If you've been scrolling social media lately, you've probably seen ads shouting "BIR-accredited e-invoicing!" Here's the twist: the BIR itself has said that, for now, nobody can truthfully claim that.
With the December 31, 2026 deadline getting closer and new rules landing in September, it's easy to feel lost. So let's walk through what the advisory says, what the new guidelines require, and what you can do right now without panicking.
Last updated: October 5, 2026. This is a fast-moving topic, so check the BIR's official channels for changes. This article is general information, not tax or legal advice.
The quick version
- The BIR issued a public advisory on September 14, 2026 about vendors claiming to be "BIR-accredited" e-invoicing providers.
- On September 22, 2026, it issued RMC No. 98-2026, with e-invoicing guidelines that took effect immediately.
- Covered taxpayers generally have until December 31, 2026, and micro taxpayers are exempt.
- Your first step is to confirm whether you're covered.
In this article
- What the advisory says
- Spotting misleading claims
- E-invoicing in plain language
- The key rules in RMC 98-2026
- Timeline
- Who's covered
- How to prepare
- FAQ
What the BIR Public Advisory Says
The advisory is short and clear. The BIR said it had received reports that some e-invoicing service providers, software developers, and other entities were advertising themselves as "BIR-Accredited," "BIR-Certified," "BIR-Compliant," or "BIR-Authorized" providers of electronic invoicing and sales reporting systems. It clarified that, as of the date of the advisory, it had not accredited, authorized, certified, recognized, or endorsed any entity as an official BIR service provider, partner, representative, or solution provider for these systems.
In other words, nobody gets to say they're officially approved by the BIR for e-invoicing unless the BIR says so through its own channels. The advisory also told everyone to wait for official policies, guidelines, and accreditation requirements. You can read the advisory itself, a copy hosted by KPMG Philippines.
It's worth noting what the advisory is not. It isn't a ban on e-invoicing software, and it doesn't cancel the deadline. It's a warning about marketing claims.
Why It Matters: Spotting Misleading "BIR-Accredited" Claims
Picture a shop owner who gets a message from a vendor saying, "We're BIR-certified for e-invoicing. Sign up today before the deadline!" It sounds reassuring, and with a deadline looming, it's tempting to say yes. (This is a hypothetical example, not a real case.)
The advisory is a reminder to slow down. Some phrases are worth a second look:
- "Official BIR partner"
- "BIR-certified e-invoicing provider"
- "Guaranteed compliant"
When you hear one, ask:
- What exactly are you claiming?
- What is your evidence?
- What does your system do, and what does it leave to me?
- Is that claim based on an official BIR issuance?
Good vendors will answer plainly. Careful wording matters too: describing what a system can do is very different from claiming the BIR has endorsed it.
E-Invoicing in Plain Language
An electronic invoice isn't just a PDF or a photo of a receipt. Under the new guidelines, it's generated by a registered, approved, or accredited system in a structured electronic format, and the system must be able to extract and transmit the data when required. Electronic invoices must be generated by a duly registered, approved, or accredited accounting or invoicing system in a structured electronic format.
Three terms will come up a lot:
- PTI (Permit to Issue) Electronic Invoice. The BIR's permission to start issuing e-invoices.
- EIS certification. A check that your system can extract, process, and transmit sales data.
- ESP (Electronic Invoicing Service Provider). An outside provider you can use instead of building or buying your own system.
E-invoicing is not e-sales reporting
These are two separate requirements. The BIR commissioner said taxpayers should focus on e-invoicing for now, and that separate rules for electronic sales reporting will come later. So meeting the invoicing deadline doesn't mean you've done everything.
E-invoicing is not the same as POS accreditation
If you already use a POS, the process for registering or accrediting it with the BIR is a different thing from the new e-invoicing requirements. One doesn't automatically cover the other, so confirm the specifics with the BIR. You can read about the existing process on our page about BIR POS accreditation.
The Key Rules in RMC 98-2026
On September 22, 2026, the BIR issued Revenue Memorandum Circular No. 98-2026. It took effect immediately, and covered taxpayers generally must comply by December 31, 2026, except micro taxpayers. You can read the official circular and the BIR's press release.
Here are the highlights.
Three ways to comply
Covered taxpayers may use an in-house system, commercially available software, or an Electronic Invoicing Service Provider.
Permit to Issue and EIS certification
A Permit to Issue is required before issuing e-invoices, followed by EIS certification within six months of the permit. The BIR evaluates a complete PTI application within twenty working days. That's one reason not to wait until December.
What doesn't count as an e-invoice
Printed invoices from systems that can't electronically transmit invoices to buyers and report required sales data to the BIR don't qualify as electronic invoices. So simply printing from a new system isn't enough.
Downtime rules
Manual BIR-authorized invoices may be used during system downtime, connectivity problems, or cybersecurity incidents. It's smart to have a written downtime plan.
Head office and branches
The requirements apply to the taxpayer as a whole, and a PTI is issued to the head office and to each branch. If you have several branches, plan for all of them.
Timeline at a Glance
- March 14, 2026: the original deadline. It was later extended to December 31, 2026.
- August 25, 2026: the BIR held a consultation with private-sector stakeholders.
- September 14, 2026: the public advisory on "BIR-accredited" claims.
- September 22, 2026: RMC 98-2026 issued.
- December 31, 2026: the deadline for covered taxpayers.
- After the PTI: EIS certification within six months.
- Later: separate rules for service providers and for electronic sales reporting.
Who Is Covered, and Who Isn't?
The mandate covers small, medium, and large taxpayers engaged in e-commerce or internet transactions, taxpayers under the Large Taxpayers Service, large taxpayers under the Ease of Paying Taxes framework, and businesses using computerized accounting or invoicing systems. Micro taxpayers are excluded.
Ask yourself:
- Which taxpayer category am I in?
- Do I sell online or through e-commerce channels?
- Do I use a computerized accounting or invoicing system?
- Do I have multiple branches?
If you're not sure, ask your accountant or your Revenue District Office. Coverage depends on the exact wording of the circular, so don't rely on a summary alone.
How to Prepare: A Step-by-Step Checklist
You don't need to do everything at once. A simple path looks like this:
- Confirm your classification. Find out whether you're covered.
- Audit your current setup. Can your system produce structured data and send invoices electronically?
- Choose your route. In-house, commercial software, or a service provider.
- Prepare your PTI application. Some advisers suggest filing well ahead of the deadline, such as by late November, since evaluation can take twenty working days.
- Plan for EIS certification. Know what testing will be required.
- Write a downtime plan. Decide how you'll issue manual invoices if systems go down.
- Clean up your data. Consistent product and customer records make everything easier.
- Train your team and document your plan. If questions come up later, a written transition plan helps.
A good rule of thumb: treat December 31 as a deadline, not a starting date.
Common Mistakes and Misconceptions
- Assuming "BIR-accredited" e-invoicing providers already exist. The advisory says otherwise, for now.
- Treating e-invoicing and e-sales reporting as the same thing. They're separate.
- Waiting until December. The PTI process alone can take weeks.
- Assuming a printed receipt from a new system counts as an e-invoice. It may not.
- Choosing a provider based on marketing claims alone. Ask for specifics.
What's Still Unclear, and What to Watch
A few pieces are still pending. The BIR said it would issue separate rules for service providers. As of early October 2026, I couldn't find that issuance, so check the BIR website. Electronic sales reporting rules are also still to come, and further clarifications or FAQs may follow.
The best way to stay current is to watch the official BIR website and follow guidance from your accountant or tax adviser.
Questions About Your Setup?
If you're not sure how your current POS fits into all this, you can talk to the Divergent POS team and ask what to prepare.
Frequently Asked Questions
What did the BIR public advisory on e-invoicing say?
It said the BIR had not accredited, authorized, certified, recognized, or endorsed any entity as an official BIR service provider for electronic invoicing and sales reporting systems, and that no one may claim otherwise.
Is there a BIR-accredited e-invoicing provider?
Not as of the advisory's date, according to the BIR. Check the official BIR website for updates, since the framework for service providers is still being finalized.
When is the e-invoicing deadline?
December 31, 2026 for covered taxpayers, with micro taxpayers exempt.
Who is required to issue electronic invoices?
Coverage includes certain e-commerce taxpayers, taxpayers under the Large Taxpayers Service, large taxpayers under the Ease of Paying Taxes framework, and businesses using computerized accounting or invoicing systems. Confirm your status with your accountant or RDO.
What is a Permit to Issue (PTI) for electronic invoices?
It's the BIR's authority to start issuing electronic invoices. Covered taxpayers need it before issuing, followed by EIS certification within six months.
Is e-invoicing the same as e-sales reporting?
No. They're separate requirements, and e-sales reporting rules will be issued later.
Final Thoughts
The advisory has a simple message: verify before you trust. The deadline is real, the rules are now written, and the smartest move is to confirm your coverage, ask good questions, and start early. Rely on official sources, keep a paper trail, and don't let a flashy "BIR-certified" claim do your thinking for you.
