A Step-by-Step Guide on How to Get a BIR Permit to Issue (PTI) Electronic Invoice

This guide is updated as the BIR releases new e-invoicing issuances. Last updated: October 14, 2026 (covers RMC No. 98-2026 and RMC No. 110-2026). For general information only, not tax or legal advice.

Under Revenue Memorandum Circular (RMC) No. 98-2026 and Revenue Regulations (RR) No. 26-2025, covered taxpayers across the country must be fully capable of issuing electronic invoices on or before December 31, 2026. However, before businesses can generate or issue a single legal e-invoice, they must first obtain a dedicated Permit to Issue (PTI) Electronic Invoice from the Bureau of Internal Revenue (BIR).

Understanding the application process early can help your business identify the appropriate system, prepare the necessary supporting documents, and allow time for BIR review. The specific PTI documentary requirements and filing procedures should be confirmed against the applicable BIR issuance as these guidelines are released or clarified.

Key Takeaways

PTI Is Not CAS Registration: A Permit to Issue (PTI) is a separate BIR authorization specifically required to issue electronic invoices; an existing CAS permit or standard PDF invoice does not qualify. What is a PTI Electronic Invoice?
3-Step Application Process: Applying requires auditing system readiness and JSON data exports, compiling a preliminary documentary package, and filing at your RDO by mid-November 2026 to clear the 20-working-day review window. Learn more about the application process.
5 Mandated Taxpayer Categories: E-commerce merchants, LTS taxpayers, EOPT large taxpayers, CAS/POS software users, and CIR-designated entities are subject to mandatory compliance by December 31, 2026. View the mandated taxpayers.
What Makes an E-Invoice Valid: Valid e-invoices must use a structured, machine-readable format (like JSON) capable of electronic extraction and transmission—static PDFs or paper prints alone fail the compliance test. Find out what makes an e-invoice valid.
Head Office & Branch Rules: The e-invoicing mandate applies enterprise-wide; each branch receives its own PTI document tied to the primary Head Office PTI number, while separate software setups require separate applications. Read more about the rules.
Strict Post-Approval Timelines: Securing a PTI starts a 6-month clock to complete EIS integration testing, maintain post-downtime manual reconciliation protocols, and re-apply if you migrate to new software. Learn what happens after you receive your PTI.

What is a Permit to Issue Electronic Invoice?

A Permit to Issue (PTI) Electronic Invoice is a formal authorization from the BIR that allows a business to issue e-invoices using its system, whether an in-house platform, commercial software, or an Electronic Invoicing Service Provider (ESP).

Having an approved Computerized Accounting System (CAS) Acknowledgement Certificate (AC) or Permit to Use (PTU) does not grant a business the automatic legal right to issue structured electronic invoices. Additionally, static digital representations (e.g., manual PDFs) or system-printed paper invoices generated from a traditional CAS or POS that lack native electronic transmission capabilities do not qualify as legal e-invoices under current BIR rules.

A PTI confirms that your system formats data correctly, locks records against alteration, and produces structured files capable of interfacing with the BIR’s central database.

Step-by-Step Guide to Applying for a PTI

(Note: This section is based on consultations with the BIR. Final requirements for the PTI are yet to be issued by the BIR).

To successfully prepare and file your PTI application, follow these three key steps:

1. Audit System Readiness & Architecture

System Origin & ESP Verification: Identify whether your setup is an in-house platform, commercially acquired software, or an Electronic Invoicing Service Provider (ESP) that meets the applicable BIR requirements.
Structured Data Export & PTI Formatting: Confirm your system generates billing records in a structured format mapping directly to the BIR’s prescribed JSON schema.
System Controls & Data Transmission: Review how your system records issued invoices, prevents unauthorized alterations, and supports electronic transmission of invoice data. Confirm any additional technical requirements against the relevant official BIR issuance.
Adjustment Workflows: Confirm built-in support for generating authorized Credit Notes/Memos (for reductions) and supplemental e-invoices (for additions) that carry explicit cross-references to the original invoice number.

2. Prepare Your Application Documents

(Disclaimer: While official registration forms and final filing guidelines are pending release through a separate BIR issuance, covered taxpayers should organize a preliminary application package based on draft BIR guidelines.)

This is a preliminary checklist, not a finalized BIR document list.

Official PTI Application Form (pending final publication by the BIR)
System Architecture Diagram & Technical Data Flow Specifications (outlining how invoice data is generated, secured, and stored)
Sample Structured Electronic Invoice Output (demonstrating extractable, machine-readable JSON data formatting)
Copy of BIR Certificate of Registration (BIR Form 2303)
Copy of Existing CAS Permit to Use (PTU) or Acknowledgement Certificate (AC), if applicable

Note on Third-Party Software & ESPs: If you plan to use an Electronic Invoicing Service Provider (ESP), ask whether they are applying for accreditation under RMC No. 110-2026. As of this writing, the BIR has not yet accredited any ESP.

3. File Application with Your Jurisdictional BIR Office

Filing Location: Head Office’s Revenue District Office (RDO) or Large Taxpayers Office.
Processing Window: Up to 20 working days for official review per complete application package.

Filing Deadline Recommendation: With the mandatory December 31, 2026 deadline approaching, coupled with a 20-working-day review window and year-end government holiday schedules, taxpayers should submit complete application applications no later than mid-November 2026 to ensure timely approval.

What Are the Five Main Categories of Taxpayers?

Under RMC No. 98-2026, the mandatory e-invoicing requirement strictly applies to the following taxpayer categories:

E-Commerce and Digital Merchants Small, medium, and large taxpayers engaged in covered e-commerce or internet transactions, including online retail, social commerce, and digital services.
Large Taxpayers Under the Large Taxpayers Service (LTS) Taxpayers that are registered under the BIR’s Large Taxpayers Service (LTS).
Large Taxpayers Under the EOPT Framework Taxpayers classified as Large under the applicable Ease of Paying Taxes (EOPT) rules.
Computerized Accounting System (CAS) and Software Users Taxpayers using a Computerized Accounting System (CAS), Computerized Books of Accounts (CBA) with electronic invoicing modules, or specialized commercial invoicing software.
Commissioner-Designated Taxpayers Any other taxpayers specifically mandated through subsequent BIR directives or notices issued by the Commissioner of Internal Revenue.

What are Reclassified Taxpayers?

Taxpayer reclassification is a transition rule rather than a separate category of covered taxpayers. The applicable compliance timeline depends on the taxpayer’s reclassification and the relevant BIR rules.

Moving Up a Classification: Taxpayers scaling into a higher category receive a mandatory transition window of at least six (6) months to secure their PTI and implement e-invoicing.
Moving Down a Classification: Taxpayers reclassified into a lower threshold must continue using their approved e-invoicing system, as previously established e-invoicing obligations remain binding.

Exemptions and Voluntary Adoption: Micro Taxpayers

Taxpayers classified as "Micro" under the EOPT framework are exempt from mandatory e-invoicing under the applicable guidelines. They may continue issuing traditional BIR-registered manual paper invoices or opt to adopt e-invoicing voluntarily, subject to the applicable BIR requirements and approval process.

Not Yet Covered Taxpayers

Businesses should not assume that standalone POS use, export activities, or Registered Business Enterprise (RBE) status automatically exempts them from e-invoicing. Applicability and implementation timelines should be determined based on the relevant BIR rules and official guidance.

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Tax Incentive Tip: Under RR No. 11-2025 (implementing the CREATE MORE Act), eligible taxpayers may qualify for additional deductions on software setup costs, subject to the prescribed rates, eligibility requirements, and supporting documentation.

What Qualifies as a Valid E-Invoice under a PTI?

Securing a PTI requires proving that your software produces genuine, structured electronic invoices rather than static digital visual files. RMC No. 98-2026 sets out the following requirements:

Compliance Test	Requirement	What the BIR Evaluates
System Origin	Registered Invoicing System	The invoice must be generated through a qualifying invoicing system that meets the applicable BIR requirements. Businesses may use an in-house system, commercially acquired software, or an ESP, subject to the relevant rules.
Data Structure	Structured Electronic Format	Invoice data must be available in a structured, machine-readable format that supports electronic extraction, processing, and transmission. The system must be able to support the applicable BIR-prescribed data format.
Digital Delivery	Electronic Transmission	The invoice must be capable of being issued electronically to the buyer through an appropriate channel, such as email, an online portal, or another supported electronic method.
Extractability	Sales Data Transmission Ready	Invoice data must be capable of electronic extraction, processing, and transmission for the applicable BIR reporting requirements.

Important Clarification on PDFs and Printed Copies: A static PDF, photograph of a receipt, or system-printed invoice does not automatically qualify as a valid e-invoice. The underlying invoice must meet the applicable electronic invoicing requirements, including the ability to issue the invoice electronically and make the required data available for electronic processing and transmission. A human-readable PDF or printed copy may be provided to the buyer upon request, provided it represents an invoice that meets those requirements.

Rules for Branches and Multi-System Setups

The PTI Electronic Invoice reflects a business’s entire operational structure across locations:

Head Office vs. Branch Coverage: When a taxpayer is mandatorily covered, the obligation applies to the enterprise as a whole. Every registered branch, sales office, or operating unit must issue compliant electronic invoices.
Individual Branch Permits: Each registered branch receives its own official PTI document issued by the BIR, bearing the same primary PTI number assigned to the Head Office.
New Branch Additions: Opening a new branch using your existing, approved invoicing system does not require a new PTI number under the applicable guidelines. However, the BIR must be notified of the additional branch in accordance with the applicable registration procedures. Confirm the current notification process with your RDO before issuing e-invoices at the new site.
Multi-System Deployments: If a branch utilizes a separate invoicing tool or distinct standalone software, a separate PTI application must be filed specifically for that branch's system setup.

What Happens After You Receive Your PTI?

Securing your PTI Electronic Invoice initiates the next phase of ongoing e-invoicing compliance.

The 6-Month EIS Testing Clock

Once your PTI is issued, your business has exactly six (6) months to perform end-to-end integration testing and secure EIS Certification via the BIR EIS Certification Portal (eis-cert.bir.gov.ph). Failure to complete certification within this window risks permit revocation.

Electronic Sales Reporting vs. E-Invoicing

Obtaining your PTI and EIS Certification authorizes you to issue structured electronic invoices to buyers. Electronic sales reporting (automatically transmitting every sales transaction directly to BIR central servers) remains subject to specific, separate transmission directives issued by the BIR.

System Changes and Replacements

Your PTI is bound to the evaluated software platform architecture. If your business migrates to a new ERP, replaces its core invoicing provider, or makes fundamental operational modifications to its invoicing software, your existing PTI cannot cover the new setup. You must file a new or amended PTI application with the BIR prior to deploying the updated platform for live billing.

Downtime & Contingency Requirements

According to RMC No. 98-2026, every business operating under a PTI must maintain a clear contingency protocol since internet interruptions and system outages do not exempt a business from its legal obligation to issue invoices.

Manual invoices may be used during downtime in accordance with the prescribed requirements, with corresponding electronic invoices generated and reconciled after the system is restored.

Operational State	Standard Mandate	BIR Protocol
Normal Operations (System Online)	Issuance of Structured E-Invoices	Issue invoices electronically through the approved system and applicable delivery channel.
System Outage / Cyber Incident	Temporary Fallback Protocol	Follow the applicable procedure for issuing authorized manual invoices and maintain the required records during downtime.
System Restoration	Post-Downtime Reconciliation Protocol	Generate the corresponding electronic invoices and reference the original manual invoice numbers as required by the applicable BIR guidelines.

Prepare Your E-Invoicing Transition with Juan by JuanTax

Navigating BIR PTI requirements, system audits, and e-invoicing workflows requires reliable software architecture and tax expertise. With the December 31, 2026 deadline fast approaching, it is advisable for businesses to start preparing early in order to safeguard their daily operations.

Don’t wait for application queues to build up at your Revenue District Office. Book a call today to evaluate your system readiness, prepare your PTI documentation, and secure your permit well ahead of the BIR deadline.

If you want to learn more about E-Invoicing, Juan by JuanTax offers a free online course to help businesses beat the e-invoicing December 31, 2026 deadline. The course covers who is required to comply, what actually counts as a valid e-invoice, how to handle branches, system downtime, and corrections, and how Juan Accounting can help streamline your transition.