The Bureau of Internal Revenue (BIR) has cautioned electronic invoicing service providers against charging excessive fees as businesses prepare for the government’s mandatory electronic invoicing system, with compliance due by December 31, 2026.
BIR Commissioner Charlito Martin Mendoza delivered the warning on October 13 during a briefing for prospective electronic invoicing service providers (ESPs) at the agency’s National Office. He urged companies not to exploit the required transition to impose unreasonable costs on taxpayers already contending with economic pressures.
“Please do not use the mandatory nature of electronic invoicing as a reason to charge excessive fees,” Mendoza said.
The warning accompanied Revenue Memorandum Circular (RMC) No. 110-2026, which establishes accreditation requirements and consumer safeguards for companies offering electronic invoicing services.
Under the circular, providers must disclose transparent and reasonable fees before onboarding taxpayers. They must also ensure businesses retain access to their electronic records even when fees remain unpaid, contractual disputes arise or customers transfer to competing providers. These safeguards are intended to prevent vendor lock-in and give taxpayers greater flexibility in choosing service providers.
The framework also requires ESPs to secure BIR accreditation before commercially deploying their services. Accreditation remains valid for five years, subject to annual review and continued compliance with information security, data protection and system reliability standards.
“While meeting our technical standards is essential, your business model must also be built around taxpayer-centric service,” Mendoza said.
The requirements come as covered taxpayers face a year-end deadline under RMC No. 98-2026. Businesses may meet their electronic invoicing obligations through internally developed systems, commercially acquired solutions or accredited service providers.
The new framework places pricing transparency and data portability alongside technical compliance, signaling that providers will be expected to protect taxpayers’ interests as well as deliver reliable systems.
For businesses, the rules offer safeguards against unexpected charges and restricted access to records. However, the practical impact will depend on how consistently accreditation, fee disclosure and service standards are enforced as the deadline approaches.
