BIR Issues Guidelines on Electronic Invoicing Under RMC NO. 98-2026
On 22 September 2026, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 98-2026, prescribing the policies and guidelines for the issuance of electronic invoices under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025.
The Circular provides further guidance on the taxpayers covered by the electronic invoicing mandate:
Mandatory electronic invoicing by 31 December 2026
Under RMC No. 98-2026, the following taxpayers, except those classified as Micro Taxpayers, are required to issue electronic invoices and comply with the Circular on or before 31 December 2026:
taxpayers engaged in e-commerce or internet transactions that are classified as Small, Medium or Large Taxpayers;
taxpayers under the jurisdiction of the Large Taxpayers Service;
taxpayers classified as Large Taxpayers under the Ease of Paying Taxes Act and RR No. 8-2024 (taxpayers with annual gross sales of at least PhP1 Billion );
taxpayers using a Computerized Accounting System (CAS) or Computerized Books of Accounts with Accounting Records with electronic invoicing, and other invoicing software; and
such other taxpayers as may be required by the Commissioner of Internal Revenue.
CAS registration and authority to issue electronic invoices are separate
RMC No. 98-2026 expressly distinguishes the authority to use a CAS from the authority to issue electronic invoices.
A Permit to Use (PTU) or Acknowledgement Certificate (AC) authorizing the use of a CAS does not, by itself, authorize a taxpayer to issue electronic invoices. Taxpayers required to issue electronic invoices must separately secure a Permit to Issue (PTI) Electronic Invoice from the BIR before generating or issuing electronic invoices.
The application for a PTI Electronic Invoice must be filed with the Revenue District Office or Large Taxpayer Office where the taxpayer is registered. The BIR is required to evaluate compliance within 20 working days from receipt of complete documents.
Accordingly, taxpayers adopting or currently using a CAS should consider their CAS registration and electronic invoicing requirements as related but separate compliance requirements.
What constitutes a compliant electronic invoice?
An invoice will qualify as an electronic invoice only if it satisfies the requirements prescribed under RMC No. 98-2026. In general, it must:
be generated by a duly registered, approved or accredited accounting or invoicing software or system in a structured electronic format;
be electronically generated and transmitted to the buyer, purchaser or client through electronic means, such as email, online viewing, QR code, mobile application or web-based platform; and
contain invoice data capable of being electronically extracted, processed and transmitted to the BIR for electronic sales reporting.
The Circular likewise clarifies that an invoice generated through a CAS or other accounting or invoicing system and subsequently printed on paper will not qualify as an electronic invoice if the system does not have the capability to electronically issue and transmit the invoice to the buyer and electronically transmit or report the required sales data to the BIR.
Electronic invoicing is separate from electronic sales reporting
RMC No. 98-2026 expressly distinguishes the obligation to issue electronic invoices under Section 237 of the Tax Code from the obligation to electronically report sales data to the BIR under Section 237-A.
While covered taxpayers must comply with the applicable electronic invoicing requirements, electronic sales reporting will become mandatory only upon the BIR's issuance of the corresponding implementing policies, guidelines and procedures.
Accordingly, the absence of full implementation of electronic sales reporting does not defer the electronic invoicing requirements applicable to covered taxpayers.
EIS Certification
Taxpayers required to issue electronic invoices must also obtain Electronic Invoicing and Sales Reporting (EIS) Certification to validate the capability of their electronic invoicing systems to electronically extract, process and transmit sales data in accordance with BIR technical standards.
The EIS Certification must be secured within six months from the issuance of the PTI Electronic Invoice.
The requirement to obtain a Permit to Transmit (PTT), however, will apply only upon notification or directive from the Commissioner in connection with electronic sales reporting.
Taxpayers subsequently reclassified to a higher category
RMC No. 98-2026 also addresses taxpayers that are subsequently reclassified to a higher category.
A taxpayer reclassified to a higher category, such as from Medium to Large, including a taxpayer subsequently enlisted in the Large Taxpayers Service, must comply with the requirements applicable to its new classification within the period prescribed by the BIR. The prescribed compliance period shall be, at the minimum, six months from the date of reclassification.
If you have any questions or require any additional information, please Anna Rochelle D. Payongayong and Alexander O. Ner.
This alert is for general information only and is not a substitute for legal advice.
Connect with us:
Alexander O. Ner, JD
Senior Partner
alexner@val.law
Anna Rochelle D. Payongayong, CPA, JD
Junior Associate
annapayongayong@val.law
