Return to mapElectronic invoicing and e-Reporting in the Philippines
Electronic invoicing is an initiative promoted by the Bureau of Internal Revenue (BIR) of the Philippines to modernize tax control and ensure the traceability of transactions. Through the Electronic Invoicing System (EIS), the country is moving towards a digital model that allows invoices to be sent and validated in real time.
Features of electronic invoicing in the Philippines
The Philippines implements a CTC (Continuous Transaction Controls) model similar to that of other Asian countries, with online validation by the tax administration.
The national electronic invoicing system is called the Electronic Invoicing/Receipting System (EIS) and is administered by the Bureau of Internal Revenue (BIR).
This system allows taxpayers to electronically transmit invoices and receipts in a structured format (JSON or XML), which are then validated and stored by the BIR.
The regulatory framework is governed by Revenue Regulations (RR) No. 11-2025, as amended by RR No. 26-2025, and by Revenue Memorandum Circular (RMC) No. 98-2026, published in September 2026.
The latest circular distinguishes between the mandatory issuance of electronic invoices and the electronic reporting of sales, establishing a phased implementation of both requirements.
RMC No. 98-2026 introduces the Permit to Issue Electronic Invoice (PTI), a specific authorization from the BIR that taxpayers must obtain before beginning to issue electronic invoices.
This authorization is separate from the Permit to Use (PTU) or the Acknowledgment Certificate (AC) corresponding to the invoicing system used.
Mandatory
December 31, 2026, is the deadline for taxpayers included in the first phase to comply with the electronic invoicing requirements established by the BIR.
Among the affected taxpayers are:
- Large taxpayers with annual revenue exceeding 1 billion Philippine pesos (PHP).
- Companies engaged in e-commerce.
- Taxpayers who use computerized accounting and billing systems (CAS and CBA) within the scope of the regulations.
- Companies registered with the BIR’s Large Taxpayers Service (LTS).
The general requirement for Electronic Sales Reporting will take effect at a later date, once the BIR publishes the corresponding provisions.
Invoice format
Electronic invoices must comply with the technical standards defined by the BIR:
- Structured format: JSON or XML.
- Document types: Electronic Sales Invoice (ESI), Electronic Receipt (ER), and Credit/Debit Notes.
Electronic signature
Billing systems must ensure the authenticity and integrity of electronic documents.
For data transmission via the EIS, authentication and digital signature mechanisms are provided in accordance with the technical specifications established by the BIR.
Archiving
Taxpayers must keep electronic copies of all invoices issued and received for at least 10 years, in a format that guarantees their legibility, integrity, and accessibility.
The BIR also maintains a central registry of validated documents, which companies can access in the event of audits.
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Upcoming dates in The Philippines
Electronic Invoice Issuance Process
Phase 1. Issuance of Electronic Invoices (December 31st, 2026)
- Generation: The taxpayer generates the electronic invoice using a registered, approved, or accredited system, in a structured electronic format.
- Authorization: The company must hold the Permit to Issue Electronic Invoice (PTI) corresponding to the invoicing system used.
- Transmission: The invoice is sent electronically to the customer via a digital channel that allows for its receipt and processing.
- Preparation for reporting: The system must allow for the extraction and transformation of invoice data in accordance with the BIR’s technical requirements.
Phase 2. Electronic Sales Reporting (date to be determined)
Once this requirement takes effect, taxpayers must electronically transmit their structured sales data to the BIR’s Electronic Invoicing System (EIS), in accordance with the technical specifications and deadlines established by the tax authority.
RMC No. 98-2026 confirms that electronic sales reporting will not generally take effect on December 31, 2026. The specific timeline will be determined by future BIR regulations.
Upcoming dates in The Philippines
Frequently Asked Questions About Electronic Invoicing in the Philippines
Which taxpayers are required to implement electronic invoicing by December 31, 2026?
The following taxpayers are required to implement electronic invoicing by December 31, 2026:
- Taxpayers engaged in e-commerce or internet transactions that are classified as Small, Medium, or Large Taxpayers. Micro Taxpayers are exempt.
- Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS).
- Taxpayers classified as Large Taxpayers under Republic Act (RA) No. 11976, also known as the Ease of Paying Taxes (EOPT) Act, and Revenue Regulations (RR) No. 8-2024.
- Taxpayers using a Computerized Accounting System (CAS) or Computerized Books of Accounts (CBA) with accounting records and electronic invoicing capabilities, as well as those using other invoicing software.
- Other taxpayers as may be required by the Commissioner of Internal Revenue.
Does the December 31, 2026 deadline include securing the PTI, and what happens if electronic invoices are already being issued without a PTI?
Yes. Covered taxpayers must secure a Permit to Issue (PTI) on or before December 31, 2026. Under RMC No. 98-2026, a PTI must be obtained before electronic invoices can be generated or issued.
Electronic invoices issued without a PTI do not qualify as compliant electronic invoices under RMC No. 98-2026. Therefore, the PTI must be secured before compliant electronic invoice issuance begins.
After the PTI is issued, the taxpayer must also obtain EIS Certification within six months. Otherwise, the PTI may be revoked.
What is the electronic invoicing compliance timeline for companies applying for Computerized Accounting System (CAS) registration?
Companies with a registered Computerized Accounting System (CAS) must comply with the electronic invoicing requirements by December 31, 2026.
If the CAS is registered after December 31, 2026, the company will also be required to have a compliant electronic invoicing solution in place upon registration.
Does the electronic invoicing requirement apply to insurance-related transactions?
Yes. Electronic invoicing generally applies to revenue- or income-generating transactions of covered taxpayers, including insurance-related revenue transactions.
If an insurance company is classified as a covered taxpayer under RMC No. 98-2026, its relevant insurance revenue transactions should be assessed and mapped to ensure compliance with the electronic invoicing requirements by December 31, 2026.
Is the buyer required to process electronic invoices electronically?
If electronic processing refers to Accounts Payable (AP) processing, this is not currently required under the Philippine electronic invoicing framework.
At present, electronic invoicing and the future electronic reporting requirements apply to Accounts Receivable (AR) transactions.
Are there any requirements for invoice numbering series or sequential invoice numbers?
Yes. Each electronic invoice must have a Unique Invoice Identifier (UID). The UID must be unique and sequential and may be generated by the electronic invoicing solution.
Is a separate PTI required when the Head Office and branches use different systems to issue invoices?
Yes. If a taxpayer uses different invoicing software or systems across its Head Office, branches, or business segments, a separate Permit to Issue (PTI) Electronic Invoice must be secured for each distinct invoicing software or system.
For example, if the Head Office issues invoices through a Computerized Accounting System (CAS), while the branches issue invoices through a separate POS or CRM system, a separate PTI is required for each system.
Upcoming dates in The Philippines
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