BIR RMC 98-2026 sets final implementation rules for 31 December 2026 launch
The Philippines Bureau of Internal Revenue (BIR) has issued detailed implementation rules for mandatory electronic invoicing under Revenue Memorandum Circular No. 98-2026. The 31 December 2026 compliance deadline remains unchanged.
The new Circular moves the regime from broad requirements to practical implementation, including what qualifies as an electronic invoice, system requirements, permits, certification and procedures for corrections and system downtime.
Who must comply by 31 December 2026?
The mandate covers:
- Small, Medium and Large Taxpayers engaged in e-commerce or internet transactions. Micro Taxpayers are exempt;
- taxpayers under the Large Taxpayers Service;
- taxpayers classified as Large Taxpayers under the Ease of Paying Taxes Act;
- taxpayers using Computerized Accounting Systems (CAS), Computerized Books of Accounts with accounting records and electronic invoicing, or other invoicing software; and
- other taxpayers subsequently designated by the BIR.
The deadline had previously been extended from March 2026 to 31 December 2026 under Revenue Regulations No. 26-2025.
What counts as a Philippine electronic invoice?
RMC 98-2026 clarifies an important point: simply creating a PDF invoice and sending it electronically does not make it a compliant electronic invoice.
A qualifying invoice must be generated through a registered, approved or accredited accounting or invoicing system in a structured electronic format. It must be electronically transmitted to the customer and its data must be capable of electronic extraction and processing for BIR reporting.
Invoices manually produced in Word, Excel, Google Docs or similar applications do not qualify.
Taxpayers may use their own electronic invoicing solution, commercially acquired software or an Electronic Invoicing Service Provider (ESP).
Permit and certification requirements
Before issuing electronic invoices, covered taxpayers must obtain a Permit to Issue (PTI) Electronic Invoice from the BIR.
Following approval, taxpayers must obtain Electronic Invoicing and Sales Reporting (EIS) Certification within six months of the PTI.
RMC 98-2026 also provides operational rules covering system downtime, branches, corrections and adjustments.
E-invoicing and electronic sales reporting are separate
Importantly, BIR has clarified that electronic invoicing and electronic sales reporting are separate requirements.
The December 2026 obligation concerns the issuance of compliant electronic invoices. Electronic sales reporting to BIR will become mandatory when the tax authority issues separate implementing policies, guidelines and procedures.
This distinction is important for businesses implementing tax technology. Generating a compliant electronic invoice is only one part of the wider digital tax process. VAT determination, invoice generation, transactional reporting and ultimately VAT return reporting must apply consistent tax logic and data.
Philippines EIS background
The Philippines first launched mandatory VAT e-invoicing testing on 1 July 2022 for around 100 large taxpayers under the Tax Reform for Acceleration and Inclusion (TRAIN) Act. Technical and implementation problems subsequently slowed the programme.
The BIR restarted implementation in 2025 and extended the first major compliance wave to the end of 2026.
RMC 98-2026 now provides businesses with considerably greater certainty over what they must implement before that deadline.
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