BIR gives covered Philippine taxpayers until 31 December 2026 to issue electronic invoices

What changed in detail

Revenue Regulations No. 26-2025, issued on 16 October 2025, amends the transitory provisions of RR No. 11-2025, extending the compliance period for electronic invoice issuance by covered taxpayers “in consideration of the operational adjustments required of taxpayers, including reconfiguration and transition to electronic invoicing”.

Four groups have until 31 December 2026 to comply with the electronic invoicing requirements: taxpayers engaged in e-commerce or internet transactions classified as Small, Medium and Large (Micro Taxpayers are exempted); taxpayers under the jurisdiction of the Large Taxpayers Service; taxpayers classified as Large Taxpayers under RA No. 11976 (Ease of Paying Taxes Act) and RR No. 8-2024; and taxpayers using a Computerized Accounting System or Computerized Books of Accounts with accounting records and other invoicing software.

A further set — exporters under sections 106 and 108 of the Tax Code, Registered Business Enterprises with incentives under section 304(D), POS System users, and others the Commissioner requires — is not on that deadline. Those taxpayers become required to issue electronic invoices only once a system capable of storing and processing the data to be transmitted to the BIR is established, and then through separate Revenue Regulations. The same condition and a near-identical list govern the Electronic Sales Reporting System.

The regulations close by reserving to the Commissioner of Internal Revenue the power to further extend the deadlines or compliance period.

Note that the digest presents the amended clause as “SECTION 6. Transitory Provisions” while introducing it as an amendment to “Section 14-Transitory Provisions of RR No. 11-2025”.

What it means

The date to work back from is 31 December 2026, but only if you are in one of the four listed groups, and classification is the part people get wrong. “Large Taxpayer” here has two separate sources — LTS jurisdiction and the RA 11976 classification — and item 4 pulls in anyone running a CAS or CBA regardless of size. A mid-sized company with accounting software can be in scope while a larger one without it is not.

The unconditional deadline and the conditional one are easy to conflate. Exporters, incentive-holding RBEs and POS users have no date at all yet; theirs starts when the BIR’s receiving system exists and a new RR says so. Building a 2026 programme around a date that has not been set is the wasted-effort case here. And the Commissioner’s reserved extension power is a reason to track issuances rather than treat the date as fixed.