RMC No. 98-2026 Explained: What Filipino Business Owners Need to Know About Electronic Invoices
Source note: This guide follows the seven-page BIR Revenue Memorandum Circular No. 98-2026 dated September 22, 2026, especially Sections I–V. I also checked the related RR No. 11-2025, RR No. 26-2025, and RR No. 7-2024. Check later BIR issuances before acting, because the circular expressly leaves several procedures for separate rules.
As the CEO of an accredited Tax Software Provider in the Philippines, it’s important that I need to know new rules and regulations passed by the BIR. The thing is though, as a business owner, I understand that keeping eye on new rules and regulations isn’t part of the usual core processes of a business. So we, at Taxumo, help the BIR out by cascading some rules that should be highlighted and in your radar as a business owner.
A new RMC that SHOULD be read is RMC 98-2026. Taxumo has a new blog post on this here: Taxumo: Explaining RMC 98-2026.
Also sharing information from the RMC in this blog post for my fellow business owners to read.
A simple way to keep the whole circular in mind: an e-invoice has to be a real invoice, delivered electronically, with usable data behind it.
Section I: Why did BIR issue this circular?
This circular 98-2026 gives policies and guidelines for issuing electronic invoices under existing tax law and regulations. It helps answer questions such as: What counts as an e-invoice? Who must issue one? What permit is needed? What happens when the internet goes down?
It does not complete every part of the rollout. The rules for ESPs (Electronic Invoicing Service Provider), detailed PTI procedures, adjustments to sales, and electronic sales reporting are still to be issued separately. Think of this RMC as an important operating guide, with some more pages of the rulebook still to come.
Section II: The terms, translated
The RMC’s nine defined terms, translated for business owners.
A useful extra term: Permit to Transmit (PTT). The RMC mentions a PTT later. It involves transmitting sales data to the BIR and becomes applicable upon the Commissioner’s notification or directive for electronic sales reporting. It is different from the PTI, which concerns permission to issue electronic invoices.
Section III: Is my business covered?
The circular lists these taxpayers:
- Businesses engaged in e-commerce or internet transactions that are classified as Small, Medium, or Large. Micro taxpayers are exempted from this particular mandate.
- Businesses under the Large Taxpayers Service (LTS).
- Businesses classified as Large under the Ease of Paying Taxes framework.
- Businesses using a CAS, computerized books with accounting records and electronic invoicing, or other invoicing software.
- Other taxpayers the Commissioner may require.
You only need to fall into an applicable category; these are not five conditions that must all be met. For covered taxpayers, the circular sets December 31, 2026 as the deadline to comply with electronic invoice issuance.
Example: A medium-sized business that sells through its website or through platforms like Lazada, Shopee or Tiktok should check its e-invoice readiness. A micro online seller is expressly exempt from the mandatory e-commerce group described here, but can choose to adopt e-invoicing voluntarily with the required PTI. A business may also fall under another coverage category, so do not decide based on its sales channel alone.
RR No. 26-2025 says the e-invoicing requirement for some businesses—including exporters, certain businesses with tax incentives, and those covered only because they use a POS system—will be addressed in further BIR rules. But your business may still need to meet the December 31, 2026 deadline for another reason, such as its size, online sales, or use of invoicing software. Check all the categories above before deciding whether the deadline applies to you.
Section IV: The actual rules, without the legalese
1. A PDF or printout is not automatically an e-invoice
For the RMC to treat an invoice as electronic, all three need to be true:
- An appropriately registered, approved, or accredited accounting or invoicing system generates it in a structured format.
- The business issues it to the buyer electronically—email, online viewing, QR code, an app, or a web platform are among the options named.
- Its data can be extracted, processed, and transmitted for BIR electronic sales reporting when required.
Emailing an invoice made in Word or Google Docs does not make it a valid e-invoice under this RMC. The same goes for an invoice created by software but only printed out. To qualify, the system must be able to send the invoice electronically and prepare its sales data for BIR reporting.
A printed copy is still possible. Customers can ask for one, and a printout can be useful where electronic delivery is impractical, especially for consumer sales. The underlying invoice must first satisfy the electronic requirements.
2. Issuing an invoice and reporting a sale to BIR are different steps
This is probably the distinction I most want business owners to remember:
| Step | Question | Where it stands under this RMC |
|---|---|---|
| Electronic invoice issuance | Can you create and send the buyer a compliant e-invoice? | Covered taxpayers must comply by December 31, 2026. |
| Electronic sales reporting | Are you required to send that sales data to BIR as part of live reporting? | BIR says implementing policies, guidelines, and procedures will be issued for this obligation. |
The system still needs the capability to extract, process, and transmit the data, even though the general reporting obligation has its own implementation step. BIR’s existing EIS uses JSON for sales-data transmission. Your invoicing software can use another structured format internally if the required data can be converted to BIR’s prescribed format.
3. Get the right permit before issuing
A covered taxpayer needs a PTI Electronic Invoice before generating or issuing e-invoices under this circular. The application goes to the taxpayer’s registered RDO or LT office, with prescribed supporting documents. BIR says it will evaluate compliance within 20 working days after receiving complete documents. That is a review period, not automatic approval.
If you already have a CAS Permit to Use or Acknowledgement Certificate, this is different from the PTI. The RMC clarifies it. The PTI specifies the software and what it covers. Changing the system’s identity, name, platform, or core details—or moving to another system—can require a new or amended PTI. Separate detailed PTI application procedures are yet to be released.
4. Do not forget your branches
If a covered business activity is registered as a branch, the e-invoice requirement applies to the head office and all branches, even branches that do not themselves perform that covered activity. The RMC describes PTIs for the head office and each branch under the same PTI number, identifying which branch each covers. A different invoicing system used by another branch or business segment requires a separate PTI for that distinct system. For a new branch using the same approved system, BIR notification is required, but a new PTI number is not. Again, how notification should be done was not specified in this RMC.
5. An issued invoice should be logged, tracked and monitored
Once issued, an e-invoice should not be deleted, edited, or quietly overwritten. In case of changes in the einvoice (change in amount), if the amount goes down, use a duly authorized credit note or memo that points to the original. If the amount goes up, issue a new e-invoice. BIR says more detailed rules on sales adjustments will follow.
Ecample, if you billed ₱10,000, then accepted a ₱2,000 return. The idea is to preserve what was first issued and record the adjustment through a separate document.
6. What if the internet or invoicing system is down?
You still have to issue an invoice. The RMC says to use a BIR-authorized manual invoice when downtime, power loss, connection problems, a cyber incident, or other disruption prevents electronic issuance. Once the system is restored, replace the manually issued invoices with corresponding e-invoices that include the manual invoice reference numbers. Record-keeping and reporting obligations also continue.
That means businesses should prepare the fallback before an outage: authorized manual invoices, a clear reference log, and a way to reconcile those transactions after restoration.
7. When will an e-invoice be useful as tax proof?
An e-invoice from the approved system with PTI can be recognized as proof of the transaction and for tax substantiation, if it meets the applicable invoice information rules and can be verified as BIR prescribes. A system label or pretty invoice design alone cannot guarantee that result.
8. EIS Certification still matters, even before broad live reporting
Covered taxpayers must obtain EIS Certification within six months after their PTI is issued. The tests check whether the system can extract, process, and transmit sales data under BIR’s technical standards. Failure to secure certification within that period is a ground for revoking the PTI. The separate PTT becomes relevant upon BIR’s directive for electronic sales reporting.
In everyday terms: the permit lets you issue; certification tests the system’s reporting capability; the transmission permit concerns live reporting when directed. These are connected, but they are not the same document.
9. A later drop in business size does not automatically switch the requirement off
If your business moves to a lower taxpayer category, you still need to keep issuing e-invoices unless BIR says otherwise. If it moves to a higher category, BIR will give you a deadline to meet the new requirements. That deadline must be at least six months after the change.
A simple checklist for business owners
- Check if the rules apply to you. Look at your taxpayer classification, online sales, branches, and the software you use to issue invoices.
- Follow one invoice through your current process. How do you create it, send it to your customer, and keep its information? What happens if you need to correct it or your system goes down?
- Check your BIR permits. Having approval for your accounting system does not automatically mean you have a Permit to Issue Electronic Invoice.
- See where a provider could help. Ask an e-invoicing provider like Taxumo how its solution could fit into your existing process, what it can handle, and what your business will still need to do. Taxumo can provide assistance, not only in offering the technical solution, but also in understanding the new rules of the BIR and in helping you comply with these.
- Keep an eye on new BIR rules. More details are still coming, including the rules for ESPs and electronic sales reporting.
You do not have to figure this out on your own. Contact Taxumo’s eInvoicing team by emailing einvoice(at)taxumo(dot)com.
Disclosure: I am the Co-Founder and CEO of Taxumo. We plan to apply as an Electronic Invoicing Service Provider when BIR releases the rules. Taxumo has not been accredited as an ESP under this circular (as mentioned in the RMC, no accreditation rules have been released yet), and each business must meet its own permit and compliance requirements.
Updated as of September 23, 2026; 8:00 pm.
