The Philippines is expanding mandatory electronic invoicing under rules administered by the Bureau of Internal Revenue (BIR). Covered taxpayers must comply with the electronic invoice issuance requirements on or before 31 December 2026. Electronic invoice issuance and electronic sales reporting are distinct obligations.
The BIR’s latest circular, Revenue Memorandum Circular (RMC) No. 98-2026, issued on 22 September 2026, sets out the detailed policies and guidelines for electronic invoice issuance under Revenue Regulations (RR) No. 11-2025, as amended by RR No. 26-2025. It confirms the 31 December 2026 deadline and sets out the rules on the Permit to Issue (PTI) Electronic Invoice and EIS Certification.
The mandate covers:
Micro Taxpayers are exempt from the mandatory issuance requirement, although other taxpayers may adopt electronic invoicing voluntarily, subject to obtaining a PTI. Coverage depends on taxpayer category and applicable regulations, not simply whether a sale is B2B or B2G.
These invoicing rules are part of a wider framework: the BIR’s Electronic Invoicing and Sales Reporting System (EIS), which covers both issuing electronic invoices and reporting sales data to the BIR.
The BIR launched the EIS as a pilot with selected taxpayers in 2022, and only those taxpayers currently report through it. Electronic invoice issuance is now mandatory for covered taxpayers by 31 December 2026, while mandatory sales reporting for everyone else (outside the pilot) will follow only once the BIR issues the relevant rules.
The end goal is for structured invoice data to flow to the BIR through the EIS, reducing paper invoices and supporting faster verification and audits.
For covered businesses, e-invoices must be generated through a registered, approved, or accredited invoicing system and made available to the buyer. Businesses must secure a Permit to Issue (PTI) which is the BIR’s authorization for a taxpayer to issue electronic invoices through a registered or approved invoicing system. The PTI is separate from the Permit to Use or Acknowledgement Certificate that covers an accounting system.
The BIR has clarified that electronic sales reporting is a separate requirement, with its own implementation arrangements. The BIR’s existing EIS uses the JSON format for sales-data transmission. Taxpayers whose systems use other structured formats internally may continue to do so, provided the required sales data can be converted to and transmitted in the format prescribed by the BIR.
Businesses should assess their ERP or invoicing systems, electronic delivery processes and Permit to Issue (PTI) Electronic Invoice application requirements before 31 December 2026. The BIR evaluates a complete PTI application within 20 working days, so early preparation is advisable. Covered taxpayers must then secure EIS Certification within six months from the issuance of the PTI; failure to do so is a ground for revocation of the PTI.
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The current BIR rules (RR No. 11-2025, as amended by RR No. 26-2025, and RMC No. 98-2026) do not set separate e-invoicing rules for sales to government entities. The electronic invoice issuance obligation depends on the supplier’s taxpayer category, not on whether the buyer is a private business or a government body.
Businesses that supply government entities should therefore check whether they fall within the covered categories and, if so, comply by 31 December 2026 like any other covered taxpayer.
Under the updated BIR framework, covered taxpayers should prepare to:
Use an appropriately registered, approved or accredited invoicing system
Generate structured electronic invoice data and deliver invoices electronically to buyers.
Provide a printed copy of the invoice when requested by the buyer
Secure a Permit to Issue Electronic Invoice before generating or issuing electronic invoices (a Permit to Use or Acknowledgement Certificate for a CAS does not by itself authorize this), and obtain EIS Certification within six months after the PTI is issued
Extract and convert invoice data into the JSON reporting format to enable sales reporting
Businesses need to prepare by ensuring their ERP or invoicing systems can generate and electronically issue structured invoice data and are capable of electronically extracting, processing and transmitting the required sales data in line with BIR technical standards. Mandatory electronic sales reporting, and the related Permit to Transmit, will apply only when the BIR issues the relevant implementing policies or directs the taxpayer to comply.
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The TRAIN Act establishes the legislative foundation for electronic invoicing and reporting.
The BIR launches the EIS pilot with selected large taxpayers.
RR No. 11-2025 introduces expanded electronic invoicing and reporting rules.
RR No. 26-2025 extends the electronic invoice issuance deadline to 31 December 2026.
RMC No. 98-2026 clarifies electronic invoice issuance, permits and certification.
RMC No. 110-2026 establishes the e-invoicing service provider (ESP) accreditation framework.
Businesses in the Philippines adopting e-invoicing benefit from reduced manual submission, faster reconciliation, and enhanced security with better validation.
Taxpayers should assess whether their invoicing software meets the applicable registration, permit and certification requirements and can support structured invoice data and future electronic sales reporting.
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Yes, for specified categories of taxpayers. The current deadline for covered taxpayers to comply with electronic invoice issuance requirements is 31 December 2026.
Taxpayers must use a compliant invoicing system, issue invoices electronically, and meet applicable BIR registration, permit and certification requirements. Electronic sales reporting obligations must be assessed separately: covered taxpayers must comply with electronic sales reporting only once the BIR issues the implementing policies, guidelines and procedures, except taxpayers already participating in the EIS pilot.