E-Invoicing in the Philippines: What the December 31, 2026 Deadline Means for Your Business
The BIR’s e-invoicing deadline is December 31, 2026, and covered businesses need a Permit to Issue before they can issue a single e-invoice. Here is who is covered, what counts as an e-invoice, and what the BIR has not yet settled.
Starlight Admin
Information current as of October 21, 2026.
The BIR’s guide to electronic invoicing keeps the December 31, 2026 deadline and adds two steps before you can issue: a Permit to Issue and an EIS Certification. Here is who is covered, what counts as an e-invoice, and how to prepare.
Key takeaways
• Covered taxpayers must issue electronic invoices on or before December 31, 2026, under RMC No. 98-2026 (issued September 22, 2026). Micro taxpayers are exempt.
• A Permit to Issue (PTI) Electronic Invoice is required before you issue any e-invoice. The BIR has up to 20 working days to evaluate a complete application, and detailed filing guidance was still pending in early October.
• EIS Certification must be obtained within six months from the PTI’s issuance. Missing it is a ground for revoking the PTI.
• Invoices made by hand in Word or Excel do not qualify, and neither do printouts from a system that cannot send invoices electronically and report sales data to the BIR.
• Electronic sales reporting is a separate obligation with no date yet. The BIR now requires e-invoicing service providers to be accredited (RMC No. 110-2026), but accreditation does not replace your own PTI.
The e-invoicing deadline in the Philippines is December 31, 2026 for covered taxpayers, and the permit review alone can take up to 20 working days. If your business issues invoices from software, now is the time to find out whether you are covered and what you need to file.
The Rules at a Glance
The BIR’s e-invoicing framework rests on Section 237 of the Tax Code, implemented by Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025, and now explained in RMC No. 98-2026. RR No. 26-2025 gave covered taxpayers until December 31, 2026, and RMC 98-2026 confirms that date.
Two obligations are separate:
• Electronic invoicing (Section 237): issuing invoices as structured electronic data. This is what the December 31, 2026 deadline covers.
• Electronic sales reporting (Section 237-A): transmitting sales data to the BIR. Covered taxpayers must comply only after the BIR issues separate implementing rules, which have not yet been released.
Who Must Comply by December 31, 2026?
Under RMC 98-2026, the covered taxpayers are:
• Taxpayers engaged in e-commerce or internet transactions, classified as Small, Medium, or Large (Micro taxpayers are exempt).
• Taxpayers under the Large Taxpayers Service (LTS).
• Taxpayers classified as Large Taxpayers under the EOPT Act (RA 11976) and RR No. 8-2024.
• Taxpayers using a Computerized Accounting System (CAS) or Computerized Books of Account (CBA) with accounting records (with electronic invoicing), and other invoicing software.
• Other taxpayers as the Commissioner may require.
The requirement applies to the taxpayer as a whole. The head office and every branch must issue electronic invoices, even if the covered activity happens at only one branch.
Taxpayers who are not required to comply by the deadline may adopt e-invoicing voluntarily, but they must first secure a PTI from their Revenue District Office (RDO).
What Counts as an Electronic Invoice?
An invoice is an electronic invoice only if it meets all three conditions:
1. It is generated by a duly registered, approved, or accredited accounting or invoicing system, in a structured electronic format.
2. It is electronically generated and sent to the buyer in digital form (for example by email, online viewing, QR code, mobile app, or web platform).
3. Its data can be electronically extracted, processed, and transmitted to the BIR for sales reporting.
A few points from the circular that businesses often miss:
• Invoices made by hand in Word, Excel, Google Docs, or Google Sheets do not qualify, however professional they look.
• A printed invoice from a CAS, POS, or invoicing system is not an electronic invoice if the system cannot both send the invoice electronically to the buyer and report the sales data to the BIR. Those invoices stay under the rules for non-electronic invoicing.
• Paper is still allowed. A printed copy may be given to the buyer, including for business-to-consumer sales where electronic delivery is not practical, as long as the original invoice was generated and can be issued electronically and all e-invoicing requirements were met. The seller must provide a printed copy if the buyer asks for one.
• The BIR system uses JSON for data transmission. Your software may keep other structured formats internally, as long as the sales data can be converted to the BIR’s format. The circular says the data requirements are not meant to change the information shown on invoices, and notes that the data includes details such as discounts and withholding taxes.
• Corrections are made by a separate document. A decrease is handled with a credit note or memo, and an increase with a new electronic invoice. An issued electronic invoice must not be deleted, altered, or modified.
• A compliant e-invoice is valid proof of the transaction. The circular recognizes an electronic invoice issued through a system with a PTI as valid proof of transaction for tax and substantiation purposes, provided it meets the definition, contains the required information, and its validity can be verified electronically or manually as the BIR may prescribe.
• If your system goes down (including internet or power problems, or a cybersecurity incident), you must issue a BIR-authorized manual invoice and later replace it with a matching electronic invoice that carries the manual invoice’s reference number.
Related: RR No. 6-2026 now requires creditable withholding tax to be shown as a separate item on invoices where it applies, so make sure your e-invoicing setup includes that line.
The Two Steps Before You Can Issue
1. Permit to Issue (PTI) Electronic Invoice. You must secure a PTI before issuing any electronic invoice.
• File with the RDO or Large Taxpayer Office where you are registered, with the required documents.
• The BIR has 20 working days to evaluate a complete application.
• The PTI names the approved system. Changing or replacing that system requires a new or amended PTI.
• If different branches or segments use different invoicing systems, each distinct system needs its own PTI. Branches using the same approved system share the same PTI number.
• A PTI is separate from a Permit to Use or Acknowledgement Certificate for a CAS. The PTU or AC covers use of the system but does not by itself authorize issuing electronic invoices.
2. EIS Certification. This confirms your system can extract, process, and transmit sales data.
• You must obtain it within six months from the PTI’s issuance. Missing this is a ground for revoking the PTI.
• The test has five mandatory tests, or seven if your system uses an API callback.
• The BIR’s certification portal is at eis-cert.bir.gov.ph.
A Permit to Transmit (PTT) is needed only later, when the Commissioner directs you to comply with electronic sales reporting.
Two practical cautions. First, the circular says the PTI application is supported by “prescribed documentary requirements,” but PwC noted on October 1 that specific PTI application guidance had not yet been issued, and we found no BIR issuance listing the requirements as of October 21, 2026. Ask your RDO what it currently accepts. Second, the circular requires covered taxpayers to issue e-invoices and comply with its provisions by December 31, 2026, and the PTI is required before any e-invoice is issued. The six-month EIS period runs from the date your PTI is issued, and PwC reads EIS Certification as not mandatory by December 31 itself. Confirm the timing for your case with your RDO or a licensed professional.
If you use a CAS, PwC also notes that enhancing it to issue and transmit e-invoices may count as a major system enhancement that requires a new Acknowledgement Certificate, which takes additional time.
What About Service Providers?
You may use an in-house system, a commercially bought solution, or an Electronic Invoicing Service Provider (ESP). Be careful with vendors:
• On September 14, 2026, the BIR publicly stated that it had not accredited, authorized, certified, recognized, or endorsed any entity as an official ESP, and warned against claims such as “BIR-accredited.”
• RMC No. 110-2026 (October 2026) then set an accreditation framework. Reports on it say an ESP must hold BIR accreditation before commercially deploying an e-invoicing solution, that accreditation lasts five years with annual review, and that fees must be disclosed before onboarding. They also say providers may not cut off your access to your records because of unpaid fees, a dispute, or a switch to another provider, and that vendor lock-in is prohibited.
• Timing matters. PwC noted on October 1 that no ESPs had yet been accredited, and KPMG reports that the BIR is accepting ESP accreditation applications only from October 16 to October 30, 2026. KPMG also notes that if an ESP’s accreditation lapses, a taxpayer’s PTI could be suspended, so ask how your provider handles renewal.
• Ask in writing whether your provider holds an accreditation certificate or has applied for one, and check the BIR’s official announcements. Even with an accredited provider, you still need your own PTI and EIS Certification.
An accredited provider helps; it does not replace your own PTI and EIS Certification.
If Your Classification Changes
Covered taxpayers keep their e-invoicing obligations even if their classification later changes, unless the BIR expressly reclassifies or exempts them. A taxpayer moved to a higher category, such as Medium to Large or enrolled in the LTS, must comply with that category’s requirements within a period set by the BIR, not less than six months from the reclassification. Moving down a category does not cancel an existing e-invoicing obligation.
Still Unsettled
• Electronic sales reporting has no date yet.
• PTI application details (documentary requirements and filing procedure) had not been published in what we found as of October 21, 2026.
• Rules for sales adjustments and for voluntary adoption procedures will come in separate issuances.
• Other taxpayer groups that RR No. 26-2025 treats separately, namely exporters, registered business enterprises availing of tax incentives, and POS system users, are to comply once the BIR has a system able to store and process invoice data, with dates to be set later, according to KPMG and PwC summaries. A business in one of these groups may still be covered through another category, such as using a CAS or other invoicing software. Please confirm your group with your accountant.
• A further extension could still be announced, since RR No. 26-2025 lets the Commissioner extend the period if deemed necessary, according to Grant Thornton. As of October 21, 2026, we have not found one, so plan as if the date holds.
A Practical Preparation Plan
The BIR’s own timing makes this tight, because the permit review alone takes up to 20 working days once your documents are complete. This timeline is our suggestion, not a BIR requirement:
• Now: Confirm your taxpayer classification and whether you are in the December 31 group. List every system that creates invoices, including branches. Ask your RDO what it currently requires for a PTI application.
• Early November: Ask your software or provider whether the system meets the three conditions above, can produce JSON output, and can show the creditable withholding tax line required by RR No. 6-2026. If you use a CAS, ask whether the change needs a new Acknowledgement Certificate.
• As soon as the BIR requirements allow: File the PTI application with your RDO or LT Office. The 20 working days start only when your documents are complete, so complete filings earlier are better.
• December: Train your staff, test your invoice process, and prepare a manual-invoice fallback for outages.
• After the PTI is issued: Schedule EIS Certification well inside the six-month window.
How Starlight Can Help
Our tax compliance and bookkeeping teams can help you confirm whether the deadline applies to you, review your invoicing setup against the BIR’s three conditions, and align your invoices with your books and filings, so your documents and your returns tell the same story. The rest of the BIR year is on our Philippine tax calendar.
Not sure whether the December 31 deadline applies to you? Book a compliance consultation or call 0917 631 8876, Mondays to Fridays, from our Makati office.
Frequently Asked Questions
When is the e-invoicing deadline in the Philippines?
December 31, 2026 for covered taxpayers, under RMC No. 98-2026, which confirms the date set by RR No. 26-2025. Micro taxpayers are exempt from the mandate.
Who must issue electronic invoices by December 31, 2026?
E-commerce and internet-transaction taxpayers classified as Small, Medium or Large; taxpayers under the Large Taxpayers Service; Large Taxpayers under the EOPT Act and RR No. 8-2024; taxpayers using a CAS or CBA with accounting records and other invoicing software; and others the Commissioner may require. The obligation covers the head office and all branches.
Does the December 31 deadline cover electronic sales reporting?
No. Electronic sales reporting under Section 237-A is a separate obligation. Covered taxpayers must comply with it only after the BIR issues its own implementing rules, which have not yet been released.
What is a Permit to Issue (PTI) Electronic Invoice, and how long does it take?
It is the BIR’s authority to issue electronic invoices through an approved system, and you need it before issuing any e-invoice. You file with your RDO or Large Taxpayer Office, and the BIR has 20 working days to evaluate a complete application. Detailed filing guidance was still pending in early October, so ask your RDO what it requires.
Can I keep issuing invoices from Word or Excel?
Not if you are covered. Invoices made manually in Word, Excel, Google Docs, Google Sheets or similar applications are not valid electronic invoices.
Is a printed invoice from my accounting or POS software an electronic invoice?
Only if the system can electronically send the invoice to the buyer and report the sales data to the BIR. Otherwise it is treated as a system-generated, non-electronic invoice. A printed copy of a properly issued electronic invoice is allowed.
Can I rely on a provider that says it is “BIR-accredited”?
Ask for proof. On September 14, 2026, the BIR said it had not accredited any provider, and RMC No. 110-2026 has since set up an accreditation framework, with provider applications open October 16 to 30, 2026. Even with an accredited provider, you still need your own PTI and EIS Certification.
What if my invoicing system goes down?
Issue a BIR-authorized manual invoice, then replace it with a matching electronic invoice that carries the manual invoice’s reference number once the system is restored.
This article is for general information only and is not tax advice. The BIR may issue further rules, so please confirm current requirements with the BIR or a licensed professional.
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