Exakt–Helix EIS / Guide

Updated 4 November 2026

BIR e-invoicing in the Philippines: what companies must do before 31 December 2026

Covered taxpayers must be issuing electronic invoices under the BIR's Electronic Invoicing System (EIS) rules by 31 December 2026. This guide sets out who is covered, the dates that matter and the steps to be ready in time.

What is changing

Under Revenue Regulations No. 11-2025, as amended by RR 26-2025, covered taxpayers must issue sales invoices electronically. RMC 98-2026 sets three conditions for a valid electronic invoice: it is generated as structured data by a registered or accredited system, it is issued and delivered to the buyer electronically, and its data can be extracted and transmitted to the BIR in the prescribed format, currently JSON. A Permit to Issue must be granted before live issuance, and the system must then be certified.

Having SAP, Oracle, NetSuite, Microsoft Dynamics, a CAS or a POS does not by itself make a company EIS-ready: an invoice that is only printed or emailed as a PDF does not qualify. What matters is whether the system produces structured, extractable invoice data and delivers invoices electronically.

Issuing e-invoices (Section 237 of the Tax Code) and electronic sales reporting (Section 237-A) are separate obligations. Your system must be ready to transmit, while the actual reporting obligation and the Permit to Transmit follow later BIR instructions. RMC 110-2026 sets out how e-invoicing service providers (ESPs) are accredited, and treats a platform shared across affiliates or franchisees as an e-invoicing service.

Who is covered

Micro taxpayers, with gross sales below PHP 3 million, are exempt.

Key dates

Seven steps to be ready

1. Confirm coverage and appoint a team

   Check whether each company in the group is covered: Large Taxpayers Service, EOPT large taxpayers, CAS or CBA users, or online sellers. Name a project owner and people from finance, tax and IT.

2. List your systems and invoice types

   Note every system that issues sales invoices (ERP, billing, point of sale, online stores) and the invoices each one issues, including exports, services, domestic and intercompany sales.

3. Choose how you will comply

   RMC 98-2026 allows an in-house system, commercially acquired e-invoicing software, or an e-invoicing service provider (ESP). Groups sharing one platform across affiliates or franchisees should also check the ESP rules in RMC 110-2026.

4. Prepare the data and delivery

   Map your invoice data to the BIR's required fields and JSON format, including VAT and withholding tax, and set up electronic delivery to buyers by email, customer portal or QR code.

5. File the Permit to Issue

   Apply with your Revenue District Office or the Large Taxpayer Office, with a system description and test outputs. The BIR evaluates a complete application in up to 20 working days, so file by about 26 November 2026.

6. Test, then go live by 31 December 2026

   Test invoice generation, delivery, credit notes and downtime reconciliation. Start live issuance only after the permit is granted.

7. Complete EIS certification

   Certify within six months of the permit: five mandatory tests, or seven where API callback functionality applies. A permit can be revoked if certification is not completed.

Which path fits your company

Groups, affiliates and franchise networks

Many groups run one invoicing system for several companies, or provide a common point-of-sale or billing platform to franchisees. Under RMC 110-2026 the BIR treats that shared platform as an e-invoicing service, so it needs an accredited provider or a BIR exemption. Each company still needs its own invoice series.

Penalties

Failure to comply with invoicing requirements can be penalised under Section 264 of the National Internal Revenue Code, with fines of up to PHP 50,000 per violation.

Checklist

• Coverage confirmed for every company in the group
• Every invoicing system listed, including POS and online stores
• Route chosen: in-house system, bought software or an ESP
• Permit to Issue filed for each system by about 26 November
• Electronic delivery to buyers set up
• Invoice data mapped to the BIR JSON format and tested
• Go-live by 31 December 2026, with monitoring in place
• EIS certification planned within six months

This guide summarises the rules as of November 2026 and is not legal or tax advice. Check the latest issuances on the BIR website or with your tax adviser. Exakt–Helix EIS is an applicant for ESP accreditation under RMC 110-2026 and is not affiliated with the BIR.