Electronic invoicing
E-invoicing is real, dated, and probably not yours.
The BIR Electronic Invoicing System has been live as a pilot since July 2022 and becomes mandatory for its first group on 31 December 2026. If you earn under ₱3,000,000 a year, none of it applies to you.
What it is
Two obligations, not one. A covered business has to issue invoices as structured data, and transmit the sales behind them to BIR within three calendar days. The second is the real change: it is near-real-time sales reporting, not digital paperwork. The legal basis is Sections 237 and 237-A of the Tax Code, added by TRAIN in 2017 and only now reaching a compliance date.
Does this reach you?
Four questions, answered in your browser. Nothing is sent anywhere.
Exempt
You are a Micro taxpayer, so electronic invoicing does not apply to you.
- Annual gross sales below ₱3,000,000 makes you a Micro taxpayer under the Ease of Paying Taxes Act, and the e-invoicing rules exempt Micro taxpayers outright.
- The exemption holds whether or not you sell online or bill foreign clients. Size is tested first.
- You may still issue electronic invoices voluntarily if you want to. Nothing obliges you to.
A reading of the published rules, not tax advice, and coverage expands by regulation rather than by law. If a real obligation turns on the answer, confirm it with your RDO in writing.
The first mandatory group
RR 11-2025, as amended by RR 26-2025, which moved this from March to December 2026.
E-commerce and internet transactions
31 December 2026
Sellers classified Small, Medium or Large, meaning ₱3,000,000 gross sales and above.
Large taxpayers
31 December 2026
Registered under the Large Taxpayers Service, or classified Large under the Ease of Paying Taxes Act.
CAS and CBA users
31 December 2026
Anyone running a Computerized Accounting System or Computerized Books of Accounts with electronic invoicing, whatever their size.
Named, but with no date
These groups are written into the rules and left waiting on a separate regulation. Nothing is due from them until it exists.
Exporters
No date set
Exporters of goods and services under Sections 106 and 108 of the Tax Code.
Incentivised enterprises
No date set
Registered Business Enterprises availing of incentives under the CREATE MORE Act.
POS users
No date set
Businesses issuing through point-of-sale systems.
Nobody is BIR-accredited for this
The Bureau has issued a public advisory that it does not accredit EIS providers, because the system is still in pilot. Software sold as “BIR-accredited e-invoicing” is claiming something that does not yet exist. “EIS-ready” means built to the published spec, which is a self-description, not an endorsement.
Certification belongs to the taxpayer. You register your own system on the EIS certification portal and the Permit to Transmit is issued to you, not to your vendor. No product can hold either on your behalf, including this one.
What compliance actually involves
- 01
Issue a structured electronic invoice
JSON or XML that BIR's system can read on its own. A PDF, a scan, or a photograph of a paper invoice is not an electronic invoice for this purpose.
- 02
Register the system generating it
A Computerized Accounting System is registered with BIR and issued an Acknowledgement Certificate. Under EOPT this replaced the old Permit to Use.
- 03
Get certified on the EIS portal
The taxpayer registers and certifies its own Sales Data Transmission System. This is done by you, not by your software vendor.
- 04
Obtain a Permit to Transmit
Issued to the taxpayer after certification. Without it, nothing may be transmitted.
- 05
Transmit within three calendar days
Sales data goes to EIS within three calendar days of the transaction, through the standard API. This near-real-time reporting, not the invoice format, is the substantive change.
What is due from you today
Being exempt from EIS does not make invoicing optional. Under the Ease of Paying Taxes Act and RR 7-2024, effective 27 April 2024, the Invoice is the primary document for a sale of services, and the Official Receipt was demoted to a supplementary one. That obligation applies at any size, and to foreign clients as much as local ones.
The forms you do have to fileSources
Practical guidance, not legal or tax advice. Coverage and dates follow RR 11-2025 as amended by RR 26-2025 and are current as of August 2026. The first deadline has already moved once, from March to December 2026, and coverage expands by regulation rather than by law — check the BIR issuances above before relying on this for anything time-sensitive.