RMC No. 98-2026: Electronic Invoicing Guidelines

Revenue Memorandum Circular (RMC) No. 98-2026

Date of Issuance: September 22, 2026

Effectivity: Immediately

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. 26-202

RMC No. 98-2026 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.

Key Highlights

1. Covered Taxpayers

The electronic invoicing mandate applies to:

1. Small, Medium, and Large Taxpayers engaged in e-commerce or internet transactions (Micro Taxpayers are exempted);
2. Taxpayers under the Large Taxpayers Service;
3. Taxpayers classified as Large Taxpayer under the Ease of Paying Taxes Act (Republic Act No. 11976) and RR No. 8-2024;
4. Taxpayers using computerized accounting systems (CAS), computerized books of accounts (CBA) with accounting records and electronic invoicing, or other invoicing software; and
5. Other taxpayers subsequently identified by the Commissioner of Internal Revenue.

2. Policies And Guidelines

Covered taxpayers, except Micro taxpayers, must be capable of issuing compliant electronic invoices no later than December 31, 2026. Taxpayers outside the mandatory coverage may voluntarily adopt electronic invoicing, subject to securing the appropriate authorization.

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.

Taxpayers enumerated above shall be required to comply with the electronic sales reporting requirements only upon the issuance by the Bureau of the implementing policies, guidelines, and procedures for such purpose.

Taxpayers shall have the option to use an in-house or commercially acquired electronic invoicing solution, or avail of the services offered by an Electronic Invoicing Service Provider (ESP). Policies and guidelines governing ESPs shall be prescribed through a separate revenue issuance.

3. What Qualifies As An Electronic Invoice

An invoice qualifies an Electronic Invoice only when if it satisfies all of the following requirements:

1. Is generated through duly registered, approved, or accredited accounting or invoicing software;
2. Uses a structured electronic format;
3. Is transmitted digitally to the customer through email, QR code, mobile application, online platform, or another electronic channel; and
4. Contains data that can be electronically extracted, processed, and transmitted for BIR sales-reporting purposes.

While the electronic invoicing system/software of the taxpayer may be capable of electronically transmitting the copy of the invoice through email, apps, a printed copy of the electronic invoice shall be provided by the taxpayer-seller upon request by the buyer.

Invoices created manually using office productivity applications, including but not limited to Microsoft Word, Microsoft Excel, Google Docs, Google Sheets, or similar applications, shall not be considered valid electronic invoices for tax compliance purposes.

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, shall not be considered electronic invoices if the system does not have the capability to electronically issue and transmit the invoice to the buyer and electronically transmit or report the required sales data to the BIR. Such invoices shall instead be treated as invoices generated through a system and shall be subject to the rules applicable to non-electronic invoicing.

4. Structured Data And JSON Requirements

Electronic invoices shall be in a structured electronic format. This means that digital information shall be organized in a set, predictable way so computers can easily read, sort, and use it.

1. The BIR’s existing EIS prescribes the use of the JavaScript Object Notation (JSON) file format for the transmission of sales data. To avoid confusion, taxpayers whose electronic accounting or invoicing software or systems utilize other structured file formats may continue to use such formats for their internal operations, provided that the required sales data can be converted to and transmitted in the format prescribed by the BIR.
2. The information required in the JSON file format is 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 to be indicated on the invoices under Section 113 of the Tax Code and RR No.7-2024, 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.

5. Corrections And Adjustments In An Issued Electronic Invoice

An issued electronic invoice must not be deleted, altered, or modified. Adjustments must be documented separately:

1. Decrease in amount: Issue an authorized credit note or credit memo referencing the original invoice.
2. Increase in amount: Issue a new electronic invoice.

6. System Downtime Procedures

During system failures, internet outages, power interruptions, cybersecurity incidents, force majeure events, or similar disruptions, taxpayers must issue a duly authorized manual invoice. Once the system is restored, the manual invoice must be replaced with a corresponding electronic invoice that references the manual invoice number.

The occurrence of system downtime or technical issues shall not exempt the taxpayer from the obligation to issue an invoice for every sale, barter, exchange, or transaction, nor from compliance with record-keeping and reporting requirements prescribed by the Bureau

7. Permit To Issue Requirement

Covered taxpayers must obtain a Permit to Issue (PTI) Electronic Invoice, or PTI Electronic Invoice, before issuing electronic invoices. This is separate from the Permit to Use (PTU) or Acknowledgement Certificate (AC) applicable to a computerized accounting system.

Applications must be filed with the taxpayer’s registered Revenue District Office (RDO) or Large Taxpayer (LT) Office. The BIR is expected to evaluate a complete application within 20 working days.

A new or amended PTI may be necessary when there 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.

8. Head Office And Branch Coverage

A PTI Electronic Invoice shall be issued to the Head Office and each separate branch, all bearing the same PTI Electronic Invoice number and indicating the branch to which the PTI Electronic Invoice pertains.

Where a taxpayer utilizes different invoicing software/systems for different branches, offices, or business segments, a separate PTI Electronic Invoice shall be secured for each distinct invoicing software/system. The PTI Electronic Invoice shall clearly identify the approved invoicing software/system and the corresponding branches, offices, or business locations authorized to use it.

The establishment of additional branches using the same approved electronic invoicing software/system shall not require the issuance of a new PTI number, provided that the taxpayer duly notifies the Bureau in accordance with existing rules and procedures.

9. Electronic Invoicing And Sales Reporting (Eis) Certification

All taxpayers required to issue electronic invoices shall obtain an EIS Certification to validate the capability of their electronic invoicing systems to electronically extract, process, and transmit sales data in accordance with this Circular and the BIR’s prescribed technical standards.

The EIS Certification Portal, including the applicable technical specifications, guides, and requirements, may be accessed through https://eis-cert.bir.gov.ph.

Taxpayers must secure EIS certification within six (6) months from the issuance of the PTI Electronic Invoice. Failure to obtain certification within this period may result in revocation of the PTI.

The Permit to Transmit (PTT) requirement will apply only after the Commissioner issues a notification or directive activating the electronic sales-reporting obligation. Therefore, electronic invoice issuance and electronic sales reporting remain separate compliance requirements.

10. 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.