Electronic Invoicing Philippines: What Businesses Need to Know About RMC 98-2026
- QNE Software Philippines
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The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 98-2026, prescribing the policies and guidelines for the issuance of electronic invoices under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as amended by RR No. 26-2025.
Issued on September 22, 2026, the circular provides businesses with clearer guidelines on who must issue electronic invoices, what qualifies as an electronic invoice, how invoice data should be structured, and what taxpayers need to prepare before issuing electronic invoices.
For covered taxpayers, the deadline to comply is December 31, 2026.
With the transition to electronic invoicing underway, businesses should take the time to review their current invoicing and accounting processes and determine whether their existing system is ready for the requirements.
What Is BIR RMC No. 98-2026?
RMC No. 98-2026 sets the policies and guidelines for electronic invoicing pursuant to Section 237 of the National Internal Revenue Code, as implemented by the applicable revenue regulations.
The circular defines electronic invoicing as an automated process of generating an electronic invoice using structured invoice data that can be electronically extracted and processed. The electronic invoice records a transaction between a seller and buyer and may be electronically transmitted to the buyer.
This means electronic invoicing is more than simply creating a digital copy of a paper invoice.
The system must be capable of generating the invoice in a structured format, transmitting it electronically, and making the required invoice information available for electronic processing and reporting.
Who Are Covered by the Electronic Invoicing Requirements?
Under RMC No. 98-2026, the electronic invoicing requirements apply to the following taxpayers:
- Small, Medium, and Large Taxpayers engaged in e-commerce or internet transactions, excluding Micro Taxpayers;
- Taxpayers under the jurisdiction of the Large Taxpayers Service;
- Taxpayers classified as Large Taxpayers under the Ease of Paying Taxes Act and applicable regulations;
- Taxpayers using a Computerized Accounting System (CAS), Computerized Books of Accounts (CBA) with Accounting Records with electronic invoicing, or other invoicing software; and
- Other taxpayers who may subsequently be required by the Commissioner of Internal Revenue.
Covered taxpayers, except those classified as Micro Taxpayers, are required to issue electronic invoices and comply with the circular on or before December 31, 2026.
Taxpayers who are not currently covered may also voluntarily adopt electronic invoicing, subject to the applicable requirements, including securing a Permit to Issue (PTI) Electronic Invoice.
Is Your Business Covered by the New E-Invoicing Requirements?
Find out what your business needs to prepare before the December 31, 2026 deadline and see how N3 AI Accounting can support your transition.
Electronic Invoicing Philippines Is Different From Electronic Sales Reporting
One important clarification in the circular is that electronic invoicing and electronic sales reporting are separate requirements.
The obligation to issue electronic invoices under Section 237 of the Tax Code is separate from the electronic sales reporting requirements under Section 237-A.
For the taxpayers covered by RMC No. 98-2026, electronic sales reporting will become mandatory only when the BIR issues the corresponding implementing policies, guidelines, and procedures for that requirement.
This distinction is important for businesses preparing their systems because electronic invoice issuance and future electronic sales reporting may involve related but separate compliance steps.
What Makes an Invoice an Electronic Invoice?
Not every digitally created invoice qualifies as an electronic invoice under RMC No. 98-2026.
The circular provides that an invoice is considered an electronic invoice only when it satisfies the prescribed requirements.
1. Generated by an Appropriate Accounting or Invoicing System
The invoice must be generated by a duly registered, approved, or accredited accounting or invoicing software or system in a structured electronic format.
2. Electronically Generated and Transmitted
The invoice must be electronically generated and transmitted to the buyer, purchaser, or client.
The circular recognizes electronic channels such as: Email, Online viewing, QR codes, Mobile applications, Web-based platforms or Other electronic means.
3. Invoice Data Must Be Electronically Extractable
The invoice data must be capable of being electronically extracted, processed, and transmitted to the BIR for electronic sales reporting purposes.
This requirement highlights why businesses should evaluate the accounting system behind their invoices—not just the appearance of the invoice itself.
Can Businesses Simply Use Word or Excel?
No. RMC No. 98-2026 specifically states that invoices manually created using office productivity applications such as Microsoft Word, Microsoft Excel, Google Docs, Google Sheets, or similar applications are not considered valid electronic invoices for tax compliance purposes.
Similarly, an invoice generated by an accounting system and then printed on paper is not considered an electronic invoice if the system does not have the capability to electronically issue and transmit the invoice and electronically transmit or report the required sales data to the BIR.
For businesses still relying heavily on spreadsheets or manually prepared invoices, this is an important point to consider when reviewing their current accounting setup.
Is Your Business Ready for the
New Electronic Invoicing Requirements?
The December 31, 2026 deadline is getting closer, and understanding the requirements is only the first step.
Your next step is making sure your accounting system can support the transition.
Keep reading to understand what
RMC No. 98-2026 means for your business, then talk to our team about how N3 AI Accounting can help you prepare.
What About Existing Accounting Systems?
Businesses using CAS, CBA, POS, or other computerized systems should review whether their current setup can actually support electronic invoicing.
It is also important to distinguish the Permit to Issue (PTI) Electronic Invoice from the Permit to Use (PTU) or Acknowledgement Certificate (AC) for CAS. Under RMC No. 98-2026, a PTU or AC authorizes the use of a computerized accounting system but does not by itself authorize the taxpayer to issue electronic invoices. The PTI Electronic Invoice is the authority granted by the BIR to issue electronic invoices through a duly registered and/or approved invoicing system.
The BIR also explains that a system-generated invoice printed on paper does not automatically qualify as an electronic invoice if the system cannot electronically issue and transmit the invoice and required sales data.
The circular requires invoice information to be maintained in a structured, machine-readable format. For the BIR’s Electronic Invoicing System (EIS), JSON is used as the required structured format, while other internal formats may be used provided they can be converted into the required format.
This means businesses should look beyond simply having accounting software or an existing CAS approval. The system should also be capable of supporting the electronic flow of invoice data and the applicable BIR electronic invoicing requirements.
Electronic Invoices Cannot Simply Be Edited or Deleted
RMC No. 98-2026 also provides rules for correcting electronic invoices.
Once an electronic invoice has been issued, it cannot simply be deleted, altered, or modified. If the original invoice needs to be decreased, an authorized Credit Note or Credit Memo should be issued with reference to the original invoice. If an amount needs to be increased, a new electronic invoice should be issued.
For businesses, this makes proper invoice and accounting workflows especially important when handling returns, adjustments, discounts, and other changes after an invoice has been issued.
What Businesses Should Prepare
Before the December 31, 2026 deadline, covered taxpayers should review their current invoicing and accounting processes.
A practical preparation checklist includes:
- Determine whether your business is covered by the electronic invoicing Philippines requirement.
- Review whether your current accounting or invoicing system can generate structured electronic invoices.
- Check whether invoice data can be electronically extracted, processed, and transmitted.
- Review your process for invoice corrections, credit notes, and adjustments.
- Determine the applicable BIR registration, approval, or certification requirements for your system.
- Coordinate with your accounting or technology provider regarding implementation.
Covered taxpayers must secure the applicable Permit to Issue (PTI) Electronic Invoice before issuing electronic invoices. The BIR will evaluate the application after complete requirements have been submitted.
The circular also states that covered taxpayers must obtain EIS Certification validating their system’s capability to extract, process, and transmit sales data.
How N3 AI Accounting Can Help?
For businesses preparing for electronic invoicing, the accounting system becomes an important part of the compliance workflow.
N3 AI Accounting can help by bringing bookkeeping, invoicing, document capture, reconciliation, BIR reports, dashboards, and AI-assisted analysis into a cloud platform designed for the Philippine market. For accountants and bookkeepers, it can reduce repetitive work and support multi-client service. For SMEs, it can provide more organized records and faster visibility into cash flow. For larger and growing businesses, it can support standardization across users, branches, and operations.
N3 can support businesses in several areas relevant to the new electronic invoicing Philippines environment:
Electronic Invoicing
N3 includes e-Invoicing capabilities designed to support the electronic generation and handling of invoice data within the accounting workflow.
Sales and Credit Note Management
Businesses can manage sales transactions and related credit notes within the accounting system, supporting a more structured process for recording invoice adjustments.
BIR Reporting and Tax Tracking
N3 includes BIR reports and supports VAT and withholding tax tracking, helping businesses maintain accounting information needed for their tax reporting processes.
AI-Powered Document Processing
N3's AI QuickScan can extract information from business documents such as invoices, receipts, and PDFs and convert the information into accounting transactions. This can help reduce repetitive manual data entry when processing accounting documents.
Financial Visibility with Quinny AI
Quinny AI provides users with financial insights through natural-language interactions with their accounting data. This can help business owners and finance teams review financial information without relying entirely on manually prepared reports.The goal is not simply to issue invoices electronically, but to have a connected accounting workflow where sales, invoices, tax information, adjustments, and financial records can be managed in one system.
Why Choose N3 AI Accounting for Your Electronic Invoicing Needs?
Electronic invoicing Philippines introduces new requirements around how businesses create, process, and maintain invoice data.
Choosing an accounting platform that is built around Philippine accounting and tax requirements can help businesses prepare their workflows for this transition.
N3 AI Accounting combines accounting, BIR-related reporting, e-Invoicing capabilities, and AI-powered automation in a cloud-based platform for Philippine businesses.
For businesses evaluating their accounting setup ahead of the December 31, 2026 electronic invoicing deadline, this is an opportunity to review not only how invoices are issued, but also how invoice data flows through the entire accounting process.
Prepare Your Business for Electronic Invoicing Philippines with N3 AI Accounting
RMC No. 98-2026 makes one thing clear: electronic invoicing Philippines is more than converting a paper invoice into a digital file.
Businesses covered by the requirement need an invoicing or accounting system capable of generating structured electronic invoice data and supporting the required electronic processes.
N3 AI Accounting by QNE Software is an AI-enabled accounting software for Philippine businesses. Its capabilities include bookkeeping automation, QuickScan document capture, bank reconciliation, BIR reports, electronic invoicing workflows, real-time dashboards, multi-user access, and Quinny AI financial analysis.
Start reviewing your current invoicing workflow today and see how N3 AI Accounting can support your business as electronic invoicing becomes part of the new accounting environment.
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N3 AI Accounting
Frequently Asked Questions (FAQs)
What is BIR RMC No. 98-2026?
RMC No. 98-2026 provides policies and guidelines on the issuance of electronic invoices under the BIR’s existing electronic invoicing Philippines regulations.
Who is required to issue electronic invoices?
Covered taxpayers include taxpayers engaged in e-commerce or internet transactions, Small, Medium, and Large Taxpayers except Micro Taxpayers, Large Taxpayers, certain taxpayers using computerized accounting or invoicing systems, and other taxpayers who may be required by the Commissioner of Internal Revenue.
When is the deadline for issuing electronic invoices?
Covered taxpayers, except Micro Taxpayers, are required to issue electronic invoices by December 31, 2026.
Is an invoice created in Excel or Word considered an electronic invoice?
No. RMC No. 98-2026 states that invoices manually created using applications such as Word, Excel, Google Docs, or Google Sheets are not considered valid electronic invoices for tax compliance.
Does printing an invoice from an accounting system make it an electronic invoice?
Not necessarily. A system-generated invoice printed on paper does not qualify as an electronic invoice if the system cannot electronically issue and transmit the invoice and required sales data.
What is structured invoice data?
Structured invoice data is information arranged in a standardized digital format that computers can automatically read, process, store, and transmit. The BIR’s EIS uses JSON as its structured format.
Can an electronic invoice be edited or deleted after it is issued?
No. Once issued, an electronic invoice cannot simply be deleted, altered, or modified. Corrections that decrease the original amount should be handled through an authorized Credit Note or Credit Memo, while an increase requires the issuance of a new electronic invoice.
Do businesses need a special BIR permit for electronic invoicing Philippines?
Covered taxpayers must secure the applicable Permit to Issue (PTI) Electronic Invoice before issuing electronic invoices. The circular also provides for EIS Certification to validate the system’s capability to extract, process, and transmit sales data.
Can businesses voluntarily adopt electronic invoicing even if they are not yet required to?
Yes. RMC No. 98-2026 allows taxpayers who are not mandated to adopt electronic invoicing to voluntarily implement it, subject to the applicable BIR requirements.
Can N3 AI Accounting support electronic invoicing?
Yes. N3 AI Accounting is EIS-ready and equipped with e-Invoicing capabilities to support Electronic Sales Reporting System requirements. N3 also provides accounting, BIR reporting, sales, and credit/debit note functions within the system.
Does electronic invoicing mean businesses no longer need to keep accounting records?
No. Electronic invoicing Philippines is part of the invoicing and tax compliance process and does not remove a business’s other accounting and recordkeeping obligations.
What should businesses do before December 31, 2026?
Businesses should first determine whether they are covered by the requirement, then review their current accounting or invoicing system, electronic invoice capabilities, structured data handling, BIR registration or certification requirements, and processes for invoice corrections and adjustments.
The Deadline Is Approaching.
Start Preparing with N3 AI Accounting.
With the December 31, 2026 deadline approaching, now is the time to make sure
your business is ready for the electronic invoicing requirements under RMC No. 98-2026.
N3 AI Accounting brings accounting and electronic invoicing capabilities together
in one AI-powered platform, helping you
business move toward a more connected and efficient invoicing workflow. Don’t wait until the deadline is near. Start preparing your business today.