22 October 2026 · Bureau of Internal Revenue

E-invoicing is due in eight weeks. The permit is the bottleneck

The Philippines moves to mandatory electronic invoicing on 31 December 2026. With eight weeks left, the constraint is not the software. It is a permit that the Bureau has 20 working days to evaluate, and that you cannot issue a single compliant invoice without.

The obligation comes from Republic Act No. 12066, which rewrote section 237 of the Tax Code, and is implemented by Revenue Regulations No. 11-2025 as amended by RR No. 26-2025, which replaced the original transitory periods with a single date: 31 December 2026. Revenue Memorandum Circular No. 98-2026 of 22 September 2026 sets out how it operates.

Who is covered

Four groups, in the regulation's own words: taxpayers in e-commerce or internet transactions classified Small, Medium or Large, with micro taxpayers exempt; taxpayers under the Large Taxpayers Service; large taxpayers under RA 11976 and RR 8-2024; and taxpayers using a Computerized Accounting System, Computerized Books of Accounts with electronic invoicing, or other invoicing software.

The e-commerce definition is broad enough to catch online sellers, digital platforms, content creators, freelancers, and delivery or ride-hailing operators. If you sell online and your gross sales are ₱3,000,000 or more, assume you are covered.

The sequence, and where files will stall

First, a Permit to Issue from the RDO or the Large Taxpayer office. The Bureau evaluates within 20 working days of a complete application. Each distinct invoicing system needs its own permit, and it covers the head office and every branch under one number. Second, EIS certification within six months of the permit, or the permit can be revoked.

Twenty working days is four calendar weeks, if the application is complete on the day it is filed. An incomplete application restarts the clock. That, not the software, is the timeline risk in the last quarter of 2026.

What does not count as an electronic invoice

An invoice generated in Word or Excel. A system-generated invoice printed and handed over on paper, where the system cannot issue and transmit it electronically. Both fail the definition, and both are the most common first attempt.

Two duties also need to be kept apart: issuing e-invoices, due 31 December 2026, and electronic sales reporting, which becomes mandatory only when the Bureau issues separate implementing rules. As of October 2026 it has not.

The downtime rule

When the system is unavailable, issue a manually authorised invoice, then replace it with an electronic invoice that references the manual number once the system is back. An issued electronic invoice cannot be deleted or altered: a decrease needs a credit note, an increase needs a new invoice.