While the Philippines is implementing its e-invoicing obligations, the Bureau of Internal Revenue (BIR) has strengthened the regulatory framework through Revenue Memorandum Circular (RMC) No. 110-2026 [âïž], introducing a dedicated accreditation regime for Electronic Invoicing Service Providers (ESPs).
Under the mandate, businesses in scope must issue e-invoices containing structured data by December 31, 2026. Electronic sales reporting to the BIR will follow once the relevant implementing rules are issued.
Businesses may use their own invoicing system or an accredited ESP to meet these requirements, and in the latter case, ensure their is duly accredited by BIR.
Who is concerned?
According to the Circular, ESPs may not commercially deploy, activate or provide e-invoicing solutions and electronic sales reporting services to taxpayers unless their solution is accredited by the BIR and they hold a valid Electronic Invoicing Solutions Accreditation Certificate.
The requirement will likely also apply to foreign service providers, although this is not explicitly stated and some aspects still require clarification.
The Circular excludes internally developed systems and software licensed to a taxpayer and operated on its own infrastructure, provided they are used exclusively by that taxpayer and its registered branches. These systems remain subject to the existing Computerised Accounting System (CAS), Point-of-Sale (POS) or other applicable registration rules.
Application dates: immediate effect
The new accreditation requirements introduced by RMC No. 110-2026 are effective immediately.
Accordingly, the BIR has set an initial application window running only from October 16 to October 30, 2026. No subsequent application window has yet been announced for providers that miss this deadline or seek accreditation at a later date.
The obligations of accredited ESPs
Accredited ESPs must provide e-invoicing and sales-data services in compliance with BIR requirements, covering invoice generation, validation, storage, preservation, retrieval, transmission and audit support. Their key obligations of ESPs include:
- e-invoice compliance: Generate and preserve structured e-invoices compliant with BIR requirements.
- PTI registration and numbering: Facilitate PTI registration and updates, ensuring the taxpayer retains control and the PTI Electronic Invoice Number appears on invoices where required.
- Data transmission: Transmit e-invoices and sales data in real time or near real time, within three calendar days, ensuring secure retransmission after disruptions without data loss or duplication.
- Integration and testing: Manage required API integrations, certifications and pre-production testing, with the taxpayerâs written authorisation.
How to obtain accreditation
After determining whether activities and solutions fall within the scope of the obligation, applicants must appoint an authorised representative and maintain accountable technical, compliance, data protection and security officers in the Philippines. They must also submit the prescribed documentation and undergo several assessment stages:
- Documentary completeness review,
- Assessment of the applicantâs suitability and financial capacity,
- Review of system architecture and end-to-end data flows,
- Cybersecurity and data privacy assessments, including the required certifications,
- Live demonstration of the solution,
- Interoperability and end-to-end transmission testing,
- Load, stress, scalability, failover, backup and recovery testing.
An ESP may only deploy its solution in production once all mandatory accreditation stages have been successfully completed and compliance has been demonstrated under test conditions reasonably reflecting projected and peak production volumes.
Accreditation is solution-specific and valid for five years, subject to annual compliance reviews.
According to the BIR’s application announcement [âïž], applications must be submitted to the ESP Accreditation Board Secretariat at the BIR National Office in Quezon City, with no online submission option mentioned.
