[Ask the Tax Whiz] Are you covered by BIR’s new e-invoicing regulation?

MANILA, Philippines – The Bureau of Internal Revenue (BIR) has formally extended the compliance period for the mandatory issuance of electronic invoices (e-invoices), giving covered taxpayers until December 31, 2026 to fully transition to digital invoicing systems.

The extension is contained in Revenue Regulations (RR) No. 26-2025, which amends RR No. 11-2025. While the regulation does not introduce new rules or technical requirements, it provides businesses with additional time to prepare for full compliance with the government’s e-invoicing initiative.

What RR No. 26-2025 covers?

RR No. 26-2025 modifies the compliance timeline in RR No. 11-2025 by extending the deadline for certain taxpayers to issue electronic invoices and prepare for electronic sales reporting. Importantly, the regulation does not change the substantive e-invoicing requirements themselves, but shifts the timeframe to allow businesses more time for system upgrades, staff training, and internal testing. The regulation aims to strike a balance between strengthening tax administration and allowing businesses to transition without disrupting day-to-day operations.

Taxpayers covered by the extended deadline

Under RR No. 26-2025, the following taxpayers now have until December 31, 2026 to comply with the electronic invoicing requirements prescribed in RR No.11-2025

1. Taxpayers  engaged in e-commerce or internet transactions, excluding Micro taxpayers.
2. Taxpayers under the BIR’s Large Taxpayers Service (LTS)
3. Taxpayers classified as Large Taxpayers under Republic Act No. 11976 (Ease of Paying Taxes Act) and RR No. 8-2024.
4. Taxpayers using Computerized Accounting Systems (CAS), Computerized Books of Accounts (CBA) with electronic invoicing, and other invoicing software.

RR No. 26-2025 also clarifies that other categories of taxpayers will also be required to comply once the BIR establishes a system capable of processing and securely storing electronic data. These include:

• Exporters of goods and services under Sections 106 and 108 of the Tax Code, except those falling under Section 3(A)(4) of RR No. 11-2025
• Registered Business Enterprises (RBEs) enjoying tax incentives under Section 304(D) of the Tax Code, except those falling under Section 3(A)(4) of RR 11-2025
• Businesses using Point-of-Sale (POS) systems.
• Other taxpayers that may be required by the Commissioner of Internal Revenue (CIR).

Once the BIR’s system is fully operational, these taxpayers will be required to submit sales reports through the Electronic Sales Reporting System (ESRS). The BIR said detailed guidelines will be issued in  separate revenue regulations and that further extensions may be granted if necessary to ensure smooth implementation.

What businesses should do now?

Despite the extended deadline, covered taxpayers’ businesses are encouraged to begin preparations early to avoid last-minute implementation challenges: 

• Reviewing current invoicing processes to identify gaps versus BIR structured e-invoicing requirements.
• Training personnel on issuing, transmitting, and storing electronic invoices.
• Establishing internal monitoring and documentation controls to ensure compliant electronic invoice issuance.
• Gradually implementing systems to avoid last-minute operational challenges.
  

Why does the extension matter?

The extended compliance period gives businesses more time to adapt, reduce errors, and integrate e-invoicing into existing accounting and operational systems. It also allows companies to manage the transition strategically, minimizing disruptions while ensuring readiness for full BIR compliance.

As the Philippines continues its move toward digital tax administration, RR No. 26-2025 signals a more measured and business-conscious approach — one that emphasizes preparedness over penalties. – Rappler.com

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