BIR RMC No. 98-2026: Mandatory Electronic Invoicing Requirements

The Bureau of Internal Revenue released Revenue Memorandum Circular (RMC) No. 98-2026, prescribing the policies and guidelines on the issuance of Electronic Invoices under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025.

The Circular operationalises Section 237 of the National Internal Revenue Code and sets out clear obligations for affected taxpayers. Below is a summary of the key provisions to help your organisation prepare.

Who is covered

The electronic invoicing mandate under RMC No. 98-2026 applies to specific categories of taxpayers identified in the Circular.

Organisations and individuals falling within the scope of this Circular are required to adopt and issue electronic invoices in accordance with the guidelines set out herein.

Specifically, the mandate applies to the following taxpayers:

• Taxpayers engaged in e-commerce or internet transactions, classified as Small, Medium and Large Taxpayers (Micro Taxpayers are exempt);
• Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS);
• Taxpayers classified as Large Taxpayers under Republic Act No. 11976 (Ease of Paying Taxes Act) and RR No. 8-2024;
• Taxpayers using a Computerised Accounting System (CAS) or Computerised Books of Accounts (CBA) with Accounting Records (with electronic invoicing) and other invoicing software; and
• Other taxpayers as may be required by the Commissioner of Internal Revenue.

The Circular also appears to allow non-covered taxpayers to adopt the framework voluntarily through the issuance of a PTI, subject to future BIR guidelines on the applicable requirements and procedures.

What Makes an Electronic Invoice Valid

An invoice will only be recognised as an Electronic Invoice if it satisfies all of the following:

1. It is generated by a duly registered, approved, or accredited accounting or invoicing software or system in a structured electronic format;
2. It is electronically generated and transmitted to the buyer in digital format through email, online viewing, QR Code, mobile applications, web-based platforms, or other electronic means; and
3. The invoice data is capable of being electronically extracted, processed, and transmitted to the Bureau for electronic sales reporting purposes.

A printed copy must still be provided to the buyer upon request. Please note that invoices created manually using office productivity applications (such as Microsoft Word, Microsoft Excel, Google Docs, or Google Sheets) will not be accepted as valid electronic invoices, and their issuance remains subject to the applicable rules and requirements governing manual or non-electronic invoicing.

How Do You Obtain a Permit to Issue (PTI) and EIS Certification?

Before generating or issuing any electronic invoice, covered taxpayers must first secure a Permit to Issue (PTI) Electronic Invoice from the Bureau. The PTI application process is as follows:

• Applications must be filed with the relevant Revenue District Office or Large Taxpayer Office.
• The Bureau will evaluate each application within twenty (20) working days of receipt of complete documents.

Covered taxpayers must also obtain an Electronic Invoicing and Sales Reporting (EIS) Certification to confirm their system can extract, process, and transmit sales data to the Bureau. Key requirements include:

• The certification must be secured within six (6) months from the issuance of PTI Electronic Invoice.
• Failure to comply within this period may result in revocation of the PTI.
• Taxpayers required to issue electronic invoices shall obtain an EIS Certification to validate the capability of their electronic invoicing systems to electronically extract, process, and transmit sales data in accordance with the Circular and the BIR’s prescribed technical standards. The EIS Certification Portal, including the applicable technical specifications, guides, and requirements, may be accessed through https://eis-cert.bir.gov.ph.

An existing CAS Permit to Use (PTU) or Acknowledgement Certificate (AC) does not serve as a substitute for the PTI Electronic Invoice. These earlier permits authorize the use of a computerized accounting system but do not, by themselves, grant the authority to issue electronic invoices. Taxpayers holding a valid PTU or AC must still apply for and secure a separate PTI Electronic Invoice before issuing any electronic invoice.  

Branch office obligations

Compliance applies to the taxpayer as a whole. Key obligations for branch offices include:

• The Head Office and all its Branch Offices are required to issue electronic invoices, regardless of where the covered activity takes place.
• A PTI Electronic Invoice will be issued to the Head Office and each branch, all bearing the same PTI number and indicating the relevant branch.
• Where different invoicing systems are used across branches or business segments, a separate PTI must be secured for each distinct system.

Key Compliance Rules and Deadlines

Covered taxpayers, except Micro Taxpayers, must issue electronic invoices and comply with the Circular no later than December 31, 2026. Taxpayers who are not covered by the mandate may still choose to issue electronic invoices instead of manual invoices, subject to the applicable requirements set by the BIR.

The Circular also sets out several practical rules that covered taxpayers need to follow. Here is a summary of the key points:

• System-generated but paper-issued invoices. Not all software-generated invoices qualify as electronic invoices. If the system cannot electronically send the invoice to the buyer and transmit or report the required sales data to the BIR, a printed copy of that invoice will not count as an electronic invoice. It will instead be treated as a non-electronic invoice and governed by the rules applicable to non-electronic invoicing.
• Structured electronic format. Electronic invoices must be in a format that computers can automatically read and process. The BIR requires sales data to be transmitted in JSON format. If your system uses a different structured format internally, that is fine, as long as the required data can be converted and sent to the BIR in JSON.
• Printed copies permitted. Even if an invoice is issued electronically, a taxpayer may still print and hand a copy to the buyer for their records. This is allowed even in business-to-consumer transactions where sending an electronic copy is not practical, as long as the invoice was originally generated electronically and all other Circular requirements are met.
• Corrections and adjustments. If an error is found in an already-issued electronic invoice, it cannot be edited or deleted. Instead, corrections must be made through a separate document that refers back to the original invoice. To reduce the amount billed, issue a Credit Note/Memo. To bill a higher amount, issue a new electronic invoice.
• System downtime. If your system goes down or is otherwise unavailable, you must issue a BIR-authorized manual invoice to record the transaction. System issues do not excuse a taxpayer from the duty to issue invoices or meet record-keeping and reporting obligations. Once the system is back up, each manual invoice must be replaced with a corresponding electronic invoice that references the manual invoice number.

Ongoing Obligations After a Change in Classification

This point deserves particular attention, as it is easy to overlook. A change in your classification under the EOPT framework does not, on its own, release you from electronic invoicing obligations. All covered taxpayers must continue to comply with the applicable electronic invoicing requirements, notwithstanding any subsequent change in classification, unless the Bureau expressly reclassifies or exempts them through a separate issuance.

The specific effect depends on the direction of the reclassification:

• Reclassified to a higher category (for example, from Medium to Large, including enlisting in the Large Taxpayers Service). You must comply with the requirements applicable to your new classification, including electronic invoicing and electronic sales reporting obligations, within the period prescribed by the Bureau. That period cannot be less than six (6) months from the date of reclassification.
• Reclassified to a lower category (for example, from Small to Micro, from Large to Medium, or delisted from the Large Taxpayers Service). You must continue to comply with your previously approved electronic invoicing requirement.

In short, moving to a higher category adds obligations within a defined timeline, whilst moving to a lower category does not remove the obligations you already carry. Treating these requirements as continuing commitments will help you avoid compliance gaps as your classification evolves.