Businesses covered by the Bureau of Internal Revenue’s (BIR) electronic invoicing mandate have until year-end to upgrade billing and accounting systems, potentially adding to software, technology and training costs.
Revenue Memorandum Circular (RMC) No. 98-2026, issued Sept. 22, requires covered taxpayers to begin issuing electronic invoices by Dec. 31, 2026, accelerating the government’s shift toward digital tax compliance.
The mandate covers small, medium and large taxpayers engaged in e-commerce or internet transactions, taxpayers under the Large Taxpayers Service, large taxpayers covered by the Ease of Paying Taxes framework, and businesses using computerized accounting or invoicing systems.
Micro taxpayers are exempt.
Covered businesses must use registered or approved systems capable of generating structured electronic invoices and transmitting them digitally. Manually prepared invoices created through Word, Excel or similar applications will not qualify.
Businesses can develop in-house systems, buy commercial software or tap electronic invoicing service providers, opening a growing compliance market for technology firms.
Covered taxpayers must also secure a Permit to Issue Electronic Invoice. BIR evaluation may take up to 20 working days after complete submission, while Electronic Invoicing and Sales Reporting certification must be secured within six months of permit issuance.
For companies with multiple branches, the compliance requirement extends across their entire network, potentially raising implementation and integration costs.
BIR Commissioner Charlito Martin Mendoza clarified that electronic sales reporting remains a separate requirement, with additional implementing guidelines still pending.
The reform is intended to strengthen transaction documentation and tax transparency, but businesses face an immediate task: upgrading systems and processes before the December deadline.
