BIR issues RMC 110-2026 on Electronic Invoicing Service Providers (ESPs) accreditation

The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 110-2026 on 12 October 2026, prescribing the accreditation and continuing compliance requirements for Electronic Invoicing Service Providers (ESPs). It aims to support the government's digitalization initiatives by ensuring that e-invoicing systems are secure, reliable, and aligned with the BIR's tax monitoring objectives through a risk-based accreditation framework for qualified service providers.

The Circular applies to ESPs that offer e-invoicing platforms, software, or services to taxpayers, excluding systems used solely within an organization. Covered ESPs must obtain a BIR Electronic Invoicing Solutions Accreditation Certificate before commercially offering their services. Accreditation is solution-specific and limited to the approved solution, version, modules, interfaces, and deployment configuration, while non-material updates do not require reaccreditation.

As part of the accreditation process, ESPs must submit complete documentary requirements, designate authorized technical and compliance officers, and disclose their beneficial owners, key personnel, and service providers. These disclosures must be updated whenever material changes occur. Failure to provide complete and accurate information, or the submission of false or misleading documents, may result in the denial or non-acceptance of the accreditation application. Accreditation consists of following mandatory stages:

• Documentary completeness review
• Fit-and-proper and financial capacity review
• Technical architecture and end-to-end data flow review
• Data privacy and cybersecurity assessment (including certifications demonstrating compliance with EO No. 119, s. 2026 on Government Data Classification and Data Residency, implementation of adequate cybersecurity controls, favorable Source Code Review and Vulnerability Assessment and Penetration Testing (VAPT) results, and certifications such as ISO/IEC 27001, ISO/IEC 27017, ISO/IEC 27018, SOC 1, SOC 2, or their equivalents)
• System/solution demonstration
• Interoperability and end-to-end transmission testing; and
• Load, stress, scalability, concurrency, failover, backup, and recovery testing

Documentary compliance alone is not sufficient for accreditation. In addition to submitting complete documentary requirements, ESPs must demonstrate operational readiness and successfully pass technical, security, performance, and operational assessments before deployment. Once accredited, ESPs are required to continuously comply with BIR standards, maintain system reliability and data security, cooperate with monitoring and audit activities, and promptly report significant incidents or material changes.

To strengthen taxpayer data protection and system reliability, the issuance requires accredited ESPs to maintain secure infrastructure, adopt internationally recognized security standards, preserve audit trails, and ensure the accessibility of e-invoices and sales data to both taxpayers and the BIR. The rules likewise prohibit vendor lock-in practices and mandate data portability and migration support when taxpayers transfer to another provider.

The BIR may suspend or revoke an ESP's accreditation for non-compliance, service failures, data security breaches, tax evasion-related violations, insolvency, or other violations of applicable laws and regulations. In cases involving material risks to taxpayer data, system integrity, or tax administration, the BIR may impose an immediate temporary suspension, subject to due process. Notwithstanding such suspension or revocation, ESPs remain responsible for data preservation, taxpayer support, confidentiality, audit assistance, incident reporting, and migration support. Administrative sanctions are likewise without prejudice to any civil, criminal, tax, cybersecurity, or data privacy liabilities that may arise.

RMC No. 110-2026 shall take effect immediately upon issuance.  Please be guided accordingly

Source:  

P&A Grant Thornton  

Certified Public Accountants  

P&A Grant Thornton is the Philippine member firm of Grant Thornton International Ltd.

As published in SunStar Cebu, dated 29 October 2026