BIR RMC No. 98-2026 Explained: New E-Invoicing Rules for Philippine Online Sellers
Jayson28 Sep 2026 10:51ENCopy link & title
BIR Revenue Memorandum Circular No. 98-2026 turns the Philippines' December 31, 2026 electronic invoicing deadline into a more detailed implementation process. Covered taxpayers must use a compliant system, obtain a Permit to Issue Electronic Invoice, deliver structured electronic invoices to customers and complete EIS Certification within six months after the permit is issued.
The circular, issued on September 22, 2026 and effective immediately, does not introduce a new tax rate. Instead, it explains what qualifies as an electronic invoice and how businesses should prepare their invoicing systems. For online sellers, this makes the remaining transition period a system and data-readiness project rather than simply a change from paper to PDF.
1. Who Is Covered by RMC No. 98-2026?
The full text of RMC No. 98-2026 keeps the taxpayer coverage established under RR No. 11-2025 and RR No. 26-2025.
| Taxpayer Group | Current Requirement |
|---|---|
| Small, Medium and Large taxpayers engaged in e-commerce or internet transactions | Must comply with electronic invoice issuance requirements by December 31, 2026 |
| Micro e-commerce taxpayers | Exempt from mandatory adoption under the current rules |
| Taxpayers under the Large Taxpayers Service | Covered |
| Large Taxpayers classified under the Ease of Paying Taxes Act and RR No. 8-2024 | Covered |
| Taxpayers using CAS, CBA with accounting records and e-invoicing, or other invoicing software | Covered |
| Other taxpayers designated by the Commissioner | Covered when formally required |
Under RR No. 8-2024, a Micro Taxpayer generally has annual gross sales below ₱3 million. Small Taxpayers have gross sales from ₱3 million to below ₱20 million, while Medium Taxpayers have gross sales from ₱20 million to below ₱1 billion.
Sellers should confirm their official BIR classification instead of deciding their status from current marketplace sales alone. RMC No. 98-2026 also states that a covered taxpayer generally continues using electronic invoicing after a later reclassification to a lower category, unless BIR expressly reclassifies or exempts it through a separate issuance.
2. What Qualifies as a BIR-Compliant Electronic Invoice?
An invoice is considered electronic only when it meets all of the following conditions:
- It is generated through duly registered, approved or accredited accounting or invoicing software.
- It uses a structured electronic format that computers can automatically read and process.
- It is electronically transmitted to the customer through email, online viewing, QR code, a mobile application, a web platform or another electronic channel.
- Its data can be electronically extracted, processed and transmitted for future BIR sales-reporting purposes.
An invoice manually created in Microsoft Word, Excel, Google Docs or Google Sheets does not qualify. A scanned paper invoice or ordinary PDF is also insufficient by itself. Even an invoice printed from a computerized accounting or POS system is treated as non-electronic if the underlying system cannot issue it digitally to the buyer and prepare the required sales data.
The BIR's existing Electronic Invoicing and Sales Reporting System uses JSON for sales-data transmission. A business may continue using another structured format internally, provided that the required data can be converted into the BIR-prescribed format.
A printed copy may still be provided when requested or when electronic delivery is impractical in a B2C transaction. However, the original invoice must have been generated by a compliant system and remain capable of electronic issuance.
3. PTI, EIS Certification and PTT: What Is the Difference?
Three similar abbreviations refer to different stages of compliance.
| Requirement | Purpose | When It Applies |
|---|---|---|
| Permit to Issue Electronic Invoice (PTI) | Authorizes a taxpayer to issue electronic invoices through the approved system | Must be obtained before electronic invoices are issued |
| EIS Certification | Tests whether the system can extract, process and transmit sales data according to BIR technical standards | Must be completed within six months after PTI issuance |
| Permit to Transmit (PTT) | Relates to the transmission of sales data under the electronic sales-reporting requirement | Applies only after a formal notification or directive from the Commissioner |
The PTI is separate from the Permit to Use or Acknowledgement Certificate for a Computerized Accounting System. Having an approved CAS does not automatically authorize the business to issue electronic invoices under the new rules.
PTI applications are filed with the taxpayer's registered Revenue District Office or Large Taxpayer Office. RMC No. 98-2026 provides a 20-working-day evaluation period after complete documents are received. A change to the approved platform or core invoicing software may require a new or amended permit.
Important: Electronic invoice issuance and electronic sales reporting are separate obligations. Covered sellers must prepare invoice data that can be transmitted, but mandatory sales-data reporting and the PTT requirement begin only when BIR issues the relevant implementation rules or directive.
4. Operational Rules Online Sellers Should Prepare For
Invoices cannot simply be edited or deleted
Once issued, an electronic invoice must not be deleted, altered or modified. A reduction caused by a return, allowance, discount or overbilling requires an authorized Credit Note or Credit Memo referencing the original invoice. An increase requires a new electronic invoice.
System downtime does not remove the invoicing obligation
During a system failure, internet outage, power interruption, cybersecurity incident or similar event, the seller must issue a BIR-authorized manual invoice. After the system is restored, that document must be replaced with an electronic invoice carrying the reference number of the manual invoice.
Branches are covered at taxpayer level
When a taxpayer is covered, the head office and all registered branches must issue electronic invoices, even if the covered ecommerce activity operates from only one location. Branches using different invoicing systems may require separate PTIs for each distinct system.
No ESP should be assumed to have blanket BIR endorsement
RMC No. 98-2026 allows taxpayers to use an in-house solution, commercially acquired software or an Electronic Invoicing Service Provider. However, the detailed policies governing ESPs will come through a separate revenue issuance. BIR had also clarified before the circular that it had not accredited, authorized or endorsed any entity as an official ESP. Sellers should verify the exact status of a provider, software and taxpayer implementation instead of relying on a general “BIR-accredited e-invoicing provider” claim.
5. What Should Philippine Online Sellers Do Now?
- Confirm coverage. Check the taxpayer classification, registered branches and every sales channel that may fall under the mandate.
- Audit the current invoicing system. Determine whether it can create structured invoices, deliver them electronically and convert the required data to BIR's prescribed format.
- Map transaction data. Align marketplace orders, Merchant SKUs, buyer details, discounts, VAT, withholding taxes, payments, returns and invoice numbers.
- Prepare the PTI application. Confirm the approved software configuration and identify whether different branches or business units use separate systems.
- Test normal and exception workflows. Cover completed sales, cancellations, returns, Credit Notes, system downtime and manual-invoice replacement.
- Plan EIS Certification. Build the six-month certification period into the implementation schedule instead of treating PTI approval as the final step.
The deadline may be December 31, but software configuration, data cleaning, permit processing and testing can take time. Businesses with multiple stores, warehouses or branches should assign clear owners across ecommerce operations, finance, accounting and technical implementation.
6. How BigSeller and AutoCount Support the Transition
Electronic invoicing depends on complete and consistent transaction data. BigSeller centralizes orders from marketplaces such as Shopee, Lazada and TikTok Shop, while Merchant SKU Mapping helps connect marketplace products with internal inventory and accounting records.
For eligible Philippine businesses, the BigSeller × AutoCount integration can sync supported orders to AutoCount Accounting 2.1 or 2.2, generate Sales Invoices and Sales Receipts, and update inventory records. Received purchase orders can also be synchronized for Purchase Invoice and stock updates. AutoCount identifies Accounting V2 as BIR CAS-ready.
This connection can reduce repeated exports and manual encoding across ecommerce and finance workflows. It does not, however, replace the taxpayer's PTI application, EIS Certification, BIR-approved configuration or professional tax review. Each business must confirm that its final system setup and invoice process satisfy RMC No. 98-2026.
For a simpler introduction to the deadline and taxpayer coverage, read BigSeller's BIR E-Invoicing Philippines 2026 guide.
This article provides general information and does not constitute tax, accounting or legal advice. BIR may issue additional procedures covering PTI applications, ESPs, sales adjustments and electronic sales reporting. Confirm the latest requirements with BIR or a qualified Philippine tax professional before implementation.
