BIR E-Invoicing (EIS) in the Philippines: What Businesses Must Do Before December 31, 2026

The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 98-2026 — the operative document that all covered taxpayers must follow to achieve e-invoicing compliance. The deadline: December 31, 2026. This is not a drill, and it is not limited to large corporations.

Who is covered? The mandatory requirement applies to: taxpayers engaged in e-commerce or internet transactions (Small, Medium, and Large — Micro Taxpayers are exempt); taxpayers under the Large Taxpayers Service (LTS); Large Taxpayers under the EOPT Act; and taxpayers using a Computerised Accounting System (CAS) or invoicing software. If your business uses AccountingSuite or any other CAS-registered system, you are covered.

What counts as a valid electronic invoice? An e-invoice must be generated by a duly registered or accredited accounting/invoicing system in a structured electronic format, transmitted to the buyer digitally (via email, QR code, web platform, or mobile app), and capable of having its data electronically extracted and transmitted to the BIR. Invoices created in Word, Excel, or Google Docs do not qualify — even if emailed as a PDF. A PDF alone is not an electronic invoice.

The December 31, 2026 deadline covers the obligation to issue electronic invoices (Section 237 of the Tax Code). It does not yet require automatic API transmission of every invoice to the BIR — that is a separate obligation (electronic sales reporting under Section 237-A) which becomes operative only upon a separate BIR directive. In short: you must be able to generate and deliver structured e-invoices by year-end; the live API feed to the BIR comes later.

Before you can issue electronic invoices, you must secure a Permit to Issue (PTI) Electronic Invoice from your Revenue District Office (RDO) or Large Taxpayer Office. The PTI is distinct from your existing CAS Permit to Use or Acknowledgement Certificate — you need both. The BIR has 20 working days to evaluate a complete application. Apply early; do not wait until Q4 2026.

Within six months of receiving your PTI, you must also obtain EIS Certification — a testing process that validates your system's ability to extract, process, and transmit sales data. The certification portal is at https://eis-cert.bir.gov.ph. Failure to obtain EIS Certification within the six-month window is grounds for revocation of your PTI.

On the technical side, the BIR prescribes JSON format for sales data, secured with JWS (JSON Web Signature) using RS256, transmitted via API within three calendar days of invoice issuance. This applies to the eventual electronic sales reporting obligation — not to the e-invoice itself, which can be delivered to the buyer by email, QR code, or other electronic means.

For system downtime, the rules are clear: you must still issue an invoice for every transaction — use a BIR-authorised manual invoice. Once your system is restored, replace every manual invoice with a corresponding electronic invoice bearing the manual invoice's reference number. Corrections work through Credit Notes (for decreases) or new electronic invoices (for increases). An issued e-invoice cannot be deleted, altered, or modified.

AccountingSuite users: AccountingSuite is BIR CAS-ready and is actively monitoring the EIS rollout. The BIR's API format for general rollout is still being finalised. If you have already received a BIR notification, EIS Certification, or Permit to Transmit, contact CBSI — we will prioritise your integration. For all other AccountingSuite users, the immediate action is to apply for your PTI and begin the EIS Certification process.

CBSI's compliance team is helping clients navigate the e-invoicing transition — from assessing coverage and preparing PTI applications to coordinating with your software provider on EIS Certification. Contact us now to get ahead of the December 31, 2026 deadline.