← All posts

BIR e-invoicing: who is actually covered by 31 December 2026

As of 3 October 2026, five categories of Philippine taxpayers must issue BIR electronic invoices on or before 31 December 2026: e-commerce sellers above Micro size, businesses under the Large Taxpayers Service, Large Taxpayers with gross sales of P1 billion or more, users of CAS, CBA with e-invoicing or other invoicing software, and anyone else the Commissioner requires. Micro taxpayers are exempt. Exporters, incentivized enterprises and POS users have no date yet.

Illustration: a government building, highlighted in olive, joined by lines to a shop, a factory, an office building and a shopping cart.

What changes on 31 December 2026 for a business that is covered?

An invoice typed into an Excel template, saved as a PDF and emailed to the customer stops counting. RMC No. 98-2026, issued by the BIR on 22 September 2026, says invoices made in Microsoft Word, Microsoft Excel, Google Docs, Google Sheets or similar applications "shall not be considered valid electronic invoices for tax compliance purposes." Covered businesses must be issuing real electronic invoices on or before 31 December 2026.

If that template is how your billing desk works today, the first question is not which software to buy. It is whether you are covered at all, and by which line of the rules, because that decides your deadline and which permit you need.

Everything below is read from the BIR's own issuances, mainly RMC No. 98-2026, RR No. 26-2025 and RR No. 11-2025, and is stated as of 3 October 2026. Where the BIR has not yet published something, this post says so.

This post is not tax advice. It tells you what the issuances say and which questions to take to your RDO or accountant.

Which businesses must issue BIR e-invoices by 31 December 2026?

As of 3 October 2026, Section III of RMC No. 98-2026 lists five categories, and every taxpayer in them except Micro taxpayers must issue electronic invoices on or before 31 December 2026. Four categories are named. The fifth is open-ended: other taxpayers the Commissioner of Internal Revenue requires. Falling into any one category is enough to be covered.

The five, in the Circular's own order:

  1. E-commerce or internet sellers classified as Small, Medium or Large taxpayers. Micro taxpayers are exempted.
  2. Taxpayers under the Large Taxpayers Service (LTS).
  3. Large Taxpayers under the Ease of Paying Taxes Act and RR No. 8-2024, meaning gross sales of P1 billion or more in a taxable year.
  4. Taxpayers using CAS or CBA with Accounting Records (with electronic invoicing), and other invoicing software.
  5. Other taxpayers as may be required by the Commissioner of Internal Revenue.

Category 1: who counts as engaged in e-commerce?

More businesses than the phrase suggests. RR No. 11-2025, Section 3(C), covers persons, natural or juridical, engaged in a list of online trades "including but not limited to" the ones it names. The list includes the "sale of creative or professional services, on-demand or freelance services or digital services supplied over the internet" and ends with "other form of businesses other than those mentioned above which are conducted online."

Size matters only at the bottom. A Small, Medium or Large taxpayer that sells online is covered; a Micro taxpayer is not.

The text does not answer one question plainly: whether taking orders over Viber or Facebook Messenger, then delivering and billing offline, counts as "engaged in e-commerce." Put that exact question to your RDO in writing.

Categories 2 and 3: the two large-taxpayer lines

These are two separate categories, and a company can sit in one without the other. Category 2 is about which BIR office handles you. Category 3 is about the size of your sales. The section on large taxpayers below explains how to check each.

Category 4: CAS, CBA and other invoicing software

This is the category most likely to catch a company of 80 to 500 staff that is neither huge nor online. RR No. 26-2025 added it to the 31 December 2026 transition, which RR No. 11-2025 had not originally included.

The wording reads "Taxpayers using CAS or CBA with Accounting Records (with electronic invoicing), and other invoicing software." Whether that catches every business with a registered computerized accounting system, or only those whose system already does e-invoicing, is not settled by the text I read. If you run a registered CAS or bill from any invoicing software, treat yourself as possibly covered and ask your RDO.

Category 5: other taxpayers the Commissioner requires

This is why "only four categories are covered" is not quite right. RMC No. 98-2026 lists a fifth in its main coverage, and its deadline clause applies to "all taxpayers covered under Section III." As of 3 October 2026, no issuance naming anyone under it had been found. It is a door the BIR can open by notice.

Who is not covered by the 31 December 2026 deadline?

Three groups, as of 3 October 2026. Micro taxpayers, with gross sales below P3 million, are exempt from the mandate but may adopt e-invoicing voluntarily. Exporters, Registered Business Enterprises with tax incentives, and POS System users have no date yet. Electronic sales reporting, meaning sending sales data to the BIR, has no date for anyone.

The detail on each:

  • ·Micro taxpayers. RR No. 11-2025, Section 4, exempts them from "the mandatory requirement to use and issue electronic invoice," but lets them adopt it. RMC No. 98-2026 says a voluntary adopter still needs a Permit to Issue from its RDO.
  • ·Exporters of goods and services, and Registered Business Enterprises availing of tax incentives. RR No. 26-2025 says they will be required once the BIR has a system able to store and process the data, through separate Revenue Regulations. The exception that matters: one that also uses CAS, CBA with e-invoicing or other invoicing software falls under category 4, and so under 31 December 2026.
  • ·POS System users. Same treatment: required later, through a separate Revenue Regulation, once the BIR's system is established. No date has been set.
  • ·Electronic sales reporting, for everyone. Issuing e-invoices and reporting sales to the BIR are separate obligations, and only the first has a date.

Can the 31 December 2026 deadline still move?

Yes. RR No. 26-2025, Section 3, says the Commissioner of Internal Revenue "may further extend the deadlines or compliance period on the transition period prescribed in these Regulations as may be deemed necessary." No new Revenue Regulation is needed for that. As of 3 October 2026, 31 December 2026 is the date in force, and no BIR issuance moving it had been published.

The date has already moved once. RR No. 11-2025, as first issued, gave the e-commerce, LTS and EOPT Large Taxpayer categories one year from the regulation taking effect. RR No. 26-2025 replaced that with 31 December 2026 and added the CAS and CBA category. RMC No. 98-2026, issued on 22 September 2026 and effective immediately, restated the same date.

Planning around a deferral that has not been issued is a bet, not a plan. The BIR's press release of 23 September 2026 told taxpayers to focus on the electronic invoicing rules now.

Is a large taxpayer under the Large Taxpayers Service the same as an EOPT Large Taxpayer?

No. They are two separate lists, and RMC No. 98-2026 names them as two separate categories. The Large Taxpayers Service is the BIR office that handles a taxpayer. The Ease of Paying Taxes classification is a sales band: under RR No. 8-2024, a Large Taxpayer is one whose gross sales for a taxable year are P1 billion or more.

RR No. 8-2024 sets four bands, all on gross sales for the taxable year:

  • ·Micro: below P3 million.
  • ·Small: P3 million to below P20 million.
  • ·Medium: P20 million to below P1 billion.
  • ·Large: P1 billion and above.

How do you find your classification?

Gross sales here means "total sales revenue, net of VAT, if applicable, during the taxable year, without any other deductions," per RR No. 8-2024. The BIR says it notifies taxpayers of their classification and any reclassification. RMC No. 62-2024 added a self-service lookup: the "BIR Registered Business Search and Taxpayer Classification Inquiry" in the Online Registration and Update System (ORUS).

The sources checked for this post do not describe how a company is placed under the Large Taxpayers Service. If you file with an LT office, ask it directly whether you are under LTS jurisdiction.

What happens if your classification changes?

Moving up does not give you a free pass, and moving down does not switch the obligation off. RMC No. 98-2026, Section IV.16, says a taxpayer reclassified to a higher category, Medium to Large for example, must comply within a period the BIR sets of not less than six months from reclassification. A taxpayer reclassified to a lower category "shall continue to comply with the previously approved electronic invoicing requirement."

Does e-invoicing apply to every branch, or only the one that sells online?

Every branch. RMC No. 98-2026, Section IV.10, says compliance "shall apply to the taxpayer as a whole," so the head office and all branch offices must issue electronic invoices "regardless of whether the covered activity is undertaken at a particular branch." The provincial depot that has never sold anything online is covered too.

Section IV.13 sets how the permit works across branches. One Permit to Issue is issued to the head office and each branch, all carrying the same permit number. Where different branches or business segments use different invoicing systems, a separate permit is needed for each distinct system.

That second rule is where multi-branch companies get caught. If one branch bills from one package, head office from another and the warehouse from a spreadsheet, the rules see three problems, and the spreadsheet cannot be one of the answers.

What does a covered business need before it issues its first e-invoice?

A Permit to Issue (PTI) Electronic Invoice, secured from the BIR before the first e-invoice is generated. The application goes to the RDO or Large Taxpayer office where the business is registered, and RMC No. 98-2026 gives the BIR twenty working days from receipt of complete documents to evaluate it. An EIS Certification must follow within six months of the PTI.

The pieces, in the order they arrive:

  1. Choose how you will issue. RMC No. 98-2026, Section IV.3, allows an in-house system, a commercially acquired one, or the services of an Electronic Invoicing Service Provider (ESP).
  2. Apply for the PTI Electronic Invoice at your RDO or LT office, with the prescribed documents. The PTI is a different document from the Permit to Use or Acknowledgement Certificate your CAS may already have. RMC No. 98-2026 says the CAS permit "does not by itself constitute authority to issue electronic invoices."
  3. Issue e-invoices only after the PTI is granted.
  4. Secure an EIS Certification within six months of the PTI. It validates that your system can extract, process and transmit sales data, and has five mandatory tests, or seven with API callback. Missing the six months is a ground for revoking the PTI.

What has the BIR not published yet?

Two things a covered business would want in hand. First, RMC No. 98-2026 says the policies and guidelines for securing a PTI "shall be prescribed through a separate revenue issuance." As of 3 October 2026, the BIR has not yet published it. Second, the rules for ESPs: the BIR's press release of 23 September 2026 said that issuance would come "within the month." As of 3 October 2026 it had not been found.

Until it is, be careful with anyone selling a "BIR-accredited" e-invoicing service. In a public advisory of 8 September 2025, the BIR said it "does not accredit EIS providers or issue accreditation." No ESP framework had been issued as of 3 October 2026, so no provider can yet hold accreditation under one.

Do covered businesses have to send every sale to the BIR from January?

No, not as of 3 October 2026. RMC No. 98-2026, Section IV.2, says issuing e-invoices and electronic sales reporting are "separate and distinct" obligations, and covered taxpayers must report sales electronically "only upon the issuance by the Bureau of the implementing policies, guidelines, and procedures for such purpose." Those rules have not been issued.

The Commissioner put it plainly in the 23 September 2026 press release: "For now, taxpayers should focus on complying with the electronic invoicing rules. Electronic sales reporting will follow once the BIR issues the separate implementing policies and procedures for it."

The same goes for the Permit to Transmit. Under Section IV.15, it applies "only upon notification or directive from the Commissioner." A vendor telling you that every invoice must reach the BIR in real time from 1 January 2027 is describing rules that do not exist yet.

That does not make reporting irrelevant. The EIS Certification already tests whether your system can transmit sales data.

What counts as a valid BIR e-invoice?

An invoice that passes three tests in RMC No. 98-2026, Section IV.4: it is generated by a registered, approved or accredited system in a structured electronic format; it is sent to the buyer electronically, by email, online viewing, QR code, app, web platform or similar; and its data can be electronically extracted, processed and transmitted to the BIR.

What fails, from the same Circular and RR No. 11-2025:

  • ·Anything made by hand in Word, Excel, Google Docs, Google Sheets or similar applications.
  • ·An invoice printed from a CAS, CBA, POS System or other software, if that system cannot issue and transmit the invoice electronically and report the sales data to the BIR.
  • ·A photo or scanned copy of a paper invoice, in any file format.

Can you still hand a customer a printed invoice?

Yes, in two cases: when the buyer asks for a printed copy, and in business-to-consumer sales where electronic delivery is "not practicable, inconvenient or not possible," as long as the original was generated and can be issued electronically. The paper is a copy of an electronic invoice, never a substitute for one.

What is the penalty for missing the BIR e-invoicing deadline?

No source read for this post sets a fine specific to missing the e-invoicing deadline. RR No. 11-2025, Section 5, says violations are subject to the penalties in Sections 264 and 264-A of the Tax Code. How those sections apply to a covered business that keeps issuing valid paper invoices after 31 December 2026 is a question of interpretation for a tax lawyer.

What the two sections say. Section 264(a) is from the 1997 Tax Code; Section 264-A was added by the TRAIN law, RA 10963:

  • ·Section 264(a) applies to a person required under Section 237 to issue invoices who fails or refuses to, or issues invoices that do not contain all the required information. On conviction, for each act or omission, the fine is P1,000 to P50,000 plus imprisonment of two to four years. Text from the Tax Code as published on LawPhil.
  • ·Section 264-A applies to a taxpayer required to transmit sales data who fails to. Transmission is not yet required (see above), so this one is not live for e-invoicing as of 3 October 2026.

How do you check in ten minutes whether your business is covered?

Answer five questions in order. One yes is enough to be covered, so note which category caught you, because that is what you tell your RDO. If every answer is no, check whether you are Micro, an exporter, incentivized or POS only, and set a date to recheck, because category 5 and the deadline can both change.

Run it with whoever does your BIR filings sitting beside you:

  1. Look up your classification in ORUS under Taxpayer Classification Inquiry. Below P3 million is Micro and exempt. P1 billion or more is Large, which is category 3.
  2. Ask whether you file with a Large Taxpayer office. If yes, confirm with that office whether you are under LTS jurisdiction, which is category 2.
  3. List every channel through which a customer can order or pay you online, including your own website, marketplaces, and services delivered over the internet. If any exist and you are above Micro, you are probably category 1. Note any Viber or Messenger ordering as a question for your RDO.
  4. List every system that produces an invoice today, branch by branch: registered CAS, CBA, invoicing software, POS, spreadsheet, typewriter pad. Any CAS, CBA or invoicing software points to category 4.
  5. Check for any letter or notice from the BIR naming you for e-invoicing, which would be category 5.
  6. Write one email to your RDO or LT office stating your category, your branches and your invoicing systems, and asking them to confirm coverage and the current deadline. Keep the reply.

If you are covered, where should you start?

Not with a software demo. Most software evaluations in a company of this size start about two years early and get pointed at the wrong problem, and a regulatory deadline adds panic to a decision that needed patience. Start with the list from step four: how many systems issue invoices, who keys them, and how many times the same sale gets typed again before it reaches the books.

Then fix and document how invoicing actually runs, including the exceptions, before you automate it. Automating a broken invoicing process makes it faster, not better, and now it carries a permit number. Our guide to buying, building or fixing what you have, linked below, covers that decision.

This post is not tax advice. It records what the BIR's issuances say as of 3 October 2026. Confirm your own position with your RDO or your accountant.

Common questions

Are freelancers and service businesses that sell online covered by BIR e-invoicing?

If they are above Micro size, very likely. RR No. 11-2025 counts the "sale of creative or professional services, on-demand or freelance services or digital services supplied over the internet" as e-commerce, and RMC No. 98-2026 puts Small, Medium and Large e-commerce taxpayers under the 31 December 2026 deadline, as of 3 October 2026. Micro taxpayers, below P3 million in gross sales, are exempt.

Is a PDF invoice emailed from accounting software a BIR e-invoice?

Only if the system that made it passes all three tests in RMC No. 98-2026: generated by a registered or approved system in a structured format, sent to the buyer electronically, and with data that can be extracted and transmitted to the BIR. The business also needs a Permit to Issue. A PDF made from Word, Excel or Google Sheets never counts.

Can a business that is not covered start issuing e-invoices voluntarily?

Yes. RMC No. 98-2026 says taxpayers not required to comply by 31 December 2026 may adopt e-invoicing voluntarily, provided they secure a Permit to Issue Electronic Invoice from their RDO. The Tax Code, as amended by RA 12066, allows the same. As of 3 October 2026, the BIR has not yet published the separate issuance on how to secure the permit.

Is there a BIR-accredited e-invoicing provider?

Not as of 3 October 2026. In September 2025 the BIR said it "does not accredit EIS providers." RMC No. 98-2026 says ESP rules will come through a separate issuance, and that issuance had not been found as of 3 October 2026. Treat any claim of BIR accreditation as something to check with your RDO.

Sources

If this is the problem you're sitting with, show us the task and we'll audit one workflow for free.

Show us the task

One email, now and then

Where the hours actually go

Every new post, and nothing else. No pitch, no schedule to keep up with, one click to leave.