POS System BIR Updated E-Invoicing

This Circular is issued to prescribe the policies and guidelines on electronic invoicing
(issuance of electronic invoice) pursuant to Sections 237 of the National Intemal Revenue
Code, as amended (Tar Code), as implemented by RR No. 8-2022 and RR No. 1l-2025, as
amended by RR No. 26-2025.

For purposes of this Circular, the following words and phrases shall have the meaning
indicated below:

l. Computerized Accounting System (CAS) - refers to the integration of different
component systems and processes to produce computer-generated accounts and
accountihg records, including system-generated invoices, reports and documents. It
involves computerized processing of full accounting cycle, i.e., from the inception of
the transaction, issuance of invoices up to the generation of financial reports. In any
case that an invoice shall be manually issued, the system/software/application shall be
considered as Computerized Books of Accounts (CBA) with Accounting Records.

2. Credit Note/lVlemo - refers to a document issued by the seller to reduce or cancel, in
whole or in part, a previously issued invoice due to returns, allowances, discounts,
overbilling, or similar adjustments.

3. Electronic Commerce (e-commerce) - refers to any commercial transaction
conducted through electronic, optical, and similar medium, mode, instrumentality and
technology. The transaction includes the sale or offer for sale, purchase of physical or
digital goods and services, or lease or offer for lease of the same, between individuals,
households, businesses, and governments conducted over  computer-mediated networks 
through the Internet, mobile phones, electronic data interchange, or other electronic
channels through open or closed networks. These may be digitally ordered, digitally
delivered or platform-enabled transactions. Internet transactions shall also refer to ecommerce.

4. Electronic Invoicing - refers to the automated process of generating an electronic
invoice in a structured invoice data which can be easily extracted electronically from
the invoice allowing for automated electronic data processing. It involves the electronic
exchange of an electronic invoice that records a transaction between a seller and a
buyer. This can be a one-way electronic exchange where the seller sends the electronic
invoice to the buyer.

5. Electronic Invoicing Service Provider (ESP) - refers to a juridical entity organized or
duly licensed to do business in the Philippines that provides e-invoicing, sales reporting,
integration, validation, transmission, storage, preservation, retrieval, reconciliation,
migration, and audit-support services to taxpayers.

The ESP shall maintain an authorized representative and accountable technical,
compliance, data-protection, and security officers in the Philippines.

6. Electronic Invoicing and Sales Reporting (EIS) Certification - refers to the process
that provides an environment for the online testing of the developed system by the
taxpayer. It has five (5) mandatory tests, or seven (7) tests, if with API callback.

7. Permit to Issue (PTI) Electronic Invoice - refers to the authority granted by the BIR
authorizing a ta(payer to issue electronic invoices that comply with the prescribed
electronic invoicing requirements, through a duly registered and/or approved invoicing
system.

The PTI is distinct from the Permit to Use (PTU) or Acknowledgement Certificate (AC)
for CAS, which authorizes the use of such systems but does not by itself constitute
authority to issue electronic invoices.

8. Point-of-Sale (POS) System - refers to a type of sales receipting system that is
considered more complex than a Cash Register Machine, which may have the capability
to record and track customer orders, process debit and credit card accounts, linked to
other systems in the establishment's network and manage inventory. Similarly, this
system can record the sale/transfer of merchandise or services rendered with systemgenerated invoices.

9. Structured Invoice Data - refers to the invoice information organized in a standard
digital format that computers can automatically read, process, store, and transmit
electronically without manual data entry.

This issuance shall apply for the following taxpayers:

l. Taxpayers engaged in e-commerce or internet transactions, classified as Small, Medium
and Large Tarpayers (Micro Taxpayers are exempted);

2. Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS);

3. Taxpayers classified as Large Taxpayer under Republic Act (RA) No. 11976 (Ease of
Paying Taxes [EOPT] Act) and RRNo. 8-2024;

4. Taxpayers using CAS or CBA with Accounting Records (with electronic invoicing),
and other invoicing software; and

5. Other taxpayers as may be required by the Commissioner of Internal Revenue.

All covered taxpayers shall adhere to this Circular and shall follow the policies and
guidelines provided herein:

l. All taxpayers covered under Section III of this Circular, except those classified as Micro
taxpayers, shall be required to issue electronic invoices and comply with the provisions of
this Circular on or before December 31,2026.

Other taxpayers not covered by the mandate of the provisions of Section 237 of the Ta:r
Code may issue electronic invoices in lieu of manual invoices.

2. The obligation to issue electronic invoices pursuant to Section 237 of the Tax Code shall
be separate and distinct from the obligation to comply with the electronic sales reporting
requirements under Section 237-A of the Tax Code.

Taxpayers enumerated under Section III of this Circular shall be required to comply with
the electronic sales reporting requirements only upon the issuance by the Bureau of the
implementing policies, guidelines, and procedtues for such purpose.

3. Taxpayers shall have the option to use an in-house or commercially acquired electronic
invoicing solution, or avail of the services offered by an ESP. Policies and guidelines
governing ESPs shall be prescribed through a separate revenue issuance.

4. An invoice shall be considered an Electronic Invoice only if it satisfies all of the following
requirements:
a. It is generated by a duly registered, approved, or accredited accounting/invoicing
software or system in a structured electronic format;
b. It is electronically generated and transmitted to the buyer, purchaser, or client in
digital format through any of the following means: email, online viewing, Quick
Response (QR) Code, mobile applications, web-based platforms, or other electronic