Draft RMC on Electronic Invoicing Guidelines for 2026

Revenue Memorandum Circular (RMC)

(DRAFT STATUS)

Prescribing Policies and Guidelines on the Issuance of Electronic Invoice under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as Amended by RR No. 26-2025

The draft Revenue Memorandum Circular (RMC) prescribes the policies and guidelines for the mandatory issuance of electronic invoices (e-Invoices) pursuant to Section 237 of the Tax Code, as implemented under RR No. 8-2022, RR No. 11-2025, and RR No. 26-2025. The regulation aims to modernize invoicing processes, improve tax compliance, and prepare taxpayers for future electronic sales reporting requirements.

Key Highlights

Coverage

The following taxpayers must implement electronic invoicing on or before 31 December 2026:

• Taxpayers engaged in e-commerce/internet transactions classified as Small, Medium, or Large taxpayers (Micro taxpayers are exempt)
• Taxpayers under the Large Taxpayers Service (LTS)
• Taxpayers classified as Large Taxpayers under the Ease of Paying Taxes (EOPT) Act
• Taxpayers using Computerized Accounting Systems (CAS), Computerized Books of Accounts (CBA) with electronic invoicing, and other invoicing software systems.

The following will be covered under a subsequent issuance:

• Exporters of goods and services
• Registered Business Enterprises (RBEs) enjoying tax incentives
• Taxpayers using POS systems (unless otherwise covered above)
• Other taxpayers as may be designated by the BIR

Note: Since not covered by the December 31, 2026 compliance deadline, they shall be required to issue electronic invoices only upon the issuance of a separate revenue issuance for this purpose.

Other taxpayers not covered by the mandate of the provisions of Section 237 of the Tax Code may issue electronic invoices in lieu of manual invoices.

Electronic Sales Reporting Requirements

The obligation to issue electronic invoices pursuant to Section 237 of the Tax Code, shall be separate and distinct from the obligation to comply with the electronic sales reporting requirements under Section 237-A of the Tax Code.

Compliance with electronic invoicing does not automatically require immediate compliance with electronic sales reporting, unless the taxpayer has already been specifically notified by the BIR. Separate implementing guidelines will be issued.

What Qualifies As An Electronic Invoice

An invoice is considered an electronic invoice only if it satisfies all of the following requirements:

• It is generated by a duly registered, approved, or accredited accounting/invoicing software or system in a structured electronic format;
• It is issued electronically to the buyer, purchaser, or client through electronic means; and
• The invoice data contained therein is capable of being electronically extracted, processed, and transmitted to the Bureau for electronic sales reporting purposes.

The following do not qualify as electronic invoices by themselves:

• PDF file;
• Scanned invoices;
• Images of paper invoices; or
• Printed system-generated invoices that cannot support electronic reporting requirements unless the foregoing requirements are satisfied

Note: Invoices generated by a CAS, CBA with Accounting Records (with electronic invoicing), POS System, or other accounting/invoicing software or system and subsequently printed on paper for issuance to buyers, without the capability or readiness to electronically report the sales and invoice data, shall not qualify as electronic invoices. Instead, they shall be classified as traditional, manually issued invoices.

Electronic Invoices Shall Be In A Structured Electronic Format

The digital information shall be organized in a set, predictable way so computers can easily read, sort, and use it.

1. The BIR’s existing Electronic Invoicing and Sales Reporting System prescribes the use of the JavaScript Object Notation (JSON) file format in the establishment of sales data transmission system. To avoid confusion, taxpayers whose electronic accounting/invoicing software or system with a file format other than the JSON shall continue to utilize their existing file formats.
2. The information required in the JSON file format are not designed to change in any way the existing information reflected on the invoices of taxpayers. The data required in the JSON file format are primarily from the minimum required information (Annexes “A-1” and “A-2”) to be indicated on the invoices under Section 113 of the Tax Code, including some additional details that are found to be relevant on most taxpayers whether engaged in the sale of goods or service such as discounts, withholding taxes, etc.

Permit To Issue (Pti) Electronic Invoice

Before issuing electronic invoices, taxpayers must obtain a Permit to Issue (PTI) Electronic Invoice from the BIR. The PTI is separate from:

• Permit to Use (PTU)
• Acknowledgement Certificate (AC) for CAS

Application Requirements

Taxpayers must submit with the concerned Revenue District Office/LT Assistance Division/Excise LT Regulatory Division/LT Division – Cebu/LT Division – Davao:

• Sworn Statement of Compliance
• Process flow documentation
• Sample electronic invoice
• Proof of system registration (PTU or AC, where applicable)

The BIR is expected to evaluate complete applications within three (3) working days.

New Or Amendment Of PTI

The following instances require the issuance of a new or amended PTI, as may be applicable:

• Any change in the identity, name, platform, or core software/system details of the approved electronic invoicing software/system, including migration to, replacement with, or
• Adoption of another electronic invoicing software/system.

Quick Response (QR) Code Requirement

All electronic invoices must contain a QR Code that:

• Verifies invoice authenticity;
• Is visible in both electronic and printed versions of the invoice; and
• Contains information prescribed by the BIR.

Issuance Of Generated Electronic Invoice

Electronic invoices may be delivered through:

• Email (PDF attachment)
• Content embedded in the body of the e-mail
• Online viewing
• Mobile application
• Web-based platforms, or
• Other electronic means.

Printed copies must still be provided upon customer request.

Invoice Corrections

Once issued, an original electronic invoice:

• Cannot be deleted
• Cannot be altered
• Cannot be modified

Adjustments must be made through:

Credit Note – A document issued by the seller to reduce or cancel, in whole or in part, a previously issued invoice due to returns, allowances, discounts, overbilling, or similar adjustments.

All adjustment documents must reference the original invoice to which they relate.

Issuance Of Manual Invoice

The taxpayer shall use a manual invoice duly authorized by the Bureau to document the transaction in accordance with Section 237 of the Tax Code in the event of:

• System downtime
• System unavailability,
• Technical malfunction
• Internet connectivity issues
• Power interruption
• Cybersecurity incidents
• Force majeure events, or
• Other circumstances that prevent the generation or issuance of an electronic invoice,

Upon restoration of the system, all invoices manually issued during the downtime period shall be duly recorded and maintained for audit and reporting purposes.

Voluntary Adoption Of Electronic Invoicing

Taxpayers not mandatorily required to comply with the electronic invoicing requirements on or before December 31, 2026 may voluntarily adopt electronic invoicing provided that they secure a PTI Electronic Invoice from the concerned Revenue District Office/Large Taxpayers (LT) Assistance Division/Excise LT Regulatory Division/LT Division – Cebu/LT Division – Davao.

Head And Branch Operations

Head Office and all its Branch Offices shall be mandated to issue electronic invoices, regardless of whether the covered activity is undertaken at a particular branch.

The PTI Electronic Invoice shall be issued per invoicing software/system and shall cover all branches utilizing the same duly registered or approved invoicing software/system.

General Rule: The Head Office of the taxpayer shall file the application for the issuance, amendment, or renewal of the PTI on behalf of all covered branches or offices.

Exception: Where a taxpayer uses different invoicing software/systems for different branches, offices, or business segments, a separate PTI shall be secured for each distinct invoicing software/system.

The addition of branches utilizing the same approved invoicing system shall not require the issuance of a new PTI number, provided that the taxpayer notifies the Bureau accordingly.

Change In Classification Of Taxpayers

1. Covered Taxpayers – continue to comply with the applicable electronic invoicing, notwithstanding any subsequent change in their classification under the EOPT framework, unless expressly reclassified or exempted by the Bureau through a separate issuance.
2. Taxpayers reclassified to a higher category (e.g., Medium to Large, including inclusion under the Large Taxpayers Service) – shall immediately comply with the requirements applicable to their new classification, including electronic invoicing and electronic sales reporting obligations, within such period as may be prescribed by the Bureau, which shall not be less than six (6) months from the date of reclassification.
3. Taxpayers reclassified to a lower category (e.g., Small to Micro, Large to Medium, including delisting from the Large Taxpayers Service) – continue to comply with the previously approved electronic invoicing requirement.