Everything You Need to Know About BIR E-Invoicing in the Philippines

This guide is updated as the BIR releases new e-invoicing issuances. Last updated: September 24, 2026 (covers RMC No. 98-2026). For general information only, not tax or legal advice.

The Bureau of Internal Revenue (BIR) has set a firm deadline for e-invoicing in the Philippines. Under RMC No. 98-2026, released on September 22, 2026 and effective immediately, covered taxpayers must issue electronic invoices on or before December 31, 2026.

RMC No. 98-2026 sets the foundation for the BIR's e-invoicing framework under RR No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025. It moves businesses toward invoices that are digital and structured, and prepares them for electronic sales reporting to the BIR in the future.

This matters most to businesses that already use accounting or invoicing systems, sell online, or fall under the Large Taxpayers Service. It also matters to the accountants, software providers, and implementation teams who will help these businesses make the transition.

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Who Is Required to Use BIR E-Invoicing?

The following taxpayers are required to comply by December 31, 2026:

1. Small, medium, and large taxpayers engaged in e-commerce or internet transactions. Based on the Circular's definition of e-commerce, this likely includes online sellers, marketplaces, digital-service businesses, delivery platforms, streaming services, and social-commerce sellers.
2. Taxpayers under the jurisdiction of the Large Taxpayers Service. 
3. Taxpayers classified as large taxpayers under the Ease of Paying Taxes (EOPT) Act and RR No. 8-2024, which generally covers businesses with gross sales of at least ₱1 billion.
4. Taxpayers using a Computerized Accounting System (CAS) or Computerized Books of Accounts with Accounting Records (CBA) with electronic invoicing, as well as those using other invoicing software.
5. Other taxpayers as may be required by the Commissioner of Internal Revenue.

Micro taxpayers are exempted from this mandate. They may still adopt e-invoicing voluntarily, but they must first secure a Permit to Issue (PTI) Electronic Invoice from their Revenue District Office.

Businesses using POS systems should also take note. The coverage includes taxpayers using "other invoicing software," and the Circular specifically mentions POS systems when describing which invoices qualify as electronic. POS users should check with their provider whether their system can issue and transmit invoices electronically. 

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What Is an E-Invoice According to the BIR?

Many businesses already send invoices by email, download PDFs from their accounting systems, or create invoices in Excel and convert them to PDF. These documents are digital, but they don't automatically qualify as BIR-compliant electronic invoices. E-invoicing is more than turning an invoice into an email attachment.

For a document to qualify as a BIR e-invoice, it must meet all three criteria:

1. It must be generated through a duly registered, approved, or accredited accounting or invoicing system. 
2. It must be issued to the buyer electronically (e.g. through email, a QR-enabled process, an application, or a customer portal). 
3. Its underlying data structure should be able to be electronically extracted, processed, and eventually transmitted to the BIR for sales reporting. 

What Is NOT Considered a BIR E-Invoice?

Many businesses assume their invoices are already electronic because they're sent by email or saved as PDFs. Under RMC No. 98-2026, that's not enough. The following are not considered valid electronic invoices:

• Invoices made in Word, Excel, Google Docs, or Google Sheets. The Circular explicitly states that invoices created manually using office productivity applications are not valid electronic invoices for tax compliance purposes.
• Manually prepared invoices converted to PDF and emailed. Saving a manually made invoice as a PDF and sending it to your customer doesn't make it an e-invoice. It still wasn't generated by a registered, approved, or accredited system.
• Scanned or photographed paper invoices. A digital image of a paper invoice is still a paper invoice. It has no structured data the BIR can extract or process.
• System-generated invoices that can only be printed. If your CAS, CBA, POS, or other invoicing software can only print invoices on paper, and cannot issue them electronically to buyers or transmit sales data to the BIR, those invoices are not e-invoices. They fall under the rules for non-electronic invoicing.
• Invoices issued before securing a PTI Electronic Invoice. Even if your system is fully capable, invoices issued before the BIR grants your PTI are not recognized as electronic invoices. Your existing PTU or Acknowledgement Certificate does not count as authority to e-invoice.

The simple test: an invoice qualifies as an e-invoice only if it passes all three checks. It must come from an approved system, be issued to the buyer electronically, and carry structured data that can be transmitted to the BIR. Failing any one of these means it's not an e-invoice.

What still counts: a printed copy of a valid e-invoice is fine. Buyers can request one, and sellers can provide printed copies in B2C transactions where electronic delivery isn't practical, as long as the original was generated and issued electronically.

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What Are the Requirements for BIR E-Invoicing?

RMC No. 98-2026 also defines a separate Permit to Issue (PTI) Electronic Invoice. This is different from the Permit to Use (PTU) or Acknowledgement Certificate (AC) that businesses receive for their CAS. A PTU or AC authorizes the use of the system, but it does not by itself authorize the business to issue electronic invoices.

The PTI Electronic Invoice authorizes a taxpayer to issue electronic invoices through its registered and compliant system, and it must be secured before any e-invoice is issued. Applications are filed with the RDO or Large Taxpayer Office where the business is registered, and the BIR will evaluate them within 20 working days from receipt of complete documents.

Another separate requirement is the Electronic Invoicing and Sales Reporting (EIS) Certification. This confirms that a system can electronically extract, process, and transmit sales data in line with the BIR's technical standards. Certification is done through online testing on the EIS Certification Portal (eis-cert.bir.gov.ph), with five mandatory tests, or seven if the system uses an API callback.

Here's a quick summary of each requirement and what it covers:

1. CAS, CBA, or Software Registration
   Whether the business is allowed to use its computerized accounting or invoicing setup.
   
2. PTI Electronic Invoice
   Authority to issue electronic invoices through the approved system.
   
3. EIS Certification
   Confirmation that the system can support the required structured-data and future sales-reporting capabilities. 

Businesses must secure their EIS Certification within six months from the issuance of their PTI Electronic Invoice. Failure to do so is a ground for revocation of the PTI.

Businesses shouldn't treat this stage as a paperwork exercise. It's an opportunity to review your software, invoice format, branch setup, user permissions, data quality, and transaction workflow before applying.

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What Special Cases Should Businesses Know About?

Changing your invoicing software

Businesses planning to change their invoicing software should time the move carefully. The PTI Electronic Invoice specifies the approved software or system it covers. Any change in the identity, name, platform, or core details of that system, including migrating to or adopting a different e-invoicing system, requires a new or amended PTI.

Branches

E-invoicing applies to the business as a whole. If a business is covered, its head office and all branches must issue electronic invoices, even if the covered activity only happens at one branch.

The head office and each branch will receive a PTI bearing the same PTI number, with each indicating the branch it pertains to. If different branches or business segments use different invoicing systems, a separate PTI is needed for each system. Opening new branches that use the same approved system does not require a new PTI number, as long as the business notifies the BIR under existing procedures.

Correcting an issued e-invoice

Once issued, an electronic invoice cannot be deleted, altered, or modified. Corrections must be made through a separate document that references the original invoice. A decrease in the amount is done through a Credit Note/Memo, while an increase requires issuing a new electronic invoice. The detailed rules on sales adjustments will come in a separate issuance.

When your e-invoicing system goes down

System downtime, internet outages, or power interruptions don't pause the obligation to issue invoices. When the e-invoicing system is unavailable, businesses must issue BIR-authorized manual invoices, so these should be kept on hand as a contingency.

Once the system is restored, every manual invoice issued during the downtime must be replaced with an electronic invoice that references the manual invoice number. Having backup invoices on file isn't enough. Businesses need a clear downtime process covering who issues manual invoices, how they're tracked, and how they're converted once the system is back.

Changes in taxpayer classification

Once covered, businesses stay covered even if their taxpayer classification changes under the EOPT framework, unless the BIR expressly exempts them. Taxpayers reclassified to a lower category, such as Small to Micro, must continue complying with their approved e-invoicing requirement. Taxpayers reclassified to a higher category, such as Medium to Large, must comply with the requirements for their new classification within a period set by the BIR, which will be no less than six months from reclassification.

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Can Businesses Comply Through a Third-Party Provider?

RMC No. 98-2026 states that businesses can comply with e-invoicing in two ways: by using their own electronic invoicing solution, whether developed in-house or commercially acquired, or by availing of the services of an Electronic Invoicing Service Provider (ESP).

ESPs are entities organized or licensed to do business in the Philippines. They provide e-invoicing, sales reporting, validation, transmission, storage, and audit-support services to taxpayers. They must also maintain an authorized representative and accountable technical, compliance, data-protection, and security officers in the Philippines. The policies and guidelines governing ESPs will be released by the BIR through a separate issuance. 

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What Is the Difference Between E-Invoicing and Electronic Sales Reporting?

The Circular creates a distinction between two related but separate obligations: 

1. Electronic invoicing: issuing compliant electronic invoices to customers 
2. Electronic sales reporting: transmitting structured invoice or sales data to the BIR. 

The December 31, 2026 deadline applies to electronic invoicing.

Meanwhile, electronic sales reporting will only be required once the BIR issues its implementing policies, guidelines, and procedures. A Permit to Transmit (PTT) will also only be required once the Commissioner issues a directive for sales reporting compliance.

Even though sales reporting isn't live yet, businesses should prepare for it now. A system that already produces clean, structured invoice data will be much better positioned once the BIR's rules, testing procedures, and transmission requirements for sales reporting take effect.

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What Is Still Pending From the BIR on E-Invoicing?

RMC No. 98-2026 isn't the full picture yet. These key items are still expected to be clarified in future BIR issuances:

1. What are the penalties for not meeting the December 31, 2026 deadline?
2. What are the requirements for a third-party provider to operate as an Electronic Invoicing Service Provider (ESP)?
3. The BIR requires an e-invoice to be generated through a duly registered, approved, or accredited accounting or invoicing system. Does this mean businesses have to be registered under a Computerized Accounting System (CAS) or similar?
4. Will the BIR recognize a model where a software provider has a platform-level approval or accreditation, while each taxpayer completes a lighter registration or authorization process?
5. What are the detailed rules governing sales adjustments for e-invoicing?
6. What are the guidelines for securing a PTI Electronic Invoice, and how will the process work in practice?
7. The Circular requires that the invoicing system be capable of electronically issuing and transmitting invoices to buyers. Does this mean invoices must be sent directly from the system itself, or is it enough to download an invoice generated by the system and email it separately?

What Should Businesses Do Now to Prepare for BIR E-Invoicing?

With the December 31, 2026 deadline approaching, implementation work should start as soon as possible. Here's what businesses should do now:

1. Confirm whether your business is covered. Check your taxpayer classification, whether you sell online, and whether you use a CAS, CBA, or other invoicing software. If you're unsure, confirm with your RDO.
2. Assess your invoicing process, not just your software. Review how invoices are created, approved, sent, and corrected today, including how each branch handles invoicing. Gaps in your process will show up during the PTI and EIS stages.
3. Ask your software provider the right questions. Can the system issue invoices electronically to buyers? Can it produce structured data in the BIR's JSON format? Is it ready for EIS Certification testing? Will switching to it require a new PTI?
4. Plan for the PTI and EIS Certification early. The BIR takes up to 20 working days to evaluate a complete PTI application, and EIS Certification must follow within six months. Starting in December leaves no room for revisions.
5. Keep your manual-invoice fallback in place. Make sure you have BIR-authorized manual invoices on hand and a clear process for replacing them with e-invoices once your system is restored.
6. Monitor further BIR issuances. Guidelines on PTI applications, ESPs, sales adjustments, and electronic sales reporting are still to come. Check the BIR website regularly, or bookmark this guide, since we update it as new issuances are released.

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Frequently Asked Questions About BIR E-Invoicing

1. What is the deadline for BIR e-invoicing?
   Covered taxpayers must issue electronic invoices on or before December 31, 2026, as set by RMC No. 98-2026.
   
2. Is e-invoicing mandatory for all businesses in the Philippines?
   No. It's currently mandatory for e-commerce businesses (except micro taxpayers), taxpayers under the Large Taxpayers Service, large taxpayers under EOPT, and taxpayers using CAS, CBA with electronic invoicing, or other invoicing software. Others may adopt it voluntarily.
   
3. Do micro taxpayers need to comply with e-invoicing?
   No. Micro taxpayers are exempt from the mandate. They may adopt e-invoicing voluntarily, but must first secure a PTI Electronic Invoice from their RDO.
   
4. Is a PDF invoice considered an e-invoice?
   Not automatically. A PDF only counts if it comes from a registered, approved, or accredited system, is issued electronically, and carries structured data that can be transmitted to the BIR. Invoices made in Word, Excel, Google Docs, or Google Sheets are not valid e-invoices.
   
5. What is a PTI Electronic Invoice?
   It's the BIR's authority for a taxpayer to issue electronic invoices through an approved system. It's separate from a CAS Permit to Use (PTU) or Acknowledgement Certificate (AC), and must be secured before issuing any e-invoice.
   
6. What is EIS Certification?
   It confirms that your system can extract, process, and transmit sales data to the BIR's technical standards. It must be secured within six months of your PTI being issued, or the PTI may be revoked.
   
7. Can I still give customers printed invoices?
   Yes. Buyers can request a printed copy of an e-invoice, and printed copies may be given in B2C transactions where electronic delivery isn't practical, as long as the original was generated and issued electronically.
   
8. What happens if my e-invoicing system goes down?
   You must issue BIR-authorized manual invoices during the downtime. Once the system is restored, each manual invoice must be replaced with an electronic invoice that references the manual invoice number.
   
9. Do I need a new PTI if I change my invoicing software?
   Yes. Any change in the identity, name, platform, or core details of your approved system, including switching to a different e-invoicing system, requires a new or amended PTI Electronic Invoice.
   
10. Do branches need their own PTI?
    The head office and each branch receive a PTI with the same PTI number. A separate PTI is only needed if a branch or business segment uses a different invoicing system.

E-invoicing isn't simply a PDF sent through email. It's an invoice generated by a compliant system, issued electronically, and backed by structured data that can support future reporting to the BIR. For covered taxpayers, the deadline to be ready is December 31, 2026.

Not sure if your business is ready? Juan by JuanTax is a CAS and EIS-ready accounting and tax software built for Philippine businesses, and a BIR-accredited Electronic Tax Software Provider (eTSP).

Book a call with one of our consultants to assess your e-invoicing requirements and map out your next steps.

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Update Log:

• [Sept 24, 2026]: Article published. Covers RMC No. 98-2026 on e-invoicing policies and guidelines.
• [Sept 22, 2026]: BIR Releases RMC No. 98-2026, new guidelines on e-invoicing and reiteration of December 31, 2026 deadline.
• [Sept 05, 2025]: BIR Releases RR No. 26-2025, BIR extends the e-invoicing compliance period to December 31, 2026, amending RR No. 11-2025.
• [Feb 25, 2025]: BIR Releases RR No. 11-2025, requirements for electronic invoice issuance and electronic sales reporting by covered taxpayers.
  
  

Latest issuance covered: RMC No. 98-2026 (September 22, 2026)