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RMC No. 98-2026 — Policies and Guidelines on the Issuance of Electronic Invoice

Tax advisoryIssued September 22, 2026Effective Immediately

The Bureau of Internal Revenue has issued Revenue Memorandum Circular No. 98-2026, on September 22, 2026, setting the mandatory compliance deadline of December 31, 2026, for covered taxpayers to adopt compliant electronic invoicing systems.

What the Circular Does

RMC No. 98-2026 establishes the legal definitions, operational boundaries, and system prerequisites for how businesses in the Philippines must issue electronic invoices and report sales to the Bureau of Internal Revenue. The circular outlines valid electronic invoice formats, imposes new permit and certification chains, mandates decentralized system rules per branch, and prescribes manual workarounds during system downtime.

Key Compliance Deadline

December 31, 2026: All covered taxpayers must be fully capable of issuing compliant electronic invoices and electronically reporting sales. This extends the transition period under previous regulations (RR No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025).

Covered Taxpayers

  • Taxpayers engaged in e-commerce or internet transactions, classified as Small, Medium and Large Tarpayers (Micro Taxpayers are exempted).
  • Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS).
  • Taxpayers classified as Large Taxpayer under Republic Act (RA) No. 11976 (Ease of Paying Taxes [EOPT] Act) and RR No. 8-2024.
  • Taxpayers using CAS or CBA with Accounting Records (with electronic invoicing), and other invoicing software.
  • Other taxpayers as may be required by the Commissioner of Internal Revenue.

Risk and Compliance Issues

  • Failure to Transition Before Deadline: Covered taxpayers who fail to comply and issue electronic invoice on or before the deadline may face heavy fines and revocation of permits.
  • Using Invalid “Electronic Invoice”: Electronic invoice does not include a pdf file, scanned invoices, images of paper invoice, and printed system-generated invoices that cannot support electronic reporting requirements.
  • Failure to Secure the Correct Permit: Leads to automatic invoice invalidation, where buyers cannot claim input VAT or deduct expenses.
  • Improper Correction of Issued Electronic Invoices: Will invalidate the correction and flag your system for an audit due to data mismatches with the BIR
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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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