BIR Extends Compliance Period for Electronic Invoicing — What Businesses Need to Know

The Bureau of Internal Revenue (BIR) has issued Revenue Regulations (RR) No. 26-2025, dated September 5, 2025, amending the transitory provisions of RR No. 11-2025. This latest issuance formally extends the compliance period for the implementation of electronic invoicing (EIS) until December 31, 2026.

Under RR No. 11-2025, taxpayers covered by Sections 237 and 237-A of the National Internal Revenue Code (NIRC), as amended by Republic Act No. 12066, were originally given one year from effectivity (around February 2026) to comply with electronic invoicing and reporting requirements. The new regulation provides businesses with an additional year to make the transition.

Key Amendments Under RR No. 26-2025

1. Extended Compliance Period

The deadline is extended to December 31, 2026 for covered taxpayers to comply with the electronic invoicing requirements under RR No. 11-2025.

2. Who Are Covered

The following taxpayers are required to issue electronic invoices and comply with the Electronic Sales Reporting System once their systems are ready:

1. Taxpayers engaged in e-commerce or internet transactions (Small, Medium, and Large; Micro taxpayers are exempted).

2. Taxpayers under the Large Taxpayers Service (LTS).

3. Large Taxpayers classified under RA No. 11976 (Ease of Paying Taxes Act).

4. Taxpayers using Computerized Accounting Systems (CAS) and Computerized Books of Accounts (CBA) with electronic invoicing features.

5. Those engaged in the export of goods and services under Sections 106 and 108 of the Tax Code.

6. Registered Business Enterprises (RBEs) availing of tax incentives under Section 304(D).

7. Taxpayers using POS systems and other invoicing software.

8. Other taxpayers as may be required by the BIR Commissioner.

3. BIR System Readiness

The regulation emphasizes that the e-invoicing mandate applies once a system capable of storing and transmitting structured data to the BIR is established. This ensures that both the taxpayer’s and BIR’s infrastructure are adequately prepared for a smooth transition.

4. Further Extension Possible

Section 3 of RR 26-2025 authorizes the Commissioner of Internal Revenue to further extend the transition or compliance period if deemed necessary.

Our Analysis and Commentary

A. Practical Implications for Businesses

• Time for System Reconfiguration: Businesses using CAS or POS systems should use this period to ensure that their software complies with BIR’s structured data requirements.

• Training and Transition: Accounting and finance teams must be trained on new electronic invoicing and reporting procedures.

• Vendor Coordination: Firms using third-party invoicing platforms should coordinate early to secure BIR accreditation and integration compatibility.

B. Legal and Compliance Perspective

From a compliance standpoint, RR 26-2025 does not change the scope of taxpayers covered under RR 11-2025. Instead, it focuses on allowing a more realistic adjustment timeline, recognizing operational and technical challenges in implementing electronic invoicing.

The inclusion of a “further extension clause” under Section 3 signals that the BIR is taking a phased, adaptive approach rather than enforcing abrupt compliance — a prudent move for both regulators and taxpayers.

C. Strategic Opportunity for Businesses

Forward-looking companies can use this period to:

• Automate accounting systems and improve internal controls.

• Integrate e-invoicing with ERP systems for seamless tax reporting.

• Prepare for real-time data submission, which could simplify audit compliance in the future.

Our Recommendation

We strongly advise all covered taxpayers to:

• Conduct a compliance audit of their current accounting and invoicing systems.

• Engage with BIR-accredited software providers for early adoption.

• Document their transition plan to demonstrate good faith compliance in case of future inspections.

Our firm offers advisory and implementation support for clients navigating e-invoicing requirements — from CAS accreditation, policy design, to data security compliance.

Conclusion

RR No. 26-2025 is more than just a deadline extension — it represents a critical step in the Philippines’ digital taxation evolution. Businesses that embrace this change early will not only comply with BIR requirements but also enhance operational efficiency and financial transparency.

📩 For assistance or consultation on how your company can transition to e-invoicing and comply with BIR regulations, contact our CPA-Law team at info@aureadalaw.com or visit our office.