Two obligations, kept separate

The BIR's Electronic Invoicing System (EIS) rests on two sections of the Tax Code:

  • Issuing electronic invoices (Section 237). Covered taxpayers issue their sales invoices electronically, in structured data that can be read by a system and reported to the BIR.
  • Reporting sales electronically (Section 237-A). Covered taxpayers send their sales data to the BIR system to system.

The BIR treats these as separate and distinct. Electronic sales reporting applies once the BIR issues the policies, guidelines and procedures for it.

Source: RMC No. 98-2026, Section IV.2.

Who is covered

The BIR's current issuances name these groups:

  • Taxpayers engaged in e-commerce or internet transactions, classified as small, medium or large (micro taxpayers are exempt)
  • Taxpayers under the jurisdiction of the Large Taxpayers Service
  • Taxpayers classified as large under the Ease of Paying Taxes Act (RA 11976)
  • Taxpayers using a computerized accounting system (CAS), computerized books of accounts with electronic invoicing, or other invoicing software
  • Other taxpayers the Commissioner may require

Where a branch is covered, the head office and all branches are covered too. For most medium and large companies, that means every branch and every billing system.

Sources: RMC No. 98-2026, Sections III and IV.10; RR No. 11-2025 as amended by RR No. 26-2025.

What counts as an electronic invoice

A printed or scanned invoice is not an electronic invoice. Under RMC No. 98-2026, an invoice counts as electronic only if, among other requirements, it is:

  • generated by a registered, approved or accredited accounting or invoicing system, in a structured electronic format; and
  • generated and given to the buyer in digital form, for example by e-mail, online viewing, a QR code, a mobile app or a web platform.

Companies may use an in-house system, a commercially acquired solution, or the services of an electronic invoicing service provider.

Source: RMC No. 98-2026, Sections IV.3 and IV.4.

The steps a company goes through

Each step is a separate application to the BIR.

  1. Register the system. The CAS or invoicing system is registered and the BIR issues an Acknowledgement Certificate.
  2. Obtain the Permit to Issue. The company applies for its Permit to Issue electronic invoices.
  3. Obtain the EIS Certification. The company's system is tested in the BIR's sandbox for authentication, invoice transmission and result inquiry. Certification is done per server, and must be secured within six months of the Permit to Issue, or the permit can be revoked (RMC No. 98-2026, Section IV.15).
  4. Permit to Transmit, where directed. Live transmission to the BIR follows the Permit to Transmit, which applies on the BIR's notification or direction.

Certification belongs to each company as the taxpayer. A software vendor can prepare it and support it, but does not hold it for you.

What it means for your invoices

The rules are short. The work sits in the data. In the exports we see, the same details come up again and again:

  • Which date counts as the invoice date, and dates written differently across systems
  • Invoice numbers outside the serial range registered for the system
  • Buyer TINs that are missing or written in different ways
  • VAT, non-VAT, zero-rated and RBE sales coded alike
  • Line items with no quantity, or no unit cost net of VAT
  • Totals that no longer add up after rounding

None of these is hard to fix once it is found. The challenge is finding them across many branches and systems, fixing each at its source, and keeping a record of what changed and who approved it.

Where Resibo fits

Resibo reads what your ERP already produces, checks every invoice against the BIR's e-invoicing rules, shows your team what to fix and where, and keeps a tamper-evident record. When the BIR directs electronic sales reporting, approved invoices go to the EIS under your own permit and credentials. See the full solution.

This guide is general information about the BIR's published rules and specifications. It is not tax advice. Your tax adviser confirms how the rules apply to your company.