The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 98-2026 dated 22 September 2026, to prescribe clear policies and guidelines on the issuance of electronic invoices. Issued pursuant to Section 237 of the National Internal Revenue Code (Tax Code), as amended, and implementing Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025, the Circular provides standard operational procedures and compliance mandates for covered taxpayers.
Electronic invoicing represents a critical step in the BIR’s modernization agenda, ensuring that transactions are recorded in structured digital formats that can be transmitted, processed, and validated electronically. This initiative strengthens compliance, enhances transparency, and reduces administrative burdens for taxpayers while aligning with global best practices in tax administration.
LEGAL DEVELOPMENT
RMC No. 98-2026 builds upon the statutory mandate of Section 237 of the Tax Code, which requires the issuance of invoices for every sale, barter, or exchange of goods and services. By introducing electronic invoicing, the BIR expands the scope of compliance to include digital transactions, particularly those conducted through e-commerce platforms and computerized accounting systems.
The Circular further distinguishes between Permits to Issue (PTI) Electronic Invoices and existing permits for computerized accounting systems, clarifying that only duly registered and approved electronic invoicing systems grants authority to issue valid electronic invoices. It also introduces the requirement for Electronic Invoicing and Sales Reporting (EIS) Certification, ensuring that taxpayer systems meet technical standards for extracting and transmitting structured invoice data.
KEY PROVISIONS
Under this Circular, taxpayers engaged in e-commerce, which are those classified as “Large Taxpayers”, and those using
“Computerized Accounting Systems” are mandated to issue electronic invoices by 31 December 2026. Micro taxpayers are exempted, though voluntary adoption is permitted subject to securing a PTI Electronic Invoice.
An invoice qualifies as an electronic invoice only if it is generated by a duly registered or accredited system in a structured digital format, transmitted electronically to the buyer, and capable of being processed and reported to the BIR. Printed invoices from such systems are valid only if the original was electronically generated. Corrections to issued invoices must be made through Credit Notes/Memos or new electronic invoices, as deletion or alteration is prohibited.
Taxpayers may adopt in-house or commercially acquired solutions, or avail of services from Electronic Invoicing Service Providers (ESPs), subject to separate regulatory issuances. Compliance extends to all branches of a taxpayer, with PTI Electronic Invoices required for each distinct invoicing system. In cases of system downtime, manual invoices may be issued temporarily but must be replaced with electronic invoices upon restoration.
Finally, all taxpayers required to issue electronic invoices must obtain EIS Certification within six months of securing a PTI Electronic Invoice. Failure to comply may result in revocation of authority to issue electronic invoices.
PRACTICAL IMPLICATIONS
With the issuance of this Circular, the adoption of electronic invoicing streamlines compliance by reducing reliance on manual documentation and enabling automated reporting. For taxpayers, this translates into faster transaction processing, reduced administrative costs, and improved accuracy in record-keeping. For the BIR, this enhances their monitoring capabilities, ensures real-time visibility of sales data, and strengthens enforcement against fraud and underreporting cases.
This initiative also aligns with the Ease of Paying Taxes Act (R.A. No. 11976), reinforcing the government’s commitment to digital transformation in tax administration. By mandating structured invoice data and electronic reporting, the BIR positions itself to integrate seamlessly with broader e-governance frameworks, ensuring that tax compliance keeps pace with the digital economy.
CONCLUSION
RMC No. 98-2026 represents a decisive step in the BIR’s modernization agenda by institutionalizing electronic invoicing as a standard compliance mechanism for taxpayers. By mandating structured digital formats, PTI authorization, and EIS certification, the Circular ensures that transactions are verifiable, secure, and efficiently processed.
This reform not only advances transparency and accountability in tax administration but also supports national policy objectives under the Ease of Paying Taxes Act and the Ease of Doing Business Act (R.A. No. 11032). In this respect, electronic invoicing should be regarded as a cornerstone of the Philippines’ transition toward a fully digital, responsive, and globally aligned tax system.
This guide provides a general overview of Revenue Memorandum Circular (RMC) No. 98-2026 at the time of writing and is not intended to constitute comprehensive legal advice or an opinion on the topic. For more details and information, you may coordinate with any GEL Law Partner regarding the matter.
Atty. Jianna Mae Robles is an Associate at GEL Law.