BIR Electronic Invoicing System (EIS): Deadline, EIS Certification and Permit to Transmit
Updated: 2 days ago
Short answer: The Electronic Invoicing System (EIS) is the BIR platform that receives invoice and sales data directly from taxpayers' systems. Covered businesses must issue e-invoices on or before December 31, 2026 (RMC No. 98-2026). Sending sales data to the EIS is a separate duty that starts only after the BIR issues the sales reporting rules, and the Permit to Transmit (PTT) applies only when the Commissioner requires it. For now, you need a Permit to Issue (PTI) Electronic Invoice before your first e-invoice and an EIS Certification within six months after the PTI.
What the EIS is
The EIS, formally the Electronic Invoicing/Receipting and Sales Reporting System, lets the BIR receive sales data system to system, without manual encoding (RR Nos. 8-2022 and 11-2025). It supports two separate duties:
E-invoicing: issuing invoices from a compliant system, in a structured format, and delivering them to buyers electronically (Section 237, NIRC; RMC No. 98-2026).
Electronic sales reporting: sending the sales data to the BIR through the EIS (Section 237-A, NIRC).
The EIS accepts encrypted sales data in JSON, a common structured data format (RR No. 8-2022). Your system may use another format internally if it can convert the required data to JSON (RMC No. 98-2026).
How the law developed
TRAIN law (RA No. 10963) directed the BIR to require exporters, e-commerce businesses and Large Taxpayers Service taxpayers to issue electronic receipts or invoices within five years, once its system could store and process the data. It also added Section 237-A and a penalty for not transmitting sales data (Section 264-A, NIRC).
EOPT Act (RA No. 11976) made the invoice the required document for sales of both goods and services, and classified taxpayers as micro, small, medium or large (Sections 21(b) and 237, NIRC).
CREATE MORE Act (RA No. 12066) removed the five-year window and added an extra deduction for setting up an electronic sales reporting system (Sections 237 and 237-A, NIRC).
RR No. 11-2025 implemented CREATE MORE and widened coverage. RR No. 26-2025 moved the deadline from March 14, 2026 to December 31, 2026.
What is mandatory now
By December 31, 2026, covered taxpayers must issue e-invoices. They are e-commerce taxpayers (except micro taxpayers), taxpayers under the Large Taxpayers Service, large taxpayers under the EOPT Act, users of a computerized accounting system (CAS) or other invoicing software, and others the Commissioner may require (RMC No. 98-2026). Our RMC No. 98-2026 e-invoicing guide covers branches, what counts as an e-invoice, and system downtime.
Exporters, registered business enterprises with tax incentives, and point-of-sale (POS) users outside those groups come later, once the BIR's system is ready and separate rules are issued (RR No. 11-2025, as amended by RR No. 26-2025).
What comes later: sales data transmission and the PTT
Electronic sales reporting applies only after the BIR issues implementing rules, and a PTT is needed only upon the Commissioner's notice or directive (RMC No. 98-2026).
RR No. 8-2022 shows what to expect: reporting starts with sales made on the day after the PTT is issued, in real time or near real time, and within three calendar days from the sale. The new rules may change these terms.
Once transmission is required, missing it is costly. The penalty for each day of violation is ₱10,000 or one-tenth of 1% of annual net income (per the audited financial statements of the second preceding year), whichever is higher. Permanent closure is added if violations exceed 180 days in a taxable year. Failures due to force majeure or causes beyond the taxpayer's control are excused (Section 264-A, NIRC).
The sequence: PTI, EIS Certification, PTT
PTI Electronic Invoice. File with your Revenue District Office (RDO) or Large Taxpayer office before your first e-invoice. The BIR evaluates a complete application within 20 working days. See What is a PTI Electronic Invoice?
EIS Certification. This online test checks whether your system can extract, process and transmit sales data to BIR standards. It has five mandatory tests, or seven if you use an API callback (automatic replies from the BIR's system to yours). Secure it within six months from the PTI, or the PTI may be revoked (RMC No. 98-2026).
Permit to Transmit. Apply when the Commissioner requires it. From then on, your system sends sales data to the EIS.
Incentives: what the law actually gives
Additional deduction. Taxpayers that issue e-invoices and report sales data electronically, including voluntary adopters, may deduct an extra 100% (micro and small taxpayers) or 50% (medium and large taxpayers) of the total cost of setting up an electronic sales reporting system. It is on top of the regular business-expense deduction and may be claimed only once (Section 237-A, NIRC), in the year the system is completed or final payment is made (RR No. 11-2025).
Tax-exempt importation. Importing such a system is exempt from taxes (Section 237-A, NIRC).
Summary List of Sales. EIS users need not submit it, but must still submit the Summary List of Purchases and Importations (RR No. 8-2022). Keep filing until you actually transmit through the EIS.
Common misconceptions
"The deadline is March 14, 2026." It is now December 31, 2026 (RR No. 26-2025).
"Only invoices reported to the EIS support input VAT or deductions." Neither the Tax Code nor RMC No. 98-2026 says this. Input VAT needs a VAT invoice issued under Section 113 (Section 110(A)(1), NIRC). A compliant e-invoice, sent electronically or printed, is valid proof for substantiating deductions (Section 34(A)(1)(b), NIRC; RMC No. 98-2026).
"We must already transmit within three days." That RR No. 8-2022 period runs only after a PTT is issued, and a PTT is needed only when the Commissioner requires it (RMC No. 98-2026). If you already transmit under an earlier PTT, confirm your status with the BIR.
"Keep records for ten years, the first five in hard copy." Since the EOPT Act, the period is five years from the day after the filing deadline (or the actual filing date, if late) for the year of the last entry (Section 235, NIRC). Manual and loose-leaf books are kept in hard copy; computerized books are kept electronically (RR No. 7-2024).
"An accredited provider makes us compliant." You still need your own PTI and EIS Certification (RMC No. 98-2026). Providers must be BIR-accredited before offering solutions commercially; in-house systems used by a single taxpayer are excluded (RMC No. 110-2026).
What to prepare now
Confirm coverage for the head office and all branches.
Ask your software provider, in writing, whether the system produces the BIR's JSON data and can pass the certification tests.
File the PTI early, allowing at least 20 working days.
Schedule EIS Certification soon after the PTI, with time to fix failed tests.
Build and test the transmission link now, so you are ready when a PTT is required.
If you use a provider, check its accreditation and secure written access to your own data.
Keep contracts and invoices for setup costs to support the additional deduction.
Frequently asked questions
Do we need a Permit to Transmit by December 31, 2026?
No, unless the Commissioner notifies you. The deadline is for issuing e-invoices, which requires a PTI (RMC No. 98-2026).
Must EIS Certification be done by December 31, 2026?
Not necessarily. The deadline is six months from the date your PTI was issued.
Will the deadline move again?
RR No. 26-2025 lets the Commissioner extend it, but RMC No. 98-2026 kept December 31, 2026. Plan for that date.
Are micro taxpayers covered?
No. Micro taxpayers, those with gross sales below ₱3 million (Section 21(b), NIRC), are exempt, but may adopt e-invoicing voluntarily after securing a PTI (RMC No. 98-2026).
Sources
National Internal Revenue Code of 1997, as amended: Sections 21(b), 34(A)(1)(b), 110(A)(1), 235, 237, 237-A and 264-A
Republic Act No. 10963 (TRAIN Law)
Republic Act No. 11976 (Ease of Paying Taxes Act)
Republic Act No. 12066 (CREATE MORE Act)
Revenue Regulations Nos. 8-2022 and 7-2024
Revenue Regulations No. 11-2025, as amended by Revenue Regulations No. 26-2025
Revenue Memorandum Circular No. 98-2026 (September 22, 2026)
Revenue Memorandum Circular No. 110-2026 (October 2026)
Facing a BIR audit, assessment or tax dispute?
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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.
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