Covered taxpayers must be ready to issue compliant electronic invoices on or before December 31, 2026.
The BIR has prescribed processing periods for some steps, but a company’s internal review may take longer.
Finance teams should allow time for tax, accounting, IT, information security, data privacy, legal, procurement, vendor, and branch approvals where these apply.
💡 First, confirm your AC or PTU status, then secure a PTI before issuing electronic invoices. Next, obtain EIS Certification within six months of PTI issuance, and apply for a PTT only after the BIR issues a directive requiring electronic sales reporting.
How much time do you have left?
until the December 31, 2026 eInvoice deadline
…
Is your system ready for eInvoicing?Check your EIS readiness with Taxumo before the clock runs out.
Check EIS readinessBest-case estimate, assuming complete documents reach your RDO on your start date and AC then PTI are filed in sequence. The AC replaces the PTU for CAS and CBA. Working days exclude weekends and holidays (Nov 2, Nov 30, Dec 8, Dec 24, Dec 25, Dec 30, Dec 31). Actual BIR processing may vary.
Why the eInvoice Requirement is needed
The requirement implements Sections 237 and 237-A of the Tax Code, as amended by Republic Act No. 12066.
In practical terms, the law requires covered taxpayers to issue electronic invoices and, once the BIR’s electronic sales reporting system is established, electronically report their sales data to the BIR in accordance with applicable rules and regulations.
Subsequent Revenue Regulations and Revenue Memorandum Circulars then provided the detailed rules, coverage, procedures, and system requirements for implementing these provisions:
| Requirement | When it applies | What it authorizes or confirms | Timing and source |
| AC or PTU | Where the taxpayer uses a system subject to registration | Used to cofirm eInvoicing system registration | AC within 3 working days after complete documents are received (RMC No. 5-2021 and RMO No. 9-2021) |
| PTI | Before generating or issuing electronic invoices | Issuance through the approved electronic invoicing system | BIR evaluation within 20 working days after complete documents are received (RMC No. 98-2026) |
| EIS Certification | After the PTI is issued | System capability to extract, process, and transmit sales data | Within six months from PTI issuance (RMC No. 98-2026) |
| PTT | Only after a BIR notification or directive on electronic sales reporting | Transmission of required sales data to the BIR | No current general filing deadline under the circular (upon new implementation) |
Allow for internal finance team vetting
The BIR’s three-working-day AC period and 20-working-day PTI evaluation period start only after complete documents are received. These periods do not include the company’s own approval process. Internal vetting may vary.
Finance should map the eInvoicing system and its requirements needed. Typical reviews may involve invoice fields, tax treatment, system controls, cybersecurity and more. Not every company will need every review, but the internal path should be documented.
First confirm the AC or legacy PTU status
For an already registered CAS or CBA, a major system enhancement or upgrade that affects its financial functions requires the taxpayer to update or submit a new registration for the enhanced system. Under RMC No. 5-2021 and RMO No. 9-2021, a new AC is issued following registration of the updated system.
For EIS compliance, this CAS/CBA registration should be distinguished from the separate requirements for electronic invoice transmission to the BIR. RR No. 11-2025 requires covered CAS, CBA with electronic invoicing, and other invoicing software to be capable of generating structured invoice data that can be electronically transmitted to the BIR.
Secure the PTI before issuing eInvoices
Every covered taxpayer must secure a Permit to Issue Electronic Invoice before generating or issuing electronic invoices.
The BIR has 20 working days from receipt of complete documents to evaluate the application and determine compliance. It is also an evaluation period, not a promise that every application will be approved at the end of that period.
Apply the PTI correctly across branches
Compliance applies to the taxpayer as a whole. The Head Office and every branch must be covered, even when the activity that triggered the eInvoice Requirement takes place at only one branch. The Head Office and branches use the same PTI number, with the relevant branch identified. A taxpayer using different invoicing systems across branches or business segments must secure a separate PTI for each distinct system.
An additional branch using the same approved system does not require a new PTI number, but the taxpayer must notify the BIR under existing procedures. Moving to a different platform or replacing the core system requires a new or amended PTI, as applicable.
Complete EIS Certification within six months
The date the PTI is issued starts the next clock. The taxpayer must secure Electronic Invoicing and Sales Reporting Certification within six months from that date. EIS Certification tests whether the approved system can electronically extract, process, and transmit sales data in accordance with BIR technical standards.
Failure to secure EIS Certification within the six-month period is a ground for revocation of the PTI.
Wait for implementation before securing the PTT
Electronic invoice issuance and electronic sales reporting are separate obligations. A system must be capable of supporting the required data extraction and later transmission, but taxpayers will be required to transmit sales data only after the BIR issues the implementing policies, guidelines, and procedures for electronic sales reporting.
Documents and evidence to control
- Current system registration and AC records, or the valid legacy PTU where applicable.
- The PTI application, complete supporting documents, filing evidence, and BIR correspondence.
- The approved PTI for the Head Office, branches, and each distinct invoicing system.
- The PTI issuance date and calculated six-month EIS Certification due date.
- EIS Certification test records and the issued certification.
- Any later BIR issuance that activates the PTT and electronic sales reporting requirements.
Frequently asked questions
Who is covered by the eInvoice requirement?
Small, Medium, and Large taxpayers in e-commerce, taxpayers under the Large Taxpayers Service, Large taxpayers under EOPT, and users of CAS, CBA, or other invoicing software. Micro taxpayers are exempt but may adopt eInvoicing voluntarily.
What is the deadline for the eInvoice requirement?
Covered taxpayers, excluding Micro, must issue compliant electronic invoices by December 31, 2026.
Does an AC or PTU allow us to issue eInvoices?
No. The AC or PTU only covers your registered accounting system. You need a PTI before issuing eInvoices, and the BIR has 20 working days to evaluate a complete application.
When is EIS Certification due?
Within six months from PTI issuance. Missing it is a ground for revocation of the PTI.
Do we need a PTT by December 31, 2026?
No. The PTT applies only once the Commissioner directs you to start electronic sales reporting.