Philippines E-Invoicing Policy and Compliance Requirements 2026

The Bureau of Internal Revenue (BIR) has issued RMC No. 98-2026, providing important guidance on the implementation of electronic invoicing in the Philippines. It sets out the requirements for covered taxpayers. This blog explains which taxpayers must comply, what businesses need before issuing electronic invoices, and the key compliance requirements they need to follow.

Who Must Comply With E-Invoicing?

Under the current framework, the 31 December 2026 deadline applies to covered taxpayers, except Micro Taxpayers with below ₱3 million. The applicable taxpayer groups include:

• Small, Medium and Large Taxpayers engaged in e-commerce or internet transactions.
• Taxpayers under the jurisdiction of the Large Taxpayers Service.
• Taxpayers classified as Large Taxpayers under the Ease of Paying Taxes Act and related regulations.
• Taxpayers using a Computerized Accounting System (CAS), Computerized Books of Accounts (CBA) with accounting records and electronic invoicing, or other invoicing software.
• Other taxpayers subsequently designated by the Commissioner of Internal Revenue.

Note: Other taxpayers, including exporters, registered businesses with tax incentives, and POS users, will be covered later under a separate BIR framework.

What Qualifies as an Electronic Invoice?

The issued circular established three core requirements for an electronic invoice. It must be generated by a compliant system, transmitted electronically to the buyer, and contain data that can be electronically processed and transmitted to the BIR.

1. Generated by a compliant system: The invoice must be generated through duly registered, approved or accredited accounting or invoicing software or a system in a structured electronic format.
2. Electronically transmitted: The invoice must be issued to the buyer, purchaser or client in digital form through email, online viewing, QR code, mobile applications, web-based platforms or other electronic means.
3. Electronically extractable: The invoice data must be capable of electronic extraction, processing and transmission to the BIR for electronic sales reporting.

Is a PDF Invoice an Electronic Invoice?

Sending a PDF invoice digitally does not automatically make it a compliant electronic invoice. Under the BIR framework, an electronic invoice must be generated through a compliant invoicing system and contain data that can be electronically processed and transmitted to the BIR. 

Businesses may use structured electronic formats supported by their invoicing or accounting systems, provided the required invoice information can be electronically extracted, processed, and transmitted in the format prescribed by the BIR. 

Structured Data Format for Electronic Invoices 

Structured invoice data is information organised in a format that computers can read, process, and exchange without manual data entry. This is important because the BIR requires invoice information to support electronic processing and reporting.

The BIR Electronic Invoicing System (EIS) uses JavaScript Object Notation (JSON) for sales-data transmission. Businesses may use other structured formats in their accounting or invoicing systems, provided the required information can be converted into the format prescribed by the BIR.

Using JSON does not change the invoice information required under the Tax Code. Required details, including discounts and withholding taxes, still need to be provided as part of the invoice information and included in the data transmitted to the BIR.  

What Is the PTI Electronic Invoice?

The Permit to Issue (PTI) Electronic Invoice is the BIR permit that allows a covered taxpayer to issue electronic invoices through an approved invoicing software or system. The PTI must be obtained before electronic invoices are issued.

The application is filed with the appropriate Revenue District Office (RDO) or Large Taxpayer Office. The BIR evaluates a complete application within 20 working days.

The PTI identifies the approved invoicing system and its applicable coverage. If the approved system changes, such as through migration to another platform or changes to its core details, a new or amended PTI may be required. An existing CAS approval or permit does not replace the PTI Electronic Invoice requirement.

What Is Required After the PTI?

After obtaining the PTI Electronic Invoice, taxpayers required to issue electronic invoices must obtain an EIS Certification within 6 months.

The EIS Certification validates whether the taxpayer’s electronic invoicing system can electronically extract, process, and transmit sales data in accordance with the BIR’s requirements and prescribed technical standards.

The 6 -month period starts from the date the PTI Electronic Invoice is issued. Failure to obtain the EIS Certification within this period may result in the revocation of the PTI Electronic Invoice.

BIR Requirements for E-Invoicing and Sales Reporting

The issued circular distinguishes the obligation to issue electronic invoices under Section 237 of the Tax Code from the electronic sales reporting requirement under Section 237-A.

The 31 December 2026 deadline for electronic invoice issuance does not automatically trigger electronic sales reporting. Covered taxpayers will be required to comply with electronic sales reporting only when the BIR issues the corresponding implementing policies, guidelines, and procedures.

The Permit to Transmit (PTT) requirement applies only when the Commissioner issues a notification or directive requiring taxpayers to comply with electronic sales reporting under Section 237-A.

Businesses should therefore treat electronic invoice issuance and electronic sales reporting as separate compliance requirements, even though they are connected within the BIR's electronic invoicing framework.

PTI Requirements for Branches and Multiple Systems 

The electronic invoicing requirement applies to the taxpayer as a whole. Where a taxpayer has a head office and registered branches, the head office and branches are subject to the requirement even when the covered business activity is conducted at only one location.

For the PTI, the invoicing system used by the branches is relevant. If multiple branches use the same approved invoicing system, the same PTI number can apply to those branches, subject to the required BIR framework.

If different invoicing systems are used across branches, offices, or business segments, a separate PTI may be required for each distinct system. The taxpayer therefore needs to identify the invoicing systems used across its operations when preparing the PTI application.

What Happens During System Downtime?

A system outage does not remove the obligation to issue an invoice. Where electronic invoicing is unavailable because of system downtime, technical malfunction, internet connectivity problems, power interruption, cybersecurity incidents, force majeure or another circumstance that prevents electronic issuance, the taxpayer must issue a BIR-authorised manual invoice.

Once the system is restored, the manual invoice must be replaced with a corresponding electronic invoice that references the original manual invoice number.

Businesses therefore need a reconciliation process that connects manual invoices issued during downtime with the subsequent electronic invoices.

E-Invoicing Systems and Service Providers 

The issued circular established that taxpayers may use an in-house solution, commercially acquired electronic invoicing software, or an Electronic Invoicing Service Provider (ESP).

The BIR stated in its 14 September 2026 public advisory that it had not accredited, authorised, certified, recognised or endorsed any entity as an official BIR e-Invoicing Service Provider, partner, representative or solution provider.

Businesses should therefore distinguish between a provider's stated product capabilities and formal BIR accreditation or endorsement.

Key Preparation Steps for E-Invoicing 

The implementation requirements can be organised into the following areas:

1. Confirm taxpayer coverage: Determine whether the business falls within the current mandatory scope and identify all relevant branches.
2. Assess the invoicing system: Confirm that the system can generate structured invoice data, issue invoices electronically and support the required data extraction and processing.
3. Prepare the PTI application: Identify the exact software or system to be used and determine whether different branches or business units require separate PTIs.
4. Plan for EIS Certification: The certification must be obtained within 6 months of PTI issuance.
5. Prepare for downtime: Establish how BIR-authorised manual invoices will be issued and subsequently replaced with electronic invoices.
6. Control invoice changes: Ensure that issued invoices cannot be deleted or overwritten and that all adjustments reference the original invoice.
7. Separate invoice issuance from sales reporting: Treat the 31 December 2026 e-invoicing deadline separately from the future electronic sales reporting requirement.

Philippines E-Invoicing 2026: Key Compliance Dates

Note: The 31 December 2026 deadline comes from the amended transitory provisions under RR No. 26-2025, while RMC No. 98-2026 provides the operational requirements for implementation.

Conclusion

We recommend that covered businesses prepare their systems to meet BIR e-invoicing requirements and secure their Permit to Transmit (PTI) and EIS Certification before the 31 December 2026 deadline.

FAQ

Who is exempt from the Philippines e-invoicing mandate?
 Micro Taxpayers are exempt, but they can still adopt e-invoicing voluntarily.

Is a PDF invoice considered an electronic invoice in the Philippines?
 No, a PDF invoice sent by email does not qualify as an electronic invoice.

What is a PTI Electronic Invoice and when is it required?
 It is a BIR permit that allows a business to issue electronic invoices, and it must be obtained before issuing any electronic invoice.

Is electronic sales reporting required from 31 December 2026?
 No, the BIR will set a separate deadline for electronic sales reporting.

What happens if the e-invoicing system is unavailable?
 Issue a BIR-approved manual invoice, then replace it with an electronic invoice once the system is back.