{"id":7077516,"date":"2026-10-06T00:35:53","date_gmt":"2026-10-06T00:35:53","guid":{"rendered":"https:\/\/fivemor.com\/?p=7077516"},"modified":"2026-10-06T00:35:53","modified_gmt":"2026-10-06T00:35:53","slug":"rmc-no-98-2026-explained-what-filipino-business-owners-need-to-know-about-electronic-invoices","status":"publish","type":"post","link":"https:\/\/fivemor.com\/?p=7077516","title":{"rendered":"RMC No. 98-2026 Explained: What Filipino Business Owners Need to Know About Electronic Invoices"},"content":{"rendered":"


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Source note: This guide follows the seven-page BIR Revenue Memorandum Circular No. 98-2026 dated September 22, 2026, especially Sections I\u2013V. I also checked the related<\/em> RR No. 11-2025<\/em><\/a>,<\/em> RR No. 26-2025<\/em><\/a>, and<\/em> RR No. 7-2024<\/em><\/a>. Check later BIR issuances before acting, because the circular expressly leaves several procedures for separate rules.<\/em><\/p>\n

As the CEO of an accredited Tax Software Provider in the Philippines, it\u2019s 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\u2019t part of the usual core processes of a business. So we, at Taxumo<\/a>, help the BIR out by cascading some rules that should be highlighted and in your radar as a business owner. <\/p>\n

A new RMC that SHOULD be read is RMC 98-2026<\/a>. Taxumo has a new blog post on this here: Taxumo: Explaining RMC 98-2026<\/a>.<\/p>\n

Also sharing information from the RMC in this blog post for my fellow business owners to read.<\/p>\n

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.<\/strong><\/p>\n

Section I: Why did BIR issue this circular?<\/h2>\n

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?<\/p>\n

It does not<\/strong> 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. <\/p>\n

Section II: The terms, translated<\/h2>\n
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The RMC\u2019s nine defined terms, translated for business owners. <\/em><\/p>\n

A useful extra term: Permit to Transmit (PTT).<\/strong> The RMC mentions a PTT later. It involves transmitting sales data to the BIR and becomes applicable upon the Commissioner\u2019s notification or directive for electronic sales reporting. It is different from the PTI<\/strong>, which concerns permission to issue<\/em> electronic invoices. <\/p>\n

Section III: Is my business covered?<\/h2>\n

The circular lists these taxpayers:<\/p>\n

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  1. Businesses engaged in e-commerce or internet transactions that are classified as Small, Medium, or Large<\/strong>. Micro taxpayers are exempted from this particular mandate.<\/strong><\/li>\n
  2. Businesses under the Large Taxpayers Service (LTS)<\/strong>.<\/li>\n
  3. Businesses classified as Large<\/strong> under the Ease of Paying Taxes framework.<\/li>\n
  4. Businesses using a CAS<\/strong>, computerized books with accounting records and electronic invoicing, or other invoicing software.<\/li>\n
  5. Other taxpayers the Commissioner may require.<\/li>\n<\/ol>\n

    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<\/strong> as the deadline to comply with electronic invoice issuance.<\/p>\n

    Example:<\/strong> 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<\/em> 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.<\/p>\n

    RR No. 26-2025 <\/a>says the e-invoicing requirement for some businesses\u2014including exporters, certain businesses with tax incentives, and those covered only because they use a POS system\u2014will 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<\/strong> the categories above before deciding whether the deadline applies to you. <\/p>\n

    Section IV: The actual rules, without the legalese<\/h2>\n

    1. A PDF or printout is not automatically an e-invoice<\/h3>\n

    For the RMC to treat an invoice as electronic, all three<\/strong> need to be true:<\/p>\n