Philippines mandates electronic invoicing by end of 2026
The Philippines Bureau of Internal Revenue has issued Revenue Memorandum Circular No. 98-2026. Covered small, medium, and large taxpayers must adopt electronic invoicing by 31 December 2026. Micro taxpayers are exempt.
The Philippines’ Bureau of Internal Revenue has set a mandatory deadline of 31 December 2026 for electronic invoicing adoption. The rule covers small, medium, and large taxpayers, particularly those in e-commerce, while exempting micro taxpayers with annual gross sales below PHP 3 million.
The Philippines’ Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular No. 98-2026 on 22 September 2026. It sets the official framework for electronic invoicing. All covered taxpayers must transition to digital invoicing systems by 31 December 2026.
Who must adopt e-invoicing
Mandatory e-invoicing applies to:
- Small, medium, and large taxpayers engaged in e-commerce or internet transactions
- Taxpayers under the Large Taxpayers Service
- Large taxpayers covered by the EOPT Act and RR No. 8-2024
- Taxpayers using computerised accounting systems, computerised books of accounts, or invoicing software with e-invoicing capabilities
- 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.
What makes a valid e-invoice
To qualify as a valid electronic invoice for tax compliance under Section 34(A)(1)(b) of the Tax Code, an invoice must meet three cumulative conditions:
- Structured format: Generated by a duly registered, approved, or accredited software or system in a structured electronic format
- Digital transmission: Electronically generated and transmitted to the buyer via email, online viewing, 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
Invoices manually prepared using office productivity tools such as Microsoft Word or Excel, or paper-printed receipts from systems lacking electronic transmittal capabilities, do not qualify as valid e-invoices.
Permits and 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.
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 certification within this period may result in PTI revocation. A new or updated PTI is required when the core e-invoicing software is changed, migrated, or replaced.
Technical requirements and operational rules
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.
Issued e-invoices cannot be deleted, altered, or modified. Reductions in invoiced amounts must be processed through an authorised Credit Note or Memo linked to the original invoice. Increases require a new e-invoice.
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.
Sellers must provide printed copies of e-invoices upon the buyer’s request. Paper copies are also required for business-to-consumer transactions where electronic delivery is impractical.
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.