BIR E-Invoicing and the BIR EIS: Requirements, PTI and Deadline

E-invoicing replaces paper and print-only invoices with structured electronic invoices the BIR can receive. This guide explains the rules in plain language and cites the regulation behind each point, so you can check it yourself.

Key points at a glance

Who must issue e-invoices

RR 11-2025 sets out who is covered first:

• e-commerce taxpayers;
• taxpayers under the Large Taxpayers Service and Large Taxpayers;
• taxpayers using a computerized accounting system (CAS) or computerized books of accounts (CBA) with e-invoicing or invoicing software.

POS users, exporters and registered business enterprises follow in later phases. Micro taxpayers are exempt, but they may adopt e-invoicing voluntarily.

Under RMC 98-2026, coverage applies to the head office and all branches. A taxpayer reclassified upward into a covered group gets at least 6 months to comply. A taxpayer reclassified downward stays covered. See who must e-invoice and when.

The deadline

RR 26-2025 sets December 31, 2026 as the date covered taxpayers must be able to issue e-invoices. The Commissioner of Internal Revenue may extend it, so watch for new issuances, but plan for the current date.

What counts as an e-invoice

RMC 98-2026 uses a three-part test. An e-invoice is:

1. generated by a registered, approved or accredited system in a structured format;
2. delivered to the buyer digitally; and
3. made of data that can be extracted and transmitted to the BIR.

Invoices made in word processors or spreadsheets, such as Word, Excel, Google Docs or Google Sheets, do not pass. See why spreadsheet invoices are not valid and the BIR sales invoice requirements. The buyer can still ask for a printed copy, and you must provide it.

Invoices from a CAS, CRM or POS that are only printed on paper, without e-invoicing and reporting capability, count as manual invoices.

Format and required fields

The format is JSON, as defined in the EIS technical specifications. Your system may keep its own internal format if it can convert the data to that JSON.

The fields follow the minimum invoice information in Section 113 of the Tax Code and RR 7-2024, plus details such as discounts and withholding taxes. Today, invoices from registered systems also show the Acknowledgment Certificate (AC) and its control number, per RMO 9-2021.

Approvals: PTI, then EIS certification

1. PTI Electronic Invoice. File for a Permit to Issue Electronic Invoice with your RDO or LTO. It is separate from your system's PTU or AC. The BIR decides within 20 working days. One PTI number covers the head office and its branches, but each distinct invoicing system needs its own PTI. A change of software, platform or core details needs a new or amended PTI. See the PTI how-to.
2. EIS certification. Test your e-invoices on the EIS certification portal (eis-cert.bir.gov.ph) within 6 months of the PTI. If you miss this, the PTI may be revoked.
3. Permit to Transmit. This applies only when the Commissioner directs it. E-sales reporting under Section 237-A starts only after the BIR issues guidelines.

Corrections, credit memos and downtime

Issued e-invoices cannot be deleted or altered. To reduce an amount, issue a credit note or memo that references the original. To increase it, issue a new e-invoice.

If your system goes down, issue BIR-authorized manual invoices, then replace them with e-invoices that reference the manual invoice numbers.

Incentive

RR 11-2025 allows an additional deduction for the cost of an e-sales reporting system. Ask your tax adviser how it applies to your business.

E-invoicing service providers (ESPs)

Per Grant Thornton's summary of RMC 110-2026, providers that offer e-invoicing services must be accredited by the BIR before offering them commercially, and accreditation involves security testing and certifications such as ISO 27001, 27017 and 27018 and SOC 1 and SOC 2 reports. Ask any provider for its accreditation status.

Background

The Electronic Invoicing System started with RR 8-2022, which covered exporters, e-commerce taxpayers and taxpayers under the Large Taxpayers Service. RR 11-2025 and RMC 98-2026 now set the current rules.

Readiness checklist

1. Confirm whether you are covered, including all branches.
2. List every system that issues invoices: CAS, POS, billing and online store.
3. Stop issuing invoices from spreadsheets or documents.
4. Check that your system can produce structured data convertible to the EIS JSON format, with all required fields.
5. Prepare your PTI Electronic Invoice application for your RDO or LTO.
6. Plan EIS certification within 6 months of the PTI.
7. Set up credit memo and downtime procedures.

How OneOffice is preparing

OneOffice invoicing keeps invoice data in structured fields, and invited clients can view their invoices in the client portal and pay through Maya payment links.

Frequently asked questions

What is the deadline for BIR e-invoicing?

Under RR 26-2025, covered taxpayers must be able to issue e-invoices by December 31, 2026. The Commissioner of Internal Revenue may extend this deadline.

Who is required to issue e-invoices?

Under RR 11-2025, the first group covers e-commerce taxpayers, taxpayers under the Large Taxpayers Service, Large Taxpayers, and taxpayers using a computerized accounting system (CAS) or computerized books of accounts with e-invoicing or invoicing software. POS users, exporters and registered business enterprises follow later. Micro taxpayers are exempt but may join voluntarily.

Is an invoice made in Excel or Google Sheets a valid e-invoice?

No. RMC 98-2026 states that invoices made in word processors or spreadsheets, such as Word, Excel, Google Docs or Google Sheets, are not e-invoices.

What file format does the BIR require for e-invoices?

RMC 98-2026 points to JSON as defined in the EIS technical specifications. A system may keep another internal format if it can convert the data to that format.

Do I still need to give a printed invoice?

Yes, when the buyer asks for one. RMC 98-2026 requires a printed copy of the e-invoice on request.

What is a PTI Electronic Invoice?

It is the Permit to Issue Electronic Invoice. It is separate from the Permit to Use or Acknowledgment Certificate for your system. You file it with your RDO or LTO, and the BIR decides within 20 working days.

Do branches need their own PTI?

No. Under RMC 98-2026, the head office and its branches use the same PTI number. A separate PTI is needed for each distinct invoicing system.

What happens if I change my invoicing software?

A change in software, platform or core system details requires a new or amended PTI under RMC 98-2026.

What is EIS certification?

It is the test that your e-invoices can be accepted by the BIR Electronic Invoicing System, done on the EIS certification portal at eis-cert.bir.gov.ph. It must be finished within 6 months of the PTI, or the PTI may be revoked.

Can I edit or delete an e-invoice after issuing it?

No. Issued e-invoices cannot be deleted or altered. A decrease is made with a credit note or memo that references the original, and an increase with a new e-invoice.

What do I do if my system is down?

Issue BIR-authorized manual invoices during the downtime, then replace them with e-invoices that reference the manual invoice numbers.

Are invoices printed from my CAS or POS already e-invoices?

Not by themselves. Invoices from a CAS, CRM or POS that are only printed on paper, without e-invoicing and reporting capability, are treated as manual invoices.

Do I have to transmit e-invoices to the BIR now?

The Permit to Transmit applies only when the Commissioner directs it, and e-sales reporting under Section 237-A starts only after the BIR issues guidelines.

Is there a tax incentive for adopting e-invoicing?

RR 11-2025 allows an additional deduction for the cost of an e-sales reporting system. Check the regulation and your tax adviser for how it applies to you.

What is an Electronic Invoicing Service Provider (ESP)?

It is a provider that offers e-invoicing services to taxpayers. Per Grant Thornton's summary of RMC 110-2026, ESPs must be accredited by the BIR before offering the service commercially.

Related guides

• BIR Sales Invoice vs Official Receipt: Requirements and E-Invoices

  Why the sales invoice replaced the official receipt, the minimum contents of a BIR sales invoice, when a system-generated invoice counts as an e-invoice, and how corrections and downtime are handled.

• Who Must Issue BIR E-Invoices, and When

  The first group under RR 11-2025, who follows later, and the deadline under RR 26-2025.

• How to Apply for a PTI Electronic Invoice

  What the Permit to Issue Electronic Invoice is, where to file it, how long the BIR takes, and when you need a new one.

• Why Excel and Google Sheets Invoices Are Not E-Invoices

  Spreadsheet and document invoices fail the BIR three-part e-invoice test. Here is why.

This guide is general information, not tax or legal advice. Check the cited regulations or a tax adviser for your situation.