Philippines: New Rules on e-Invoicing and CTC e-Reporting Published

The Philippines Bureau of Internal Revenue (BIR) has published Revenue Regulations 11-2025, which implement changes to existing e-invoicing and CTC e-reporting obligations. The officially published regulation includes a few changes compared to its draft version.

The amendments made in the official version include:

1. Broader Taxpayer Scope: Taxpayers classified as Large Taxpayers under Republic Act No. 11976 and Revenue Regulations 8-2024 have now been included in the scope of e-invoicing and CTC e-reporting obligations. This was not explicit in the draft version.

2. Extended Penalty Provisions: Section 264, in addition to Section 264-A of the Tax Code, will be applicable in cases of violation or non-compliance with e-invoicing and CTC e-reporting obligations.

3. Deadline for e-Invoicing: Taxpayers engaged in e-commerce, Large Taxpayers under the Large Taxpayer Service (LTS), and Large Taxpayers under Republic Act No. 11976 and Revenue Regulations 8-2024 will have one year from the effective date of the regulation to comply with the requirement to issue e-invoices in a structured format that can be easily extracted and readily reported to the BIR. The draft version included taxpayers using Computerized Accounting Systems (CAS), Computerized Accounting Books (CBA), or any other invoicing software which are now no longer included in this deadline.

This means that from March 2026, structured e-invoicing becomes mandatory for companies engaged in e-Commerce and for all Large Taxpayers. No specific e-invoicing standard has been mandated.

While the official Revenue Regulations, like its draft version, do not set specific deadlines for the expansion of the Philippines CTC e-reporting obligation to the remaining taxpayers, they confirm that separate regulations mandating taxpayer compliance with both structured e-invoicing and e-reporting will be issued.

Therefore, it is expected that separate regulations will provide the deadlines impacting all taxpayers subject to the system.

Learn more about the current CTC e-reporting requirements in the Philippines.