9 November 2026 · Bureau of Internal Revenue

BIR suspended the seal badge. The registration did not move

On 26 October 2026 the Commissioner of Internal Revenue issued Revenue Memorandum Circular No. 113-2026, suspending the mandatory display of the BIR Registration Seal Badge until further notice. The obligation to be registered, to issue invoices and to file returns is not mentioned in the circular and is untouched by it.

On 26 October 2026 the Commissioner of Internal Revenue issued Revenue Memorandum Circular No. 113-2026. It suspends, until further notice, the mandatory display of the BIR Registration Seal Badge prescribed by RMC No. 38-2026, as supplemented by RMC Nos. 64-2026 and 99-2026. The circular sets no replacement date.

What the suspension covers

Only the badge. In the text of RMC No. 113-2026 the suspension is directed at the mandatory display of the Registration Seal Badge and at nothing else. Taxpayers who already secured a badge may continue to display it from their online platforms, at their option. The circular then states that no penalties shall be imposed solely on account of non-display of the badge during the period of suspension.

The word solely carries the weight. It protects a seller who is registered, issues invoices and files returns, but has no badge on a shop page or a social media account. It does not protect a seller who never registered.

The date that was replaced

Before the suspension the operative date was 31 October 2026. RMC No. 99-2026, dated 24 September 2026, extended the period for compliance with the display requirement to that date. In its own words, taxpayers who had not yet displayed the Registration Seal Badge were given until 31 October 2026 to comply fully, without the imposition of penalties arising solely from the non-display. RMC No. 113-2026 withdrew the compulsion before the date arrived. It suspended the requirement; it did not delete it.

Who was covered

RMC No. 99-2026 restated the population: online sellers, online merchants, and persons engaged in the sale of goods or services through digital or electronic platforms, as well as those with an online business presence. It cited Section 5(H) of Revenue Regulations No. 7-2024 and Section 7 of RR No. 15-2024 as the source of the posting duty. A foreign-owned entity selling through a Philippine e-marketplace, or through its own site, fell inside that description. So did a resident sole proprietor trading online, which is the segment most exposed, because a badge carries a QR code that resolves to the registered name rather than to a chosen trade name.

What did not move

Three obligations sit outside this circular: registration, the issuance of invoices, and the filing of returns. RMC No. 113-2026 is silent on all three. A suspension of a display format cannot be read as a suspension of the registration that the display was meant to evidence.

Two consequences follow for a business that is partway through setup.

• A Certificate of Registration that was amended, or a branch that was added, still needs the corresponding registration step closed. The badge question does not defer it.
• Invoicing continues on its own clock, including the separate creditable withholding tax line required under RR No. 6-2026, with its own transitory dates for systems.

How to hold a suspension that has no end date

Until further notice cuts both ways. Nothing has to be done today to satisfy a badge rule that is not being enforced. Nothing should be dismantled either. The defensible position is to keep the registration documents current, keep the badge file if one was already generated, and treat display as a privacy decision rather than a compliance one while the suspension lasts.

When a later circular restores the requirement, the compliance window will be fixed in that circular, not in this one. A file that is otherwise complete moves quickly at that point. A file with an unregistered branch, a stale registered address or an invoice layout that was never corrected does not.

Where this leaves a foreign-owned seller

The suspension removes an administrative annoyance and leaves the underlying structure exactly where it was. The useful work this month is not the badge. It is the registration certificate matching the address actually used, the invoice set matching the current rules, and a clear record of which filings are due next. Those are the items a later circular will assume are already in order.