BIR e-invoicing deadline 2026: who must comply and how

TL;DR: Covered taxpayers must issue compliant electronic invoices on or before 31 December 2026. Coverage turns on e-commerce activity, Large Taxpayer status and the accounting or invoicing system you use, not on who owns the company. Micro taxpayers are excluded. Invoices typed in Word or Excel never count as electronic invoices.

What the December 2026 deadline is

The BIR issued Revenue Memorandum Circular (RMC) No. 98-2026 on 22 September 2026. It sets out the rules for issuing electronic invoices under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025. The BIR’s media release of 23 September 2026 says the rules take effect immediately and that covered taxpayers must issue electronic invoices on or before 31 December 2026.

RR No. 11-2025, which the BIR digest dates to 27 February 2025, implements Sections 237 and 237-A of the Tax Code as amended by RA No. 12066 (CREATE MORE). Under that regulation, the first three groups were given one year from effectivity to comply. RMC 98-2026 sets the date for the first group at 31 December 2026. This guide relies on the circular’s description of RR No. 26-2025. Confirm its text against the regulation itself with the BIR.

Who must comply

RMC 98-2026 lists five groups of taxpayers that must issue electronic invoices:

1. Taxpayers engaged in e-commerce or internet transactions, classified as Small, Medium or Large Taxpayers.
2. Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS).
3. Taxpayers classified as Large Taxpayers under RA No. 11976 (the Ease of Paying Taxes Act) and RR No. 8-2024.
4. Taxpayers using a computerized accounting system (CAS), or a computerized books of accounts (CBA) with accounting records, with electronic invoicing and other invoicing software.
5. Other taxpayers the Commissioner of Internal Revenue requires to comply.

If a covered business activity is registered as a branch, the head office and all its branches must also issue electronic invoices, whether or not the activity happens at that branch.

The e-commerce test is wide. RR No. 11-2025 defines e-commerce to include the sale of goods and services through digital platforms, digital services supplied over the internet, and online freelance or professional services. A foreign-owned company that sells software, subscriptions or services online to Philippine customers should assume it falls within group 1 unless it is a micro taxpayer.

Foreign ownership is not part of the test. The coverage list does not mention it. Your company’s classification and its systems decide coverage, so start there rather than with the parent company’s structure.

Who is not covered

Micro taxpayers are excluded from the mandatory requirement. The circular says they may keep issuing registered manual invoices, and under RR No. 11-2025 they may use a CAS, cash register machine or POS system in place of electronic invoices.

Exporters, registered business enterprises with incentives and POS system users are on a later track. RR No. 11-2025 says they become subject to electronic invoicing only after the BIR has set up a system able to receive the data and has issued separate regulations. They are not in the RMC 98-2026 coverage list.

Taxpayers outside the mandatory groups may still issue electronic invoices voluntarily, but only after they secure a PTI from the Revenue District Office.

What makes an invoice a valid electronic invoice

RMC 98-2026 says an invoice counts as an electronic invoice only if it meets all three conditions:

• It is generated by a duly registered, approved or accredited accounting or invoicing software or system, in a structured electronic format.
• It is generated electronically and sent to the buyer in digital form, by email, online viewing, QR code, mobile app, web platform or another electronic means.
• Its invoice data can be extracted electronically, processed and transmitted to the BIR for sales reporting.

“Structured” means the data is organized so a computer can read it without manual entry. The BIR’s existing EIS uses JSON for transmitting sales data. Systems that use another structured format may keep it internally, provided they can convert the data to JSON.

Two things to get right:

• A PDF made by hand, or a Word or Excel file, does not qualify, even if it looks like an invoice.
• An invoice printed from a CAS, POS or other software does not qualify if the system cannot transmit it electronically or report the sales. Such an invoice is treated as a non-electronic invoice. A printed copy may still be given to a buyer who asks for one.

EIS Certification (the circular’s “Electronic Invoicing and Sales Reporting” certification) validates that a system can extract, process and transmit sales data. It runs as an online testing environment with five mandatory tests, or seven if the system uses API callback. The certification portal is at eis-cert.bir.gov.ph.

The deadline and what happens after it

Covered taxpayers must comply on or before 31 December 2026. After that date, the circular’s rules apply in full:

• A PTI must be in place before the company issues electronic invoices. Without one, the company does not have the authority to issue them.
• EIS Certification must be obtained within six months from the date the PTI is issued. Failing to do so is a ground for revoking the PTI.
• If the system goes down, the taxpayer must issue a manual invoice, duly authorized by the BIR, to document the transaction. Once the system is restored, each manual invoice must be replaced with an electronic invoice that carries the manual invoice’s reference number.
• A correction is made through a separate document that references the original invoice. A decrease uses a credit note or memo, and an increase uses a new electronic invoice. An issued electronic invoice must not be deleted, altered or modified.
• A taxpayer reclassified to a higher category must comply with the rules for its new classification within a period the BIR sets, which may not be less than six months from the reclassification.

The circular does not state a penalty figure for missing the deadline. Its text sets the deadline and the PTI and certification conditions, but it does not set a number. Confirm what non-compliance costs before you rely on any figure.

Practical steps for a foreign-owned subsidiary

1. Confirm your classification. Find out whether you are micro, small, medium or large, whether you sell online, whether you are in the LTS, and whether you are a Large Taxpayer under the EOPT framework. The circular does not restate the thresholds, so confirm them with the BIR and read the Ease of Paying Taxes Act guide for context.
2. Map your systems. List every system that produces an invoice: accounting software, billing tools, POS terminals and any ERP module. Each one is a separate question under the circular.
3. Choose a solution. The circular lets you use an in-house or commercially acquired solution, or a service from an Electronic Invoicing Service Provider (ESP). An ESP must be a juridical entity organized or licensed to do business in the Philippines, and it must keep authorized representatives and technical, compliance, data-protection and security officers in the Philippines. The BIR said a separate issuance on ESPs would follow, so check whether it has been released before you choose a vendor.
4. Apply for the PTI. The application goes to the Revenue District Office, or the Large Taxpayer Office, where you are registered. The BIR has 20 working days to evaluate a complete application. The PTI names the approved software and the branches that may use it. Each distinct system needs its own PTI, and any change of software needs a new or amended PTI. A new branch that uses the same approved software does not need a new PTI number, provided the BIR is notified.
5. Get EIS Certification within six months. The test window starts when the PTI is issued, so plan the certification along with the PTI application rather than after it.
6. Set your invoice rules. Decide how corrections, credit notes and printed copies will work before go-live, so the system and your staff follow the same process.

Start the PTI application well before December. A company that applies in late November leaves little margin if the BIR asks for documents or the vendor’s software needs a fix.

How this relates to your books of accounts

The circular defines a CAS as a system that runs the full accounting cycle, from the transaction through invoice issuance to financial reports. It also says that where an invoice is issued manually, the system or application involved is treated as a computerized books of accounts (CBA) with accounting records. So the choice of accounting software and the choice of invoicing system are linked, and one decision can affect both.

Two points follow for planning. First, keeping books in a CAS does not authorize e-invoicing, as explained above. Second, the circular treats e-invoicing and electronic sales reporting as separate requirements. The BIR said sales reporting for these groups will follow a later issuance. Plan for e-invoicing now, and watch for the sales-reporting rules separately.

For the record-keeping rules that apply to your books, see the books of accounts guide. For the broader classification rules, see the Ease of Paying Taxes Act guide. If your company sells online, the Internet Transactions Act guide covers the e-commerce side. A PTI application is filed with the office where you are registered, so if you are still setting up your registration, see the BIR Form 2303 guide for the certificate itself.

Next step

If your company falls within one of the five groups, the first job is a classification and systems review: which invoices you issue, from which systems, and whether each system can be PTI-approved and EIS-certified before December. Chamberlain can help with the compliance side of that work through our tax compliance services.

This guide is general information, not legal advice on your facts. The circular has been issued alongside several related regulations, so confirm the current BIR text before you file or change a system.