PhilExport seeks 1-year delay in mandatory e-invoicing

The Philippine Exporters Confederation, Inc. (PHILEXPORT) is asking the Bureau of Internal Revenue (BIR) to defer the December 2026 implementation of the agency’s mandatory Electronic Invoicing System (EIS) by one year, warning that businesses face “massive operational disruptions” under the tight compliance deadline.

In a position letter to BIR Commissioner Charlito Martin R. Mendoza dated September 23, PHILEXPORT President Sergio R. Ortiz-Luis Jr. said the exporters’ trade group supports a request by the BIR-Partnership with the Multisectoral Group (BIR-PMSG), a formal consultative body between the bureau and the private sector, to postpone the e-invoicing mandate.

The BIR issued Revenue Memorandum Circular (RMC) No. 98-2026 on September 22, 2026, prescribing policies and guidelines for the issuance of electronic invoices.

The circular sets December 31, 2026 as the mandatory compliance deadline for businesses covered by the initial phase of the EIS.

It covers small, medium, and large taxpayers engaged in e-commerce or internet transactions; taxpayers under the Large Taxpayers Service; large taxpayers covered by the Ease of Paying Taxes Act; and users of Computerized Accounting Systems (CAS) or Computerized Books of Accounts (CBA) with accounting records and electronic invoicing, as well as users of other invoicing software.

Micro taxpayers are exempt from the initial implementation.

PHILEXPORT said the one-year deferment is necessary because businesses need more time to address the operational and technical requirements of the new system.

Ortiz-Luis cited the “extremely tight deadline” for compliance, noting that the draft RMC detailing the technical and compliance guidelines was released for public consultation only at the end of August.

This leaves covered taxpayers, including large companies, e-commerce businesses and CAS/CBA users, with less than four months to reconfigure complex enterprise resource planning systems, test application programming interface integrations and train personnel.

“A forced year-end transition risks massive operational disruptions,” Ortiz-Luis said.

PHILEXPORT also warned that the operational and financial effects of the mandate could extend to micro enterprises, despite their exemption from the initial phase of implementation.

Ortiz-Luis pointed to the “deep interdependence” between micro enterprises, small exporters and companies covered by the EIS.

“Despite their exemption, micro enterprises operate within supply chains anchored by large taxpayers and direct exporters. Any administrative or technical bottlenecks experienced by large corporations will inevitably disrupt the cash flow and continuity of smaller suppliers,” he said.

The group also called for stronger institutional support for businesses affected by the mandate and those indirectly exposed to its impact.

“We recommend utilizing an extended transition window to deploy sector-specific technical toolkits, dedicated helpdesks and stable testing environments to ensure compliance without compromising the principles of the Ease of Doing Business Act,” Ortiz-Luis said.

Under RMC No. 98-2026, valid electronic invoices must be generated through accredited and registered accounting or invoicing software or systems capable of electronically extracting and transmitting data.

Invoices manually created using Microsoft Word, Excel, Google Docs or Google Sheets are not considered valid electronic invoices. Digital files and emailed PDFs also do not automatically qualify as electronic invoices under the rules.

Businesses must also secure a Permit to Issue (PTI) Electronic Invoice from the Revenue District Office or Large Taxpayer Office where they are registered before deploying their in-house, commercial, or service-provider invoicing solution.

“To ensure an orderly and compliant migration, PHILEXPORT respectfully requests the BIR to extend the mandatory EIS implementation deadline to another year or December 31, 2027,” the letter said.