere to this Circular.

The Commissioner of Internal Revenue retains the authority to further extend the compliance period if necessary.

Who Is Covered? #

RMC No. 98-2026 identifies the following taxpayers as covered by the mandatory electronic invoicing requirement:

1. Taxpayers engaged in e-commerce or internet transactions, classified as Small, Medium, and Large Taxpayers (Micro Taxpayers are exempted);
2. Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS) ;
3. Taxpayers classified as Large Taxpayers under Republic Act (RA) No. 11976 (Ease of Paying Taxes [EOPT] Act) and RR No. 8-2024;
4. Taxpayers using CAS or CBA with Accounting Records (with electronic invoicing), and other invoicing software;
5. Other taxpayers as may be required by the Commissioner of Internal Revenue.

Note for AccountingSuite users: If you use a CAS or CBA with electronic invoicing, you fall under item 4 and are covered by the December 31, 2026 deadline.

Who Is Exempt? #

Micro Taxpayers are exempted from the mandatory electronic invoicing requirement. However, taxpayers not mandatorily covered may voluntarily adopt electronic invoicing, provided they secure a Permit to Issue (PTI) Electronic Invoice from the concerned Revenue District Office.

The December 31, 2026 Deadline: What It Actually Covers #

All covered taxpayers, except Micro Taxpayers, must issue electronic invoices and comply with RMC No. 98-2026 on or before December 31, 2026.

Key clarification from RMC No. 98-2026: The obligation to issue electronic invoices under Section 237 of the Tax Code is separate and distinct from the obligation to comply with the electronic sales reporting requirements under Section 237-A of the Tax Code.

This means:

• By December 31, 2026, covered taxpayers must be capable of issuing electronic invoices.
• Electronic sales reporting (transmitting sales data to the BIR) will be required only upon the issuance by the Bureau of the implementing policies, guidelines, and procedures for that purpose.
• The requirement to secure a Permit to Transmit (PTT) applies only upon notification or directive from the Commissioner for compliance with electronic sales reporting.

In practice: The deadline is about being able to generate and deliver structured electronic invoices – not yet about automatically transmitting every invoice to the BIR via API. That second obligation will come later, with its own rules and timeline.

What Is an Electronic Invoice? #

RMC No. 98-2026 defines an electronic invoice as one that satisfies all of the following requirements:

1. Generated by a duly registered, approved, or accredited accounting/invoicing software or system in a structured electronic format;
2. Electronically generated and transmitted to the buyer in digital format through any of the following means: email, online viewing, Quick Response (QR) Code, mobile applications, web-based platforms, or other electronic means;
3. The invoice data is capable of being electronically extracted, processed, and transmitted to the Bureau for electronic sales reporting purposes.

What Is NOT an Electronic Invoice #

• Invoices created manually using office productivity applications – including but not limited to Microsoft Word, Microsoft Excel, Google Docs, Google Sheets, or similar applications – shall not be considered valid electronic invoices for tax compliance purposes.
• Invoices generated by a system but merely printed on paper without the capability to electronically issue and transmit the invoice to the buyer and electronically transmit or report the required sales data to the BIR are not electronic invoices. They are treated as invoices generated through a system and are subject to the rules applicable to non-electronic invoicing.

Printing Electronic Invoices #

The electronic invoice may be printed and furnished to the buyer for reference or record-keeping purposes, including in business-to-consumer (B2C) transactions where electronic transmittal is not practicable. However, this is valid only if the original invoice was generated and can be issued electronically and all electronic invoicing requirements have been complied with.

In addition, a printed copy of the electronic invoice shall be provided by the taxpayer-seller upon request by the buyer.

Structured Invoice Data: JSON and Other Formats #

Electronic invoices must be in a structured electronic format – meaning digital information organized in a set, predictable way so computers can easily read, sort, and use it.

RMC No. 98-2026 clarifies:

• The BIR’s existing EIS prescribes the use of the JavaScript Object Notation (JSON) file format for the transmission of sales data.
• Taxpayers whose electronic accounting or invoicing software or systems utilize other structured file formats may continue to use such formats for their internal operations, provided that the required sales data can be converted to and transmitted in the format prescribed by the BIR.
• The information required in the JSON file format is not designed to change the existing information reflected on the invoices of taxpayers. The data required in the JSON file format are primarily from the minimum required information to be indicated on the invoices under Section 113 of the Tax Code and RR No. 7-2024, including additional details relevant to most taxpayers (such as discounts, withholding taxes, etc.).

Important: This means the JSON format is the prescribed format for eventual transmission to the BIR, but it does not change what must appear on the invoice itself. The invoice content requirements remain governed by existing rules.

Permit to Issue (PTI) Electronic Invoice #

Taxpayers required to issue electronic invoices shall secure a Permit to Issue (PTI) Electronic Invoice from the BIR prior to the generation or issuance of electronic invoices.

What Is a PTI? #

The PTI is the authority granted by the BIR authorizing a taxpayer to issue electronic invoices that comply with the prescribed electronic invoicing requirements, through a duly registered and/or approved invoicing system.

The PTI is distinct from the Permit to Use (PTU) or Acknowledgement Certificate (AC) for CAS. The PTU or AC authorizes the use of a system but does not by itself constitute authority to issue electronic invoices.

How to Apply #

• The application shall be filed with the Revenue District Office (RDO) or Large Taxpayer (LT) Office where the taxpayer is registered.
• The application must be supported by the prescribed documentary requirements.
• The BIR shall evaluate the application and determine compliance within twenty (20) working days from receipt of complete documents.
• Upon approval, a PTI Electronic Invoice shall be issued specifying the approved software/system and its corresponding coverage.

Changes Requiring a New or Amended PTI #

Any change in the identity, name, platform, or core software/system details of the approved electronic invoicing software/system – including migration to, replacement with, or adoption of another electronic invoicing software/system – shall require the issuance of a new or amended PTI Electronic Invoice.

Head Office and Branches #

• A PTI Electronic Invoice shall be issued to the Head Office and each separate branch, all bearing the same PTI Electronic Invoice number and indicating the branch to which the PTI pertains.
• Where a taxpayer utilizes different invoicing software/systems for different branches, offices, or business segments, a separate PTI Electronic Invoice shall be secured for each distinct invoicing software/system.

Branches and Covered Activities #

For taxpayers with registered branch offices, including those whose covered business activities are registered as branch offices, compliance with RR No. 11-2025, as amended by RR No. 26-2025, shall apply to the taxpayer as a whole. Thus, the Head Office and all its Branch Offices shall be mandated to issue electronic invoices, regardless of whether the covered activity is undertaken at a particular branch.

EIS Certification #

All taxpayers required to issue electronic invoices shall obtain an EIS Certification to validate the capability of their electronic invoicing systems to electronically extract, process, and transmit sales data in accordance with RMC No. 98-2026 and the BIR’s prescribed technical standards.

What Is EIS Certification? #

The EIS Certification refers to the process that provides an environment for the online testing of the developed system by the taxpayer. It has five (5) mandatory tests, or seven (7) tests if with API callback.

Timeline #

Taxpayers shall secure an EIS Certification within six (6) months from the issuance of the PTI Electronic Invoice.

Failure to do so shall constitute a ground for the revocation of the PTI Electronic Invoice.

Portal #

The EIS Certification Portal, including the applicable technical specifications, guides, and requirements, may be accessed through:

https://eis-cert.bir.gov.ph

Permit to Transmit (PTT) #

The requirement to secure a Permit to Transmit (PTT) shall apply only upon notification or directive from the Commissioner for compliance with the electronic sales reporting requirements under Section 237-A of the Tax Code.

System Downtime and Manual Invoices #

In the event of system downtime, system unavailability, technical malfunction, internet connectivity issues, power interruption, cybersecurity incidents, force majeure events, or other circumstances that prevent the generation or issuance of an electronic invoice, the taxpayer shall issue a manual invoice duly authorized by the Bureau to document the transaction in accordance with Section 237 of the Tax Code.

Important: The occurrence of system downtime or technical issues shall not exempt the taxpayer from:

• The obligation to issue an invoice for every sale, barter, exchange, or transaction;
• Compliance with record-keeping and reporting requirements prescribed by the Bureau.

Upon system restoration, all manually issued invoices shall be replaced with corresponding electronic invoices bearing the reference numbers of the manual invoices.

Corrections and Adjustments #

Any correction or adjustment to an issued electronic invoice shall be made through a separate document that references the original electronic invoice.

• A decrease in the invoiced amount shall be effected through a duly authorized Credit Note/Memo.
• An increase in the invoiced amount shall be effected through the issuance of a new electronic invoice.

An issued electronic invoice shall not be deleted, altered, or modified.

The rules governing sales adjustments shall be prescribed through a separate revenue issuance.

Electronic Invoicing Service Providers (ESPs) #

Taxpayers shall have the option to use an in-house or commercially acquired electronic invoicing solution, or avail of the services offered by an Electronic Invoicing Service Provider (ESP) .

An ESP is defined as a juridical entity organized or duly licensed to do business in the Philippines that provides e-invoicing, sales reporting, integration, validation, transmission, storage, preservation, retrieval, reconciliation, migration, and audit-support services to taxpayers.

The ESP shall maintain an authorized representative and accountable technical, compliance, data-protection, and security officers in the Philippines.

Policies and guidelines governing ESPs shall be prescribed through a separate revenue issuance.

Reclassification Under the EOPT Framework #

All covered taxpayers shall continue to comply with the applicable electronic invoicing requirements notwithstanding any subsequent change in their classification under the EOPT framework, unless expressly reclassified or exempted by the Bureau through a separate issuance.

• Taxpayers reclassified to a higher category (e.g., Medium to Large, including enlisting in the Large Taxpayers Service) shall immediately comply with the requirements applicable to their new classification, including electronic invoicing and electronic sales reporting obligations, within such period as may be prescribed by the Bureau, which shall not be less than six (6) months from the date of reclassification.
• Taxpayers reclassified to a lower category (e.g., Small to Micro, Large to Medium, including delisting from the Large Taxpayers Service) shall continue to comply with the previously approved electronic invoicing requirement.

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 RMC No. 98-2026, 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

Important clarification from RMC No. 98-2026: The JSON/JWS/API transmission requirement applies to electronic sales reporting under Section 237-A. The obligation to issue electronic invoices (Section 237) is separate and distinct. The API transmission requirement becomes operative upon notification or directive from the Commissioner, and upon securing a Permit to Transmit.

A simple PDF invoice is not sufficient to meet the definition of an electronic invoice. The system must produce structured, cryptographically signed data and be capable of transmitting it programmatically to the BIR when required.

EIS vs. Electronic Sales Reporting System #

These are related but distinct obligations:

• EIS (Electronic Invoicing System) – governs the issuance of electronic invoices to customers. This is the obligation with the December 31, 2026 deadline.
• Electronic Sales Reporting System – governs the reporting of sales data to the BIR. This obligation becomes operative only upon the issuance by the Bureau of the implementing policies, guidelines, and procedures, and upon notification or directive from the Commissioner.

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.

Current Status #

• The BIR format and API for the Philippines EIS are still being finalized for general rollout.
• The December 31, 2026 deadline applies to the issuance of electronic invoices. The electronic sales reporting obligation (API transmission to the BIR) will come later, upon separate rules and notification.

What AccountingSuite Provides #

• BIR CAS-Ready functionality – supporting Philippine BIR requirements for computerized accounting, invoicing, books of accounts, and tax reporting.
• Structured invoice generation – enabling the production of invoices in structured electronic formats.
• Documentation to support your CAS registration and compliance processes.
• Monitoring of BIR issuances – we track RMC No. 98-2026 and related regulations to ensure our roadmap aligns with BIR requirements.

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 for the Philippine EIS API transmission will be available once the BIR opens the format/API for all covered taxpayers.

Preparation Checklist for Covered Taxpayers #

Use this checklist to prepare for compliance with RMC No. 98-2026 and the December 31, 2026 deadline:

• Determine your coverage – Are you covered under RMC No. 98-2026? (e-commerce, LTS, Large Taxpayer, CAS/CBA user, or as required by the Commissioner)
• Confirm your CAS/CBA status – E-Invoicing is separate from CAS registration. You may need both.
• Assess your current invoicing system – Can it generate structured electronic invoices? Does it have the capability to electronically transmit invoices to buyers?
• Apply for a Permit to Issue (PTI) Electronic Invoice – File with your RDO/LT Office with complete documentary requirements.
• Secure EIS Certification – Within 6 months from issuance of the PTI. Access the portal at https://eis-cert.bir.gov.ph.
• Prepare for system downtime – Ensure you have BIR-authorized manual invoices available and a process to replace them with electronic invoices upon system restoration.
• Establish correction procedures – Ensure your system can issue Credit Notes/Memos for decreases and new electronic invoices for increases.
• Document your compliance plan – Include milestones leading to December 31, 2026.
• Monitor BIR issuances – The Commissioner may issue further regulations, extensions, or implementing guidelines.
• Contact your software provider – Confirm their EIS roadmap and timeline.

Frequently Asked Questions #

Is the December 31, 2026 deadline final?
It is the current deadline under RR No. 26-2025 and RMC No. 98-2026. 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. A CAS Acknowledgement Certificate does not authorize you to issue electronic invoices – you need a separate PTI Electronic Invoice.

Are Micro Taxpayers required to comply?
Micro Taxpayers are exempted from the mandatory electronic invoicing requirement. However, they may voluntarily adopt electronic invoicing by securing a PTI Electronic Invoice.

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.

Can I just email a PDF invoice to my customer?
No. A PDF sent by email is not an electronic invoice unless it was generated by a duly registered/approved/accredited system in a structured electronic format, transmitted electronically, and capable of having its data electronically extracted and transmitted to the BIR. Invoices created manually in Word, Excel, Google Docs, or similar applications are not valid electronic invoices.

Can I print my electronic invoice for my customer?
Yes. The electronic invoice may be printed and furnished to the buyer for reference or record-keeping purposes, including in B2C transactions, provided the original invoice was generated and can be issued electronically and all electronic invoicing requirements have been complied with. A printed copy shall be provided upon request by the buyer.

What happens if my system goes down?
You must issue a BIR-authorized manual invoice to document the transaction. Upon system restoration, all manually issued invoices must be replaced with corresponding electronic invoices bearing the reference numbers of the manual invoices.

Can I correct an electronic invoice?
An issued electronic invoice cannot be deleted, altered, or modified. A decrease in the invoiced amount shall be effected through a Credit Note/Memo. An increase shall be effected through the issuance of a new electronic invoice.

Key Takeaways #

• Deadline: December 31, 2026 for covered taxpayers (except Micro Taxpayers) to issue electronic invoices.
• Legal basis: RR No. 11-2025, as amended by RR No. 26-2025, implemented by RMC No. 98-2026.
• Permit to Issue (PTI): Required before generating or issuing electronic invoices. Separate from CAS Permit to Use / Acknowledgement Certificate.
• EIS Certification: Required within 6 months from issuance of PTI. Portal: https://eis-cert.bir.gov.ph.
• Technical standard: JSON + JWS (RS256) + API transmission – for electronic sales reporting, which becomes operative upon separate rules and notification.
• E-Invoicing ≠ CAS registration – two distinct compliance areas.
• E-Invoicing ≠ Electronic Sales Reporting – two distinct obligations with different timelines.
• 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, RR No. 26-2025, and RMC No. 98-2026 as published by the BIR.