The Philippines Bureau of Internal Revenue (BIR) published Revenue Regulations No. 26-2025, extending the deadline for mandatory issuance of structured e-invoices until 31 December 2026.
According to Revenue Regulations No. 11-2025, published earlier this year, certain taxpayers will be required to issue e-invoices in a structured data format that can be easily extracted and transmitted electronically to the BIR, enabling taxpayers to comply with the country’s CTC (Continuous Transaction Controls) e-reporting obligation once the mandate takes effect. Non-structured e-invoice formats such as PDFs will no longer be considered as e-invoices. There is no clearance requirement, nor is there a designated format for the issuance of structured e-invoices.
Taxpayers in scope were initially required to comply with the obligation from March 2026. However, with this extension, taxpayers will have until 31 December 2026 to comply with the structured e-invoicing requirements. All taxpayer originally mandated under RR No. 11-2025 are affected by the postponement:
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E-commerce and internet transaction businesses (Small, Medium and Large taxpayers; Micro taxpayers remain exempt)
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Large Taxpayers Service (LTS) taxpayers
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Large Taxpayers classified under the Ease of Paying Taxes Act (RA No. 11976)
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Users of computerized accounting systems (CAS), computerized books of accounts (CBA) with electronic invoicing, and other invoicing software
Other taxpayers will also be required to issue structured e-invoices, once a system capable of storing and processing the required data to be transmitted to the BIR is established:
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Exporters (under Sections 106 and 108 of the Tax Code)
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Registered Business Enterprises with tax incentives (Section 304(D))
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POS System users
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Other taxpayers as designated by the Commissioner
Electronic Sales Reporting System (CTC E-reporting)
Revenue Regulations 26-2025 reiterate that taxpayers will be mandated to comply with the Electronic Sales Reporting System (CTC E-reporting) requirement under Section 237-A of the Tax Code only after the BIR establishes its technical infrastructure. Separate regulations will be issued for this requirement. All taxpayer categories listed above will be in scope of this obligation.
The BIR has been running a pilot program since 2022, requiring selected taxpayers to report their sales data electronically in near real-time via the EIS (Electronic Invoice System). The timeline for expansion of this CTC e-reporting obligation to taxpayers in scope, outside the pilot, is still awaited.
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