top of page
Search

BIR RMC No. 110-2026: Is Your E-Invoicing Provider Accredited?

Writer: Atty. Yasser R. Aureada, CPA
Atty. Yasser R. Aureada, CPA
1 hour ago
3 min read

BIR Revenue Memorandum Circular (RMC) No. 110-2026, issued October 12, 2026, requires e-invoicing service providers to get BIR accreditation before they can sell an e-invoicing solution in the Philippines. The rule is aimed at providers, not at taxpayers. But if your business will use a third-party provider to meet the December 31, 2026 e-invoicing deadline, ask now whether the provider applied for accreditation and what happens to your data if it is not approved.


What is RMC No. 110-2026?


It sets the BIR's accreditation rules for Electronic Invoicing Service Providers (ESPs). These are companies that offer e-invoicing platforms, software or services to taxpayers.


An ESP must hold a BIR Electronic Invoicing Solutions Accreditation Certificate before it offers its solution commercially. The accreditation covers a specific solution, including its version, modules and setup. The circular took effect immediately.


Does it add a new duty for taxpayers?


No.


It regulates providers. Your own duties stay the same: be able to issue electronic invoices by December 31, 2026 if you are covered, and get a Permit to Issue Electronic Invoice (PTI). See who must comply with e-invoicing and what a PTI is.


Systems used only inside one organization are outside the circular. If your group shares one in-house system across several companies, ask your tax adviser whether that still counts as internal use.


What must a provider pass?


The BIR reviews each applicant in stages:


  • complete documents, with named technical and compliance officers;


  • a fit-and-proper and financial capacity review;


  • a technical and data-flow review;


  • a data privacy and cybersecurity assessment, including security certifications, source code review and penetration testing;


  • a live demonstration;


  • interoperability and transmission testing; and


  • load and recovery testing.


The first application window ran from October 16 to October 30, 2026. The BIR said it would not accept later applications for that round.


How does the circular protect taxpayers?


  • Your data stays yours. Accredited providers must keep your e-invoices and sales data available to you and to the BIR.


  • No lock-in. Providers must support data portability and help you move if you switch providers.


  • Accountability. The BIR may suspend or revoke an accreditation for non-compliance, service failures or data breaches. A provider must still preserve data and support migration after that.


What should your business do before December 31, 2026?


  1. Ask your provider in writing whether it applied for accreditation in the October 2026 window and for which solution and version.


  2. Check your contract. Look for clauses on data ownership, data export, service levels, and what happens if the provider loses or fails to get accreditation.


  3. Keep a fallback. Know how you will issue compliant invoices if your provider cannot go live on time.


  4. Do not pay for promises. Until the BIR announces accredited providers, treat claims of "BIR-accredited e-invoicing" with care and ask for the certificate.


  5. Update invoice content. Systems under the e-invoicing mandate must also show creditable withholding tax on invoices by December 31, 2026. See how to show CWT on invoices.


Frequently asked questions


Are micro taxpayers covered by mandatory e-invoicing?


The BIR has said micro taxpayers are not covered by the mandate. See our e-invoicing guide for the categories.


Can I build my own e-invoicing system?


A system used only within your organization is outside RMC No. 110-2026. It must still meet the BIR's e-invoicing and registration rules.


Where can I see the list of accredited providers?


Wait for the BIR's announcement, and ask any provider for its accreditation certificate.


Sources




Facing a BIR audit, assessment or tax dispute?


Aureada CPA Law Firm's CPA-lawyers handle BIR audits, assessment protests, refund claims and Court of Tax Appeals cases from our Makati and Lucena offices. See our tax services.



You can also email info@aureadalaw.com or call (02) 8812-9990.


Related guides



This article is general information as of its publication date, not legal advice, and does not create a lawyer-client relationship. For advice on your situation, consult a lawyer.

Comments

bottom of page