Electronic Invoicing Philippines and Electronic Sales Reporting in The Philippines: BIR EIS Solution

Electronic Invoicing & Electronic Sales Reporting in the Philippines 

The Philippines is moving forward with the implementation of electronic invoicing under an increasingly defined regulatory framework. The publication of RMC No. 98-2026 by the Bureau of Internal Revenue (BIR) provides new guidelines for taxpayers subject to this requirement and confirms December 31, 2026 as the deadline for implementing electronic invoicing.

The move toward mandatory electronic invoicing is part of a broader effort by the Philippine government to modernize tax administration and accelerate the country's digital transformation. In late 2024, the government enacted Republic Act No. 12066, also known as the CREATE MORE (Corporate Recovery and Tax Incentives for Enterprises to Maximize Opportunities for Reinvigorating the Economy) Act. The legislation expands and strengthens the original CREATE Act (Republic Act No. 11534) by introducing a more competitive, transparent, and investment-friendly tax incentive framework designed to attract both domestic and foreign investment.

In 2025, the publication of Revenue Regulation No. 11-2025, subsequently amended by Revenue Regulation No. 26-2025, marked another step forward by defining the taxpayers subject to the requirement and establishing December 31, 2026, as a key date for transitioning to the new model.

The process has now entered a much more specific phase with the publication of Revenue Memorandum Circular (RMC) No. 98-2026. The new circular sets out guidelines for issuing electronic invoices and provides greater clarity on the requirements companies will need to meet by December 2026. Among other provisions, it defines what qualifies as an electronic invoice, introduces the requirement to obtain a Permit to Issue Electronic Invoice (PTI), and subsequently establishes EIS certification.

In addition, RMC No. 98-2026 clarifies one of the most relevant aspects of the new model: electronic invoicing and electronic sales reporting to the BIR are separate obligations and will be implemented in different phases. While affected taxpayers must be prepared to issue electronic invoices by December 31, 2026, the general requirement for electronic sales reporting will take effect at a later date, in accordance with future BIR regulations.

What qualifies as an electronic invoice?

According to RMC No. 98-2026, an electronic invoice must meet the following requirements:

• It must be generated through a duly registered, approved, or accredited accounting or invoicing system and in a structured electronic format.
• It must be electronically transmitted to the customer in digital format. This may be done through channels such as email, online access, QR codes, mobile applications, web platforms, or other electronic means.
• The invoice data must be capable of being electronically extracted and processed, as well as transmitted to the BIR to comply with electronic sales reporting requirements.

Therefore, simply creating an invoice using tools such as Word, Excel, Google Docs, or Google Sheets does not qualify as electronic invoicing. Likewise, generating an invoice in an accounting system and then printing it does not, by itself, meet the requirements if the system does not allow the invoice to be issued and transmitted electronically to the customer and the required data to be extracted for subsequent reporting.

Electronic invoices must use a structured electronic format. Although the BIR's Electronic Invoicing System (EIS) currently uses JSON to transmit sales data, companies may use other structured formats within their own systems, provided that the required information can be converted into the format established by the BIR.

Who Must Comply with Electronic Invoicing in the Philippines?

Under the implementation timeline established by the Bureau of Internal Revenue (BIR), the first group of taxpayers required to adopt the Electronic Invoicing System (EIS) must comply by December 31, 2026. The initial mandate focuses on businesses with high transaction volumes and organizations that already use digital accounting and invoicing systems. At this initial stage, the requirement applies to:

• Large taxpayers with annual revenues exceeding PHP 1 billion. 
• E-commerce businesses that conduct taxable digital transactions and report them to the BIR. 
• Companies using a Computerized Accounting System (CAS) to manage their accounting and invoicing processes. 
• Businesses registered under the BIR's Large Taxpayers Service (LTS).

At this stage, microenterprises are generally excluded from the mandate. However, the BIR is expected to expand the scope of the Electronic Invoicing System (EIS) in future implementation phases, gradually extending compliance requirements to additional taxpayer groups as the nationwide rollout progresses.

The following table summarizes which businesses are currently required to comply with the Philippine Electronic Invoicing System (EIS) and the applicable implementation deadlines established by the Bureau of Internal Revenue (BIR).

Electronic invoicing and electronic sales reporting: two separate obligations

One of the key clarifications introduced by RMC No. 98-2026 is the distinction between electronic invoicing and electronic sales reporting to the BIR.

Implementation can therefore be understood in two phases:

Phase 1: Electronic invoicing. Taxpayers subject to the requirement must be able to generate structured electronic invoices that comply with BIR requirements through their registered, approved, or accredited systems and transmit them electronically to their customers. The deadline for complying with this requirement is December 31, 2026.

Phase 2: Electronic sales reporting. This phase involves the electronic transmission to the BIR of structured sales data. Although taxpayers' systems must have the technical capability to perform this reporting, the BIR has not yet established a general effective date for this second obligation. Electronic sales reporting will become mandatory when the Commissioner of Internal Revenue subsequently establishes it through the corresponding notice or directive.

This distinction is particularly relevant for companies preparing for the December 2026 deadline. By that date, they must be able to issue electronic invoices that comply with the regulations, but this does not mean that the general requirement to electronically report sales to the BIR will take effect at the same time.

Permit to Issue Electronic Invoice (PTI)

RMC No. 98-2026 also establishes the Permit to Issue Electronic Invoice (PTI) as one of the key requirements for taxpayers subject to the obligation.

The PTI is separate from the Permit to Use (PTU) or Acknowledgement Certificate (AC) associated with the taxpayer's accounting or invoicing system. While the PTU or AC relates to the system being used, the PTI constitutes the BIR's specific authorization to issue electronic invoices through that system.

Taxpayers must obtain the PTI before they begin generating or issuing electronic invoices.

The application must be submitted to the relevant Revenue District Office (RDO) or Large Taxpayer Office. The BIR will assess the application and verify compliance with the requirements within 20 business days of receiving all required documentation.

The PTI is linked to the authorized electronic invoicing system. Therefore, changes to the invoicing platform or core invoicing software, including system migrations or replacements, may require a new PTI or an amendment to the existing one.

When the head office and its branches use the same authorized electronic invoicing system, they may use the same PTI number, with the corresponding branches identified. However, if different branches, offices, or business units use different systems, a separate PTI will be required for each system.

The BIR is expected to issue further guidelines specifying the application process and the final documentation required to obtain the PTI.

How Does the Electronic Invoicing System Work in the Philippines?

Under the new regulations, the Philippine model should be understood as a progressive compliance process.

During the first phase, companies will need to:

• Generate electronic invoices through a duly registered, approved, or accredited system.
• Issue them in a structured electronic format.
• Transmit them electronically to the customer.
• Ensure that the data can be electronically extracted and processed for future reporting to the BIR.
• Obtain the Permit to Issue Electronic Invoice (PTI) before beginning to generate or issue electronic invoices.

After obtaining the PTI, taxpayers will have six months to obtain EIS certification, which confirms that the system is capable of extracting, processing, and transmitting the required sales data.

During the second phase, the general Electronic Sales Reporting requirement will take effect, under which structured sales data will be transmitted electronically to the BIR. At this time, the Philippine tax authorities have not established a general effective date for this second phase.

Therefore, the December 31, 2026 deadline applies to the electronic invoicing requirement and should not be interpreted as the general start date for the requirement to electronically report sales to the BIR.

Mandatory information on the electronic invoice

Electronic invoices must include a series of mandatory data, including:

• Document number
• Issue date
• Unique identification number linked to the document
• Seller information
• Buyer information
• Details of the goods or services sold
• Transaction amount
• Applicable VAT
• Discounts applied

EDICOM’s Global Electronic Invoicing Platform: Ensuring Compliance in the Philippines

Implementing the Electronic Invoicing System (EIS) required by the Bureau of Internal Revenue (BIR) involves much more than building a simple technical connection. Businesses must ensure that electronic invoices are generated in the required format, digitally signed, submitted within the prescribed deadlines, and remain compliant as regulatory and technical requirements evolve.

The EDICOM Global Electronic Invoicing Platform integrates seamlessly with leading ERP and business management systems, including SAP, SAP S/4HANA, Oracle, Microsoft Dynamics 365, NetSuite, Infor, and other accounting and billing solutions.

This allows organizations to continue using their existing business systems while EDICOM automatically transforms invoice data into the format required by the Electronic Invoicing System (EIS), applies the required digital signature, and securely transmits electronic invoices and sales data to the Bureau of Internal Revenue (BIR). By automating the entire compliance workflow, businesses can reduce manual effort, improve data accuracy, and maintain continuous compliance with the Philippines' Electronic Invoicing and Electronic Sales Reporting requirements.

The process follows these key steps:

Receiving and Transforming Invoices

When an invoice is generated in a company’s ERP, EDICOM’s platform captures the document in its original format. Since the BIR requires invoices in JSON format under the EIS framework, the platform automatically converts the invoice data to align with the mandated structure, ensuring full compliance.

Applying the Electronic Signature

To ensure data authenticity and security, the EDICOM platform applies a digital signature to the invoice. This step is essential in the Philippines, as the BIR mandates the use of electronic signatures to validate that invoices are legitimate and have not been altered after issuance.

Submission to the BIR’s EIS System

EDICOM automates the submission process by regularly scanning for new invoices that need to be sent to the BIR. Once validated, the invoices are automatically transmitted to the BIR’s Electronic Invoicing/Receipting System (EIS) for approval. This process eliminates manual errors and ensures real-time compliance with Philippine tax regulations.

Automated PDF Invoice Generation and Customer Notification

For businesses required to provide customers with PDF invoices, EDICOM offers an automated solution. The platform generates a PDF version of the invoice and securely publishes it for the recipient. An email notification is also sent, allowing the customer to download the invoice seamlessly. This eliminates the need for manual email distribution and ensures that invoices are delivered in a timely manner.

Why Companies in the Philippines Choose EDICOM?

EDICOM’s Global Electronic Invoicing Platform is tailored to meet the unique e-invoicing requirements of the Philippines, helping businesses remain compliant while optimizing their invoicing processes. Key benefits include:

• Seamless ERP Integration: The platform integrates with existing ERP systems, reducing manual input and minimizing errors.
• BIR Compliance: EDICOM ensures compliance with the BIR’s EIS framework, including required formats and electronic signature standards.
• Real-Time Automation: Invoice transformation, validation, and submission occur automatically, reducing administrative burden.
• Secure Digital Transactions: The use of digital signatures ensures the security and authenticity of each transaction.
• Efficient Invoice Distribution: Customers receive timely notifications and access to their invoices through a secure online portal.

By implementing EDICOM’s platform, businesses in the Philippines can confidently navigate the complexities of the country’s e-invoicing regulations while improving operational efficiency and reducing compliance risks.