The Bureau of Internal Revenue (BIR) issued Revenue Regulation (RR) No. 28-2025 last 22 December 2026, to implement the enhanced version of the Electronic Documentary Stamp Tax (eDST) System.
The regulation requires certain taxpayers to use the enhanced eDST system when affixing documentary stamps to taxable documents.
Taxpayers covered
The enhanced eDST system is mandatory for taxpayers, whether individuals or non-individuals, engaged in the following industries:
- Banks, quasi-banks, non-bank financial intermediaries, finance companies, insurance, surety, fidelity, or annuity companies;
- Shipping and airline companies;
- Pre-need companies in relation to the sale of pre-need plans;
- Educational institutions issuing taxable certificates such as diplomas and transcripts of records;
- National government agencies and instrumentalities, including government-owned or controlled corporations and local government units (except barangays), insofar as documents taxable as certificates are concerned;
- Notaries public, including those employed in law firms and other public or private offices; and,
- Other industries that may later be required by the Secretary of Finance upon recommendation of the Commissioner of Internal Revenue.
How the enhanced eDST system works
Under the enhanced eDST system, taxpayers may choose between two modules upon enrollment:
Deposit Module. This module requires an advance deposit, which is credited to the taxpayer’s ledger account. The deposit is automatically deducted each time documentary stamps are printed for taxable documents.
Non-Deposit Module. This module allows the immediate printing of documentary stamps without an advance deposit. The total documentary stamp tax for all documents printed during the month must be remitted on or before the prescribed deadline.
Once a taxpayer has enrolled and selected a module, shifting to the other module is no longer allowed.
Limited use of Loose Documentary Stamps
As an exception to the mandatory use of the enhanced eDST system, the BIR allows the use of loose documentary stamps, subject to limitations that may be imposed through a separate issuance.
Loose documentary stamps may only be used for documents taxable under Section 188 of the Tax Code where the documentary stamp tax due does not exceed ₱30. The affixture of multiple loose stamps to cover a tax due exceeding ₱30 is prohibited.
The advance purchase of multiple loose documentary stamps for future affixture is generally not allowed, except as may be permitted by the Commissioner.
This regulation took effect last 6 January 2026, following its publication on the BIR’s official website.
Treatment on the Excess Deposit in Case upon Business Closure
In the event of business closure, any excess deposit reflected in the taxpayer’s eDST ledger account will be validated by the BIR. The validated excess will first be applied against outstanding documentary stamp tax liabilities, then against other tax liabilities. Any remaining balance after settlement of all tax dues will be refunded to the taxpayer.
Please be guided accordingly.
Source:
P&A Grant Thornton
Certified Public Accountants
P&A Grant Thornton is the Philippine member firm of Grant Thornton Internation Ltd.
As published in SunStar Cebu, dated 28 January 2026
