Regulatory updates - Philippines

The Bureau of Internal Revenue (BIR) has released Revenue Memorandum Circular No. 98-2026 (RMC), which effective immediately, prescribes new policies and guidelines for the upcoming e-invoicing mandate starting December 31, 2026. The RMC makes it clear that the e-invoicing obligations are distinctly separate from the electronic sales data reporting requirement to the EIS platform, which has been in pilot phase since 2022. Electronic sales data reporting will only come into effect after a separate issuance of policies and guidelines from the BIR. Taxpayers are allowed to use in-house solution, commercially acquired e-invoicing solutions or an E-invoicing Service Provider (ESP) to comply with the requirements. Guidelines and policies governing ESPs are expected to be released soon in separate issuance.

The following taxpayers have to comply with the e-invoicing mandate:

• Taxpayers classified as Small, Medium, or Large engaged in e-commerce or internet transactions (Micro Taxpayers are exempted);
• Taxpayers under the Large Taxpayers Service;
• Taxpayers classified as Large Taxpayer under the Ease of Paying Taxes Act (Republic Act No. 11976) and RR No. 8-2024;
• Taxpayers using Computerized Accounting Systems (CAS), Computerized Books of Accounts (CBA) with accounting records and electronic invoicing, or other invoicing software;
• Other taxpayers identified by the Commissioner of Internal Revenue.

Additional notable mentions from the RMC:

• E-Invoices must be generated as structured e-invoice files in a duly registered, approved or accredited accounting/e-invoicing system. The e-invoice must be transmitted electronically to the buyer (e-mail, online viewing, QR code, mobile/web applications or electronic means). The e-invoice data needs to be able to be extracted to the BIR for the purpose of electronic sales data reporting.  A printed copy of the invoice must be provided to the buyer upon request.
• Any corrections to an issued e-invoice shall be made through a separate document issuance that references the original e-invoice. A decrease in the invoiced amount shall be handled through a credit note, while an increase in the invoiced amount shall be handled through the issuance of a new e-invoice.
• Taxpayers can opt in for e-invoicing mandate before December 31, 2026.
• Manual (paper) invoices are to be used by taxpayers during downtime of the accounting/e-invoicing system. Upon restoration of the system, a replacement e-invoice referencing the manual invoice must be issued.
• Taxpayers in scope of the e-invoicing mandate must secure a Permit to Issue E-invoice Permit (PTI), prior to issuance of e-invoices.
• All taxpayers in scope of e-invoicing mandate need to obtain EIS certification to validate electronic sales data reporting capabilities. This must be obtained within 6 months from receiving the PTI.
• Taxpayers reclassified from a Medium to a Large taxpayers classification, must immediately comply with their new obligations applicable to their new classification. This includes e-invoicing and electronic sales data reporting (electronic sales data reporting is still contingent on new policy issuance from the BIR).

Read the announcement here.

The launch of the portal is part of the BIR’s broader efforts to modernize tax administration and promote ease of doing business in the Philippines.

Currently available through a pilot implementation to taxpayers under the LTS, the portal enables taxpayers to access their tax information through a single online view, reducing the need for manual follow-ps and in-person visits to BIR offices.

Taxpayers may enroll to  access the following functionality through the platform:

• Viewing of taxpayer registration information
• Monitoring of status of filed tax returns per Tax Type/Form Type
• Tracking of tax payments
• Viewing of Account Ledger per Tax Tpe/Form Type
• Receiving of system-generated notifications and tax reminders

The pilot implementation is intended to support the gradual rollout of the system to other taxpayer categories by ensuring operational readiness before wider deployment.

The RMC states the suspension aims to protect taxpayers from irregular, untimely or intrusive audits by limiting the field operations conducted by the authority.

The issuance of the circular stems from complaints from taxpayers, stakeholders and internal units reporting on irregularities and inconsistencies in audit operations.

During the suspension, the BIR will conduct a review of existing policies and procedures. Issuance of written orders to audit or investigate taxpayer liabilities is suspended during this period, except for in the following cases:

• Investigation of cases prescribing within six (6) months from the date of this Order
• Processing and verification of estate tax returns, donor's tax returns, capital gains tax returns, and withholding tax returns on the sale of real properties or shares of stocks, together with the documentary stamp tax returns related thereto
• Examination or verification of internal revenue tax liabilities of taxpayers retiring from business
• Letters of Authority (LOA)/ Mission Orders (Mo) necessary for active criminal probes conducted by duly authorized enforcement units through verified intelligence reports, inter-agency referrals, third-party data validation, or risk-scoring anomalies that require immediate audit action where delay would prejudice the government's case
• Claims for refund where the issuance of an LOA is statutorily required
• Other matters/concerns where deadlines have been imposed or under the orders of the Commissioner

The suspension took immediate effect on November 24, 2025, and will remain in force until lifted by the Commissioner.