The Philippines’ Bureau of Internal Revenue has issued Revenue Memorandum Circular No. 098-2026, setting out requirements for electronic invoicing, including taxpayer coverage, Permit to Issue and system certification requirements, technical standards, and procedures for corrections and system downtime, with mandatory adoption required by 31 December 2026.
The Philippines’ tax authority, the Bureau of Internal Revenue (BIR), has announced the issuance of Revenue Memorandum Circular No. 098-2026 on 22 September 2026, establishing the official framework for the issuance of electronic invoices in the Philippines.
It mandates that small, medium, and large taxpayers, particularly those involved in e-commerce, transition to digital invoicing systems by 31 December 2026.
Scope of coverage and exemptions
Mandatory e-invoicing applies to small, medium, and large taxpayers engaged in e-commerce or internet transactions, taxpayers under the Large Taxpayers Service, and large taxpayers covered by the EOPT Act and RR No. 8-2024.
It also covers taxpayers using computerised accounting systems, computerised books of accounts, or other invoicing software with e-invoicing capabilities, as well as taxpayers specifically designated by the Commissioner of Internal Revenue.
Micro taxpayers with annual gross sales below PHP 3 million are exempt from mandatory e-invoicing. Other taxpayers may voluntarily adopt electronic invoicing by obtaining a Permit to Issue. All taxpayers covered by the mandatory rules must fully transition to e-invoicing by 31 December 2026.
Essential requirements for a valid e-invoice
To qualify as a valid electronic invoice for tax compliance and substantiation under Section 34(A)(1)(b) of the Tax Code, an invoice must meet three core cumulative conditions:
- Structured format: Generated by a duly registered, approved, or accredited software/system in a structured electronic format.
- Digital transmission: Electronically generated and transmitted to the buyer or client via digital channels—such as email, online viewing, Quick Response (QR) codes, mobile applications, or web-based platforms.
- Data extractability: Invoice data must be capable of being electronically extracted, processed, and transmitted to the BIR for sales reporting.
- Non-compliant formats: Invoices manually prepared using office productivity tools (e.g., Microsoft Word, Microsoft Excel, Google Sheets) or paper-printed receipts from systems lacking electronic transmittal capabilities do not qualify as valid e-invoices.
Permit to issue (PTI) & system certification
Covered taxpayers must obtain a Permit to Issue (PTI) Electronic Invoice from their registered Revenue District Office or Large Taxpayers Office before issuing e-invoices. The BIR will evaluate complete applications within 20 working days, and a new or updated PTI is required when the core e-invoicing software is changed, migrated, or replaced.
Taxpayers must also secure Electronic Invoicing and Sales Reporting (EIS) Certification within six months of receiving the PTI to confirm system capability. Failure to obtain the certification within this period may result in PTI revocation.
Key operational rules & technical standards
- Data transmission: The BIR’s Electronic Invoicing System (EIS) requires sales data to be transmitted in JSON format. Taxpayers may use other structured formats internally, provided the data is converted to JSON before transmission.
- E-invoicing and sales reporting: E-invoicing under Section 237 is separate from electronic sales reporting under Section 237-A. Sales data transmission will only be required when specifically directed or notified by the BIR.
- Corrections and adjustments: Issued e-invoices cannot be deleted, altered, or modified. Reductions in invoiced amounts must be processed through an authorised Credit Note/Memo linked to the original invoice, while increases require a new e-invoice.
- System downtime: During system outages, power failures, or connectivity problems, taxpayers may issue authorised manual invoices. Once the system is restored, these must be replaced with corresponding e-invoices that reference the original manual invoice numbers.
- Paper copies: Sellers must provide printed copies of e-invoices upon the buyer’s request. Paper copies are also required for B2C transactions where electronic delivery is impractical.
