The Latest Updates on BIR E-Invoicing in the Philippines
By:
Myla Hernandez, CPA
LAST UPDATED: September 25, 2026
This timeline will be updated as the BIR releases new issuances, clarifications, and implementation guidelines on e-invoicing. For general information only, not tax or legal advice.
The Bureau of Internal Revenue’s rollout on e-invoicing has been progressing through a series of laws, regulations, circulars, and implementation updates. Anchored in Sections 237 and 237-A of the Tax Code (originally introduced by the TRAIN Law, standardized under the Ease of Paying Taxes (EOPT) Act, and updated under the CREATE MORE Act), the mandate is executed through BIR regulations, including RR No. 8-2022, RR No. 11-2025, RR No. 26-2025, and RMC No. 98-2026.
This article serves as a guide to the timeline of every major government issuance that businesses need to track. From the initial legislative foundations of e-invoicing to the latest regulatory issuances from the BIR, here is what has changed, when it was changed, and what each development means for businesses.
E-Invoicing Update Timeline
DATE
KEY DEVELOPMENTS
December 31, 2026
Compliance Deadline — Covered taxpayers (LTS, EOPT Large, E-Commerce, and CAS/software users) must issue compliant electronic invoices.
View overview.
September 22, 2026
RMC No. 98-2026
— Prescribes operational mechanics for e-invoicing, including Permit to Issue (PTI) rules, 6-month EIS Certification, system downtime protocols, and multi-branch management.
View key points.
September 08, 2025
BIR Public Advisory — Clarifies that the BIR does not accredit, endorse, or certify any third-party entities as "Official BIR EIS Providers".
View key points.
September 05, 2025
RR No. 26-2025
— Formally extends the mandatory e-invoicing compliance period for covered taxpayers from the original transitory date of March 14, 2026 to December 31, 2026.
View key points.
February 25, 2025
RR No. 11-2025
— Implements the CREATE MORE Act (RA 12066), establishing the technical outline for electronic invoicing and granting tax deductions (50%–100%) for e-invoicing setup costs.
View key points.
January 22, 2024
EOPT Act (RA 11976)
— Standardizes the Sales Invoice as the single primary document for both goods and services while reclassifying Official Receipts as supplementary proof-of-payment documents.
View key points.
June 30, 2022
RR No. 8-2022
— Prescribes initial administrative policies and system requirements governing the Electronic Invoicing/Receipting System (EIS) initial mandate and pilot rollout.
View overview.
January 01, 2018
TRAIN Law (RA 10963)
— Introduces Sections 237 and 237-A to the Tax Code, establishing the original statutory foundation for electronic invoicing and electronic sales reporting.
View overview.
What Are the Key Issuances in the BIR E-Invoicing Timeline?
September 22, 2026 — RMC No. 98-2026 (Latest)
The Revenue Memorandum Circular No. 98-2026 functions as the detailed blueprint for Philippine e-invoicing. By defining permit workflows, branch handling, correction policies, and system downtime rules, the Circular connects high-level regulations with daily business operations.
Key Points
Defines a compliant electronic invoice:
An e-invoice is a system-generated document containing structured, extractable digital data issued to a buyer, rather than a static PDF or manually created file in Word, Excel, Google Docs, or Sheets.
Establishes key e-invoice requirements:
Outlines four operational standards:
Must originate from a BIR-registered or authorized system (such as CAS, CBA, or invoicing software).
Must be transmitted to the buyer electronically via channels like email, customer portal, app, or QR code.
Must contain structured, extractable data fields ready for future BIR processing.
Must maintain non-editable integrity where issued e-invoices cannot be overwritten, requiring a Credit Note/Memo for reductions or a supplemental e-invoice for additions.
Reaffirms covered taxpayers:
The mandate applies strictly to:
Small, Medium, and Large taxpayers engaged in e-commerce or internet-based transactions (Micro taxpayers remain exempt).
Taxpayers under the Large Taxpayers Service (LTS).
Large taxpayers classified under the Ease of Paying Taxes (EOPT) Act and RR No. 8-2024.
Taxpayers using a Computerized Accounting System (CAS), Computerized Books of Accounts (CBA) with electronic invoicing, or other invoicing software.
Establishes the firm compliance date:
Enforces December 31, 2026, as the mandatory deadline for covered taxpayers to issue electronic invoices to buyers, while clarifying that electronic sales reporting to the BIR remains a separate, future requirement.
Outlines compliance setup requirements (PTI, EIS, & ESPs):
Establishes the three main operational requirements:
Permit to Issue (PTI):
Requires covered taxpayers to apply for a dedicated PTI Electronic Invoice from the BIR before issuing e-invoices, as existing CAS approvals do not grant e-invoicing rights.
EIS Certification:
Mandates that taxpayers pass EIS Certification testing within six months of obtaining a PTI to prove software readiness for structured data exchange.
E-Invoicing Service Providers (ESPs):
Allows businesses to use in-house systems or third-party ESPs, while reiterating that the BIR does not accredit or endorse any vendor as an "Official BIR EIS Provider".
RMC No. 98-2026 transitions e-invoicing from a general tax policy to a functional reality. IT and Finance teams must now prioritize securing the proper BIR permits, establishing solid contingency processes for downtime, and guaranteeing their software stack generates valid, structured e-invoices before the December deadline.
September 8, 2025 — BIR Public Advisory on EIS Providers
The BIR issued an official Public Advisory that cautioned businesses about third-party vendors falsely claiming to be “BIR-accredited Electronic Invoicing Systems (EIS) Providers.” This was later reiterated by the BIR in a follow-up advisory on September 14, 2026, confirming that it has not endorsed, recognized, certified, authorized, or accredited any entity as an official BIR e-Invoicing Service Provider.
September 5, 2025 — RR No. 26-2025
Revenue Regulations No. 26-2025 formally extends the mandatory deadline for covered taxpayers to issue electronic invoices to December 31, 2026, from the initial transitory deadline of March 14, 2026. This was a result of recognizing the system configurations and technical complexities required across different industries.
This extension gives covered taxpayers additional time to coordinate with system providers, reconfigure their software, conduct gap analyses, and prepare for system testing ahead of the December 2026 deadline.
February 25, 2025 — RR No. 11-2025
Revenue Regulations No. 11-2025 establishes the official administrative outline for the country’s Electronic Invoicing and Electronic Sales Reporting System (EIS), providing the technical baseline on how electronic invoices must be generated, issued, and reported.
RR No. 11-2025 marks the transition from traditional document printing to structured data compliance. It signaled to finance teams that the central requirements for BIR compliance moving forward will be software readiness, system-to-system integration, and data extraction capabilities.
January 22, 2024 — Ease of Paying Taxes (EOPT) Act (RA No. 11976)
The Ease of Paying Taxes (EOPT) Act was signed into law in early 2024. It introduces reforms that affect invoicing requirements and forms the legislative foundation for modernizing tax administration.
For businesses, this reform means updating accounting systems, reissuing invoice templates, and aligning internal workflows around the Sales Invoice as the primary foundation for tax reporting.
June 30, 2022 — RR No. 8-2022
Revenue Regulations No. 8-2022 provides the initial administrative policies, system guidelines, and technical parameters governing the BIR’s Electronic Invoicing/Receipting System (EIS) initial mandate and pilot rollout.
RR No. 8-2022 defines the early technical requirements for e-invoice issuance and real-time sales data transmission to the EIS via standard Application Programming Interfaces (APIs). It serves as the operational testing ground that underlined system integration challenges and technical complexities across industries, laying the foundation for the improved guidelines and deadline extensions issued in succeeding revenue regulations.
January 01, 2018 — The Tax Reform for Acceleration and Inclusion (TRAIN) Law (RA No. 10963)
The TRAIN Law establishes the legal foundation for the digital tax administration in the Philippines by introducing Sections 237 and 237-A to the National Internal Revenue Code (Tax Code).
Section 237 legally mandates covered taxpayers to issue electronic invoices, while Section 237-A tasked the BIR with establishing a centralized Electronic Sales Reporting System. RA No. 10963 sets a statutory deadline for the BIR to build the infrastructure for electronic data exchange, initiating the multi-year regulatory transition toward mandatory Philippine e-invoicing.
What Are Other Government Developments Businesses Need To Watch?
May 2024 — Administrative Order No. 23
Administrative Order No. 23, as issued by Malacañang, established a digital and integrated national framework for the pre-border technical verification and cross-border electronic invoicing of all imported commodities entering the country.
Despite centering around “electronic invoicing”, AO No. 23 is distinct from the BIR’s domestic taxpayer e-invoicing mandate. The system is enforced by the Bureau of Customs (BOC) under the inter-agency committee chaired by the Secretary of Finance (DOF), governing cross-border import verification and foreign supplier invoices. Contrastingly, BIR rules regulate local sales invoices issued by domestic taxpayers to their local customers.
What Should Businesses Watch Next?
Development
Current Status
What to Watch For
Electronic Invoice Issuance
Dec 31, 2026 mandatory deadline for covered taxpayers
Preparing your systems and securing your Permit to Issue (PTI) before the December 31, 2026 deadline should not disrupt your daily business operations.
Book a call with a Juan by JuanTax consultant today to assess your software setup, configure compliant invoicing workflows, and create a seamless strategy ahead of the BIR deadline.
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