BIR EIS rules under RMC No. 98-2026 explain PTI requirements, branch permits, downtime invoices, corrections, EIS Certification and later sales reporting.
RR No. 11-2025 established the electronic invoicing framework, including who may be covered and what an electronic invoice needs to do. RR No. 26-2025 then moved the compliance deadline for the first covered group to 31 December 2026.
The new circular (RMC No. 98-2026) goes a step further. It explains the Permit to Issue Electronic Invoice, how permits work for branches and different systems, what to do during downtime, EIS Certification and more. These are the changes this article focuses on.
| Area | What the circular explains |
| Permit to Issue | A covered taxpayer must secure a PTI before issuing electronic invoices. The permit identifies the approved system and its coverage. |
| Branches and systems | The circular explains how permits apply to the head office, branches, additional locations, and businesses using more than one invoicing system. |
| Downtime | A BIR-authorized manual invoice must be used when electronic issuance is not possible, followed by a replacement electronic invoice after service returns. |
| Corrections | An issued electronic invoice must not be deleted or changed. Adjustments require a separate document that refers to the original invoice. |
| Certification and reporting | EIS Certification is due within six months after the PTI. A Permit to Transmit applies only when the BIR later directs electronic sales reporting. |
The Permit to Issue (PTI) now has a clearer role
The circular states that an e-invoice must come from an appropriately registered or approved system, be issued electronically to the buyer, and have structured data that can be extracted for eventual BIR sales reporting. The taxpayer needs a Permit to Issue Electronic Invoice (PTI) before issuing.
The PTI is different from the Permit to Use (PTU) or Acknowledgement Certificate (AC) for CAS, which authorizes the use of such systems but does not by itself constitute authority to issue electronic invoices.
Invoices generated by a CAS, CBA with Accounting Records (with electronic invoicing), POS System, or other accounting/invoicing software or system, and subsequently printed on paper for issuance to buyers, shall not be considered electronic invoices ifthe system does not have the capability to electronically issue and transmit the invoice to the buyer and electronically transmit or report the required sales data to the BIR.
The circular also states that the BIR must evaluate the application and determine compliance within 20 working days after receiving the complete documentary requirements. Once approved, the PTI will identify the approved system and its coverage.
A change in the system’s identity, name, platform, or core details, including a migration, replacement, or adoption of another system, requires a new or amended PTI, as applicable.
Branches need to be part of the permit plan
The electronic invoicing requirement applies to the business as a whole, not only to the branch conducting the covered activity.
The head office and each branch must have a PTI. If they use the same approved invoicing system, their PTIs will carry the same PTI number.
If a branch uses a different invoicing system, the taxpayer must secure a separate PTI for that system.
A new branch using the same approved system does not need a new PTI number. However, the taxpayer must notify the BIR under the applicable rules and procedures.
Downtime does not pause the duty to issue an invoice
During downtime, the business must issue BIR-authorized manual invoices and replace them with corresponding electronic invoices after the system is restored. Each replacement electronic invoice must carry the reference number of the manual invoice.
As an operational control, the business should also track and reconcile the manual and electronic records so they are not treated as separate transactions.
If your electronic invoicing system goes down, you must still document every sale.
It means the business needs a complete process for handling invoicing outages:
- If the electronic invoicing system cannot be used, the business must issue a BIR-authorized manual invoice for each transaction.
- It must record and track every manual invoice issued during the outage.
- Once the system is restored, the business must create a corresponding electronic invoice for each manual invoice.
- The electronic invoice must include the reference number of the manual invoice it replaces.
- The business should reconcile the records so the manual and electronic invoices are not treated as two separate transactions.
Issued invoices cannot simply be edited
If an electronic invoice is wrong, the original must not be deleted, altered, or overwritten. The correction depends on what needs to change.
- If the invoiced amount must be reduced, issue a duly authorized credit note or credit memo that identifies the original electronic invoice.
- If the customer owes more, issue a new electronic invoice for the additional amount. It must also identify the original invoice.
The BIR is expected to issue more detailed rules for sales adjustments separately. Until then, businesses should make sure their systems preserve the original invoice and create a clear audit trail for every adjustment.
EIS Certification starts after the PTI
A Permit to Issue (PTI) Electronic Invoice is the BIR’s authority for a taxpayer to issue electronic invoices through its registered or approved invoicing system. A covered taxpayer must secure the PTI before generating or issuing electronic invoices.
After the PTI is issued, the taxpayer must obtain EIS Certification within six months. This certification checks whether the system can extract, process, and transmit sales data according to BIR technical standards. Failure to obtain certification within that period is a ground for revoking the PTI.
A Permit to Transmit (PTT) applies to electronic sales reporting, which is separate from electronic invoicing. It becomes required only when the Commissioner notifies or directs the taxpayer to comply with electronic sales reporting requirements.
Therefore, obtaining EIS Certification does not by itself mean that the taxpayer must already begin transmitting sales data to the BIR.
Classification changes do not always switch the rule off
Once a taxpayer is required to use electronic invoicing, moving to a lower taxpayer category does not automatically end that requirement. The circular says the taxpayer continues with electronic invoicing unless the BIR expressly reclassifies or exempts it through another issuance.
A taxpayer moving to a higher category must comply with the requirements for the new classification within the period set by the BIR. The circular says that period must be at least six months from the date of reclassification.
Where Taxumo may help
Taxumo can help guide clients through the PTI application process.
If a business already uses a CAS or ERP for its accounting but will generate and issue its electronic invoices through Taxumo, the PTI application should identify Taxumo as the electronic invoicing software/system used for that purpose.
💡 No accreditation is currently issued to any e-invoicing system providers. However, Taxumo is EIS-ready. Any applicable accreditation for e-invoicing is handled through a separate process.
The existing CAS or ERP’s own BIR registration (PTU or Acknowledgement Certificate) is a separate matter and is not affected by this.
What businesses should prepare now
1. Confirm whether your business is in the covered group under RR Nos. 11-2025 and 26-2025. Ask a qualified tax professional to review your classification, registration, systems, and branches.
2. Set up a consultation meeting with Taxumo and see what possible next steps will you need to take to ensure that you comply with this BIR ruling. Set up a meeting by emailing einvoice@taxumo.com.
The bottom line
RMC No. 98-2026 is about making the existing rules workable.
For businesses preparing for the 31 December 2026 deadline, the next step is no longer simply choosing software. It is identifying a process that can obtain the right permit, keep operating during an outage, preserve every issued invoice, and stay ready for later BIR sales-reporting instructions.
This article is based on Revenue Memorandum Circular No. 98-2026. It is for general information only and should not be treated as legal or tax advice. For advice specific to your business, please consult a CPA, tax professional, or legal adviser.
Under RMC No. 98-2026, taxpayers covered by Section III, except those classified as Micro taxpayers, must issue electronic invoices on or before 31 December 2026. The BIR EIS Certification deadline is separate: covered taxpayers must obtain certification within six months after the PTI is issued.
BIR Electronic Invoicing and Sales Reporting (EIS) Certification tests whether a taxpayer’s electronic invoicing system can extract, process, and transmit sales data in accordance with BIR technical standards. Failure to obtain EIS Certification within six months after PTI issuance is a ground for revoking the PTI.
No. A Permit to Issue Electronic Invoice is the BIR’s authority for a taxpayer to issue electronic invoices through the approved system. It must be secured before the taxpayer generates or issues electronic invoices. BIR EIS Certification is a subsequent technical validation that must be completed within six months after the PTI is issued.
No. Electronic invoicing and electronic sales reporting are separate obligations. A Permit to Transmit applies only when the Commissioner notifies or directs the taxpayer to comply with electronic sales reporting. Obtaining BIR EIS Certification does not by itself activate the sales-reporting requirement.
The head office and each separate branch must receive a PTI. When they use the same approved invoicing system, the permits carry the same PTI number. A separate PTI is required for each distinct invoicing system. A new branch using the same approved system does not require a new PTI number, provided the taxpayer properly notifies the BIR.