RMC 98-2026 Explained: Electronic Invoice Issuance vs. Sales Reporting

Preparing for electronic invoicing involves two audiences: the customer who needs an invoice and the Bureau of Internal Revenue (BIR), which requires sales data under its reporting framework. Understanding which information goes to each recipient helps businesses plan their systems and compliance work.

RMC 98-2026 separates electronic invoice issuance from electronic sales reporting. It also explains what makes an electronic invoice compliant and introduces requirements that businesses should consider alongside their software implementation. This guide explains that distinction and suggests practical questions for your finance and technology teams.

Who is covered, and what is the deadline?

The issuance deadline established under RR 26-2025 is 31 December 2026 for its specified taxpayer groups:

• Small, medium, and large taxpayers engaged in e-commerce or internet transactions; micro taxpayers are exempted.
• Taxpayers under the Large Taxpayers Service.
• Taxpayers classified as large under the Ease of Paying Taxes framework.
• Taxpayers using computerized accounting systems (CAS), computerized books of accounts with accounting records and electronic invoicing, and other invoicing software.

RR 26-2025 separately addresses categories such as POS users under provisions requiring subsequent implementation. Owning a POS system alone should therefore not be treated as proof that every business has the same deadline. A business may nevertheless fall within a covered category for another reason. Source: BIR RR 26-2025, Section 2.

Confirm your taxpayer classification, business activities, and registered systems before deciding which obligations apply.

Issuance goes to the buyer; reporting goes to the BIR

	Electronic invoice issuance	Electronic sales reporting
Recipient	Buyer or customer	BIR
Purpose	Provide the transaction invoice	Submit required sales data
Information	A buyer-readable invoice supported by structured, electronically extractable data	Machine-readable data in the BIR-prescribed format
Timing	Applicable issuance requirements and deadline	Applicable BIR implementing policies and directives

Issuance includes electronic delivery through channels such as email, online viewing, or QR codes. The customer-facing version can be human-readable, but issuance itself still requires structured invoice data. A manually prepared Word or Excel invoice does not qualify simply because it is emailed. Compliant electronic invoices may also be printed under the circular’s conditions.

Sales reporting is a separate transmission to the BIR. The circular identifies JSON as the existing EIS transmission format, while allowing other internal structured formats that can be converted as required. Reporting obligations follow the applicable implementing rules; “when the infrastructure is ready” is not, by itself, the regulatory trigger. Source: RMC 98-2026, IV.2 and IV.4–7.

For implementation planning, ask your provider to demonstrate both outputs from the same sample transaction: what the customer receives and what your system can extract for reporting. This makes the distinction tangible and helps reveal missing fields or manual work between systems.

PTI, EIS certification, and PTT serve different purposes

• PTI: Obtain authority before issuing electronic invoices. A CAS PTU or Acknowledgement Certificate does not replace it.
• EIS certification: Complete within six months of PTI issuance; failure can lead to PTI revocation.
• PTT: Required upon the Commissioner’s notification or directive for electronic sales reporting.

Source: RMC 98-2026, II.7, IV.12 and IV.15.

Create separate work items for permits, system testing, and reporting readiness. Assign an owner to each, record dependencies, and confirm application procedures with the relevant BIR office. Treat purchasing software and obtaining taxpayer authorization as separate project activities.

Include branches, corrections, and downtime in your plan

The circular covers head-office and branch compliance, distinct-system PTIs, corrections through referencing documents instead of changing issued invoices, and authorized manual fallback invoices followed by electronic replacements after recovery. Source: RMC 98-2026, IV.8 and IV.10–13.

Turn those requirements into test scenarios. For example, ask your team to walk through a returned item, an incorrect amount, a lost internet connection, and a branch using different software. Record who handles each situation and how finance reconciles the resulting records. A demonstration of a successful sale alone will not reveal these operational gaps.

A practical readiness checklist

The following are implementation recommendations to help organize your project:

1. Map your current workflow. List sales channels, invoicing applications, branches, and the people responsible for each. Identify where staff re-enter transaction information.
2. Request a realistic demonstration. Use a sample sale representative of your business. Review the customer’s experience and the corresponding structured data together.
3. Review integration choices. Ask which parts of your existing workflow can remain, which need changes, and what evidence supports the proposed approach. Compare ongoing support and maintenance responsibilities as well as initial cost.
4. Create an authorization and testing schedule. Track application preparation, technical work, staff training, and unresolved questions separately. Avoid planning the entire project around a single software installation date.
5. Rehearse exceptions. Include returns, adjustments, duplicate submissions, outages, and recovery in acceptance testing. Agree on how discrepancies will be investigated before launch.
6. Maintain a decision record. Keep the guidance consulted, questions raised with your BIR office, provider responses, and test results together so the team can revisit decisions when guidance changes.

Read RMC 98-2026 alongside later guidance

RMC 98-2026 should not be read in isolation. BIR subsequently issued RMC 110-2026, addressing accreditation and technical, operational, security, data-governance, and continuing-compliance requirements for ESP electronic invoicing solutions. Source: BIR RMC 110-2026.

When evaluating a provider, request evidence relevant to its proposed solution and clarify which responsibilities remain with your business. Keep provider-related approvals and taxpayer permits as separate items in your review.

Discuss your invoicing workflow with Third Channel

Bring a sample invoice, a list of your sales systems, and a description of your branch operations. These provide a useful starting point for discussing integration needs and implementation questions.

Contact Third Channel to discuss your electronic invoicing workflow.