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RMC No. 110 - 2026 — Accreditation for E-Invoicing Service Providers

Tax advisoryIssued 12 October 2026Effective Immediately

The Bureau of Internal Revenue has issued Revenue Memorandum Circular no. 110 – 2026, prescribing the accreditation and continuing compliance requirements for Electronic Invoicing Service Providers (ESPs) to strengthen the security, reliability, and proper handling of electronic invoices and sales data.

What the Circular Does

  • Mandatory Accreditation for E-Invoicing Service Providers (ESP): Tech providers can no longer sell e-invoicing systems or software without passing strict BIR accreditation process first.
  • Protects taxpayers from data hostages: It outlaws hidden exit fees and explicitly bans software providers from blocking a business's access to its own tax records over billing disputes.
  • Enforces a 3-day data deadline: It mandates that the software must successfully transmit sales records to the BIR in real-time or within 3 calendar days.

7-Stage Accreditation Process

  • Documentary Review: Checks all legal permits and paperwork.
  • Fit-and-Proper and Fnancial Capacity Review: Proves the tech vendor is stable and won't suddenly shut down.
  • Technical Architecture: Verifies the system structure handles data smoothly.
  • Cybersecurity & Data Residency Check: Protects data against hackers and keeps it localized (EO 119).
  • Live System/solution Demonstration: Proves the software actually works in real-time.
  • Interoperability and end-to-end transmission testing: Confirms the app communicates perfectly to BIR servers.
  • Stress & Load Testing: Checks if the system will not crash during peak transaction volume.

Protection to Businesses

  • Hostage-Free Data: Providers cannot cut off or disable your access to tax records over contract or billing disputes.
  • No Hidden Fees: Lock-in fees, hidden charges, or exit penalties to get your data back are illegal.
  • Safe Harbor: Taxpayers will not be penalized for transmission failures caused entirely by an accredited ESP.
  • Accreditation Lifespan: Approved software certificates are good for 5 years with an annual checkup. This protects businesses by ensuring long-term operational stability and preventing frequent, costly system changes caused by short vendor lifecycles.

Key Reminders to Businesses

  • Check Accreditation: Verify your provider’s BIR accreditation.
  • Monitor Transmission: Ensure invoice data is transmitted on time.
  • Secure Your Records: Keep your invoicing data accessible.
  • Ensure Data Portability: Confirm you can export or transfer your records when changing providers.
  • Report System Issues: Know the proper process for reporting transmission failures.
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The advisory in six cards

The same summary, in the form we publish on social media. Select any card to read it full size.

This advisory is a general summary and is not a substitute for professional advice. For guidance on your own situation, please consult us.

Related: AAC Tax Calendar · AAC Tax Code · All advisories

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