The Bureau of Internal Revenue (BIR) now requires taxpayers in a broad range of industries to use the Enhanced Electronic Documentary Stamp Tax (eDST) System.
This system replaces the older eDST platform. It is part of the BIR's Digital Transformation Roadmap to modernise tax administration, make compliance more efficient, and strengthen revenue collection.
Two issuances govern this requirement:
- Revenue Regulations (RR) No. 28-2025, issued December 22, 2025, sets the mandate and the core rules.
- Revenue Memorandum Circular (RMC) No. 107-2026, dated October 1, 2026, explains how the mandate is carried out.
RR No. 28-2025 makes the Enhanced eDST System mandatory for covered taxpayers. They must use it to affix documentary stamps to their taxable documents. The mandate applies to both individual and non-individual taxpayers in the covered industries. All covered taxpayers must enroll online through the BIR website.
Who Are the Covered Taxpayers?
The regulation names seven categories of covered taxpayers:
- Banks and financial institutions. banks, quasi-banks, non-bank financial intermediaries, finance companies, and insurance, surety, fidelity, or annuity companies
- Shipping and airline companies
- Pre-need companies. for sales of pre-need plans under Section 186 of the National Internal Revenue Code (NIRC) of 1997, as amended
- Educational institutions. for taxable certificates such as diplomas, transcripts of records, and other documents taxable as certificates under Section 188 of the NIRC
- Government entities. national government agencies and their instrumentalities, government-owned or -controlled corporations (GOCCs), and local government units (LGUs), except barangays, for documents taxable as certificates under Section 188
- Notaries public. including those employed in law firms and other public or private offices
- Other industries. any industry the Secretary of Finance adds through a revenue regulation, on the CIR's recommendation
What Are the Two System Modules?
The Enhanced eDST System has two modules. You can enrol in only one. Once you select and enrol in a module, you can no longer enroll in or use the other. Below are the 2 types of modules:
| Feature | Deposit Module | Non-Deposit Module |
| How it works | You make an advance deposit, which is credited to your taxpayer ledger account in the system | You print documentary stamps on taxable documents right away, with no advance deposit |
| How tax is settled | The tax due is deducted from your ledger each time you print a stamp | documents printed during the month is totalled |
| Payment timing | Paid in advance | Paid by the prescribed monthly deadline |
| Documents covered | Taxable documents of covered taxpayers | Documents taxable under Section 188 of the NIRC |
The use of loose documentary stamps and constructive affixture is still permitted as an exception. The CIR will set the conditions and requirements in a separate issuance. Strict limits apply to loose stamps:
- ₱30.00 tax due only: Loose stamps may be affixed only to documents taxable under Section 188 of the NIRC whose tax due is ₱30.00. This does not apply to documents covered by the eDST System or by constructive affixture.
- No multiple stamps: You may not affix several loose stamps to a document whose tax due exceeds ₱30.00.
What Are the Prohibitions on Reuse and Stockpiling?
RR No. 28-2025 sets clear boundaries on how loose documentary stamps may be handled. The following prohibitions apply to all persons executing taxable documents:
- No stockpiling: Buying two or more loose stamps for future use is prohibited, unless the CIR allows it in a separate issuance.
- No reuse: Using a loose stamp that was already affixed to another document is strictly prohibited.
- Proper cancellation: Anyone who executes a taxable document, whether a natural or juridical person, must properly cancel the loose stamp before releasing the document. Cancellation must follow Item No. 3.c of the "Guidelines on the Proper Sale and Affixture of Loose Documentary Stamps" under RMC No. 092-2024.
What Happens to Excess Deposit Balances Upon Business Closure?
When a covered taxpayer applies for business closure, the Revenue District Office (RDO) will check the taxpayer's eDST ledger for any excess deposit balance during its review of the books of accounts.
The validated balance is applied in this order:
- Against any outstanding documentary stamp tax (DST) liability found in the examination
- Against any other outstanding tax liabilities found in the examination
- Any remaining balance is refunded to the taxpayer
The ledger balance is then adjusted or reversed to match.
What Are the Penalties for Selling Stamps Above Face Value?
No person may collect, sell, or offer to sell documentary stamps for more than their face value. Violators face criminal and civil penalties.
Revenue Memorandum Circular No. 107-2026
RMC No. 107-2026 provides operational guidance for carrying out RR No. 28-2025. It sets enrolment deadlines, outlines the enrolment process, addresses notaries public, and covers system issues, erroneous affixtures, and penalties for non-compliance.
When Are the Enrolment Deadlines?
RMC No. 107-2026 sets firm timelines for enrolment:
- Existing Covered Taxpayers. On or before December 31, 2026
- Newly Registered Covered Taxpayers. Within 90 days from the date of BIR registration
How to Enrol
You can enrol through either channel:
- BIR website: Go to the BIR website, open eServices > Other eServices, and click the "eDST" icon.
- eDST portal: Visit the eDST portal.
Once your enrolment is approved, follow the User's Manual (Job Aids) on the eDST System homepage.
What are the other Requirements
You must meet two further requirements alongside eDST enrolment:
- eFPS enrolment: Enrol in the Electronic Filing and Payment System (eFPS). You will use it to file the Documentary Stamp Tax Declaration/Return (BIR Form No. 2000) and pay the tax due.
- MOMD orientation: Attend an orientation on the Enhanced eDST System. The Miscellaneous Operations Monitoring Division (MOMD) holds it every second Thursday of the month. You must attend before you can use the system.
What Are the Special Rules for Notaries Public?
The circular sets specific obligations for notaries public:
- Individual enrolment: Each notary public must enrol in their own name and maintain their own eDST account.
- Applies to all work arrangements: This holds whether the notary is employed by a law firm or other office, or engaged as a third-party or outsourced service provider. It also applies regardless of which taxpayer receives the notarial service.
- Registration update: Under Section 236 of the NIRC, as implemented by RR No. 7-2024 and RMC No. 74-2025, notaries must coordinate with their RDO to:
- Update their taxpayer classification to "Professional"
- Ensure their registration records accurately reflect their authority to perform notarial services
What Happens With Erroneous Affixtures and Refund Claims?
If a double, multiple, or erroneous affixture of documentary stamps occurs through the eDST System:
- File a claim for refund with the Large Taxpayers Division or the RDO where you are registered.
- Your claim must comply with existing laws, rules, and regulations on tax refunds.
What Are the Penalties for Non-Enrolment?
Covered taxpayers who fail to enrol within the prescribed period will be considered non-compliant. They will face the applicable penalties and sanctions under existing laws, rules, and regulations upon enrolment. Enrolling late does not remove the liability for missing the deadline.
