RMC No. 98-2026: Prescribing Policies and Guidelines on the Issuance of Electronic Invoice under RR No. 8-2022 and RR No. 11-2025, as Amended by RR No. 26-2025

The Bureau of Internal Revenue (BIR) has further advanced its digital transformation initiatives through the issuance of Revenue Memorandum Circular (RMC) No. 98-2026, which prescribes the policies and guidelines on the issuance of electronic invoices pursuant to Section 237 of the National Internal Revenue Code, as implemented under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025. The Circular provides much-needed clarifications on the scope, requirements, and implementation of electronic invoicing, particularly for businesses transitioning from traditional invoicing systems to digital platforms. 

The Circular emphasizes that the obligation to issue electronic invoices under Section 237 of the Tax Code is separate and distinct from the obligation to comply with electronic sales reporting requirements under Section 237-A. Thus, compliance with electronic invoicing does not automatically mean immediate compliance with electronic sales reporting unless specifically required by the BIR through subsequent issuances. 

Who are required to issue Electronic Invoices?

In line with RR No. 26-2025, the following taxpayers are required to comply with the electronic invoicing requirements on or before 31 December 2026:

1. Taxpayers engaged in electronic commerce (e-commerce) or internet transactions classified as Small, Medium, and Large Taxpayers, with Micro Taxpayers expressly exempted;
2. Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS);
3. Taxpayers classified as Large Taxpayers under the Ease of Paying Taxes (EOPT) Act; and
4. Taxpayers using Computerized Accounting Systems (CAS), Computerized Books of Accounts (CBA) with electronic invoicing, and other invoicing software systems. 

Meanwhile, exporters, registered business enterprises enjoying tax incentives, taxpayers using Point-of-Sale (POS) systems, and other taxpayers that may be designated by the Commissioner are not yet covered by the mandatory deadline and shall be subject to separate implementing regulations to be issued in the future. 

What qualifies as an Electronic Invoice?

The RMC clarifies that not all digitally generated invoices qualify as electronic invoices for tax purposes.

To be considered a valid electronic invoice, the invoice must satisfy all of the following conditions:

• It must be generated through a duly registered, approved, or accredited accounting or invoicing software system;
• It must be issued electronically to the buyer through electronic means; and
• The invoice data must be capable of electronic extraction, processing, and transmission to the BIR for electronic sales reporting purposes. 

Hence, generating an invoice using a computerized system and printing it on paper does not automatically make it an electronic invoice. If the system is not capable of electronically extracting and transmitting the required invoice data, the invoice will continue to be treated as a traditional invoice rather than an electronic invoice. 

Acceptable methods of issuance

The Circular allows electronic invoices to be issued through various electronic channels e.g. email transmission, online customer portals, web-based platforms, mobile applications, QR-code-enabled retrieval systems, and other electronic means that allow the buyer to access and receive invoice information electronically. 

Implications for taxpayers

Businesses covered by the regulations should evaluate their processes and systems considering the deadline set. Taxpayers currently using CAS, invoicing software, or other digital accounting platforms must determine whether their systems meet. 

RMC 98-2026 takes effect immediately. 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 30 September 2026