EazLink guide
BIR EIS Certification and Permit to Transmit: A Taxpayer Guide
Understand BIR EIS certification, PTI and Permit to Transmit requirements, CAS documents, and how taxpayer and provider roles affect preparation.
Updated and reviewed:
Reviewed under the EazLink editorial standard.
Direct answer
A Philippine e-invoicing project can involve a Permit to Issue, BIR EIS Certification and a Permit to Transmit. Each serves a different purpose. The taxpayer applies for its own permissions and remains responsible for compliance. A software provider can help with system design, data mapping, tests and evidence, but it cannot replace the taxpayer in the BIR process.
According to Revenue Memorandum Circular No. 98-2026 and Revenue Memorandum Circular No. 110-2026, this answer reflects the cited BIR regulation or official portal guidance. Confirm later BIR issuances before acting.
What to remember
- A PTI permits electronic invoice issuance through the covered system.
- EIS Certification checks whether the system meets the required technical tests.
- A PTT authorizes sales-data transmission when the applicable BIR directive requires it.
- CAS registration, PTI, certification and PTT are separate records. One does not prove that the others are complete.
PTI, certification, PTT, CAS and ESP in brief
Use the exact term for the decision or document you are checking.
| Item | What it addresses | Who or what it applies to |
|---|---|---|
| Permit to Issue (PTI) | Authority to generate or issue electronic invoices through the covered system | The taxpayer and its specified invoicing system |
| EIS Certification | Technical ability to extract, process and transmit the required sales data | The taxpayer's actual system and middleware in the test scope |
| Permit to Transmit (PTT) | Authority to transmit sales data to BIR EIS under the applicable reporting instruction | The taxpayer that has been directed or notified to report |
| CAS AC or PTU | Registration or permission for the computerized accounting system | The registered taxpayer, system, version and locations |
| ESP solution accreditation | BIR approval of a specified electronic invoicing solution under RMC 110-2026 | The ESP's approved solution, version and deployment scope; the taxpayer still needs its applicable registrations and permits |
Do not use one approval as proof that every other requirement is complete.
Sources: Revenue Memorandum Circular No. 98-2026, II.5-7 and IV.12-15; Revenue Memorandum Circular No. 110-2026, IV.c, V.A.1 and V.A.5
BIR EIS Certification and PTT answer different questions
Certification shows whether the system can pass the required technical tests. A PTT authorizes production transmission of sales data. Passing a test does not, by itself, authorize production transmission.
RR 8-2022 describes taxpayer enrollment, system certification and a PTT before actual transmission. RMC 98-2026 ties the PTT requirement to a notification or directive from the Commissioner. A taxpayer that already has a reporting directive must continue to follow it.
Sources: Revenue Regulations No. 8-2022, Section 4.2-5; Revenue Memorandum Circular No. 98-2026, IV.15
Where PTI and CAS registration fit
RMC 98-2026 requires taxpayers covered by the electronic invoicing rules to obtain a PTI before they generate or issue electronic invoices. Those taxpayers must obtain EIS Certification within six months after the PTI is issued.
A CAS Acknowledgement Certificate or Permit to Use does not replace a PTI. Check the system, version, branches and changes covered by the existing CAS record. RMO 9-2021 allows a valid existing CAS PTU to continue, but a system change can require an update.
Sources: Revenue Memorandum Circular No. 98-2026, II.7 and IV.12-15; Revenue Memorandum Order No. 9-2021, V.8 and VII
Check whether the December 31, 2026 deadline applies
The December 31, 2026 electronic invoicing deadline applies to the categories specified in RMC 98-2026 and RR 26-2025, including covered e-commerce businesses, large taxpayers and users of specified accounting or invoicing systems.
It is not a universal sales-transmission deadline. Check the taxpayer classification, the Micro taxpayer exception, branch scope and any overlapping category before using that date in a project plan.
Sources: Revenue Memorandum Circular No. 98-2026, III, IV.1-2 and IV.16; Revenue Regulations No. 26-2025 Digest, official digest
The taxpayer applies even when a provider helps
The taxpayer remains responsible for its applications and compliance. RR 8-2022 requires the taxpayer to apply for EIS Certification and PTT regardless of its arrangement with a software provider.
A technical team can document the architecture, map invoice data, build the interface, run tests and prepare evidence. The project should also name who controls production access, handles errors, stores records and manages recovery.
Sources: Revenue Regulations No. 8-2022, Section 4.5; Revenue Memorandum Circular No. 98-2026, IV.15
Check the ESP service model and solution accreditation
RMC 110-2026 now sets accreditation requirements for ESP electronic invoicing solutions. An ESP must meet the applicable Philippine legal-presence and local-officer requirements.
Before commercial deployment or activation, an ESP must hold a valid Electronic Invoicing Solutions Accreditation Certificate for the covered solution. Check that the certificate covers the proposed version, modules, interfaces and deployment configuration.
Section III defines an important scope boundary:
- It excludes an internally developed system, or licensed software run on the taxpayer's own infrastructure, used only by one taxpayer and its registered branches. Existing CAS, POS and other applicable registration rules still apply.
- A system or service offered to another legal entity falls within ESP scope unless BIR grants an exemption. This includes services offered to an affiliate or subsidiary.
Confirm the actual users, operators and hosting arrangement before choosing a route. A software licence or a foreign hosting location alone does not establish an exemption.
ESP solution accreditation does not replace the taxpayer's CAS or POS registration, PTI or EIS Certification. Keep the taxpayer's applicable PTT and reporting instructions as separate checks. An ESP can support authorized work, but the taxpayer remains the holder of its own permissions.
Sources: Revenue Memorandum Circular No. 110-2026, III, IV.a and V.A.1-3, V.A.5; Revenue Memorandum Circular No. 98-2026, IV.12-15
Choose Annex C or Annex E for the real arrangement
The CAS supporting statement depends on who uses and maintains the system. The BIR checklist distinguishes taxpayer-maintained systems from systems maintained by a third-party provider. The 2026 Citizen's Charter lists Annex C or the Joint Sworn Statement in Annex E, as applicable.
A Joint Sworn Statement supports the CAS registration. It does not create a joint PTI, EIS Certification or PTT. The reviewed official sources do not resolve how a foreign supplier without a Philippine TIN can sign Annex E and have it accepted. Ask the registered RDO or LT Office for written confirmation before relying on a foreign tax number or signature.
Where the third-party service arrangement in RMO 9-2021 applies, complete CAS registration before the service contract takes effect. Confirm this point before setting contract and implementation dates.
Sources: RMC No. 5-2021 Annex A, Annex A; BIR Citizen's Charter 2026, printed pages 66-68; Revenue Memorandum Order No. 9-2021, V.6
Plan the application period carefully
RMC 98-2026 gives BIR 20 working days to evaluate a PTI application and determine compliance after it receives complete documents. This period does not include development, document preparation or time needed to correct an incomplete application. It is not a guaranteed launch date.
Start certification preparation early. Failure to obtain certification within the six-month period is a ground for PTI revocation. Keep the system version stable, prepare representative invoices and exceptions, and retain test results for each attempt.
For failed tests, use our BIR EIS test failure checklist to record the evidence and identify the responsible team.
Sources: Revenue Memorandum Circular No. 98-2026, IV.12 and IV.15
What EazLink can support
EazLink can help a taxpayer and its provider assess the integration scope, map source data, run prechecks, prepare test evidence and track technical results.
EazLink does not issue a PTI or PTT, decide whether an arrangement qualifies as an ESP, or guarantee BIR certification. BIR determines the applicable approvals and whether an application is accepted.
Find your next application step
Choose the checks that fit your taxpayer, system and service model. These are planning checks, not a fixed sequence for every project. Confirm the route and required documents with your Revenue District Office (RDO) or Large Taxpayer (LT) Office.
| Your situation | Next check or action | Responsible party | Evidence to keep |
|---|---|---|---|
| You have a CAS AC or PTU and must issue electronic invoices | Check the required PTI before issuance. Confirm its system and branch coverage. | Taxpayer, with technical support as needed | CAS record and the applicable PTI |
| You must issue electronic invoices and already have a PTI | Obtain EIS Certification within six months from PTI issuance. Start test preparation early. | Taxpayer and its authorized technical team | PTI issue date, test records and EIS Certification |
| BIR has directed you to report sales data | Follow the directive. Complete the required enrollment and PTT steps before production transmission. | Taxpayer, with an authorized provider where applicable | BIR directive, enrollment record and PTT |
| You plan to use an ESP solution | Check the solution's accreditation and approved scope. Check the taxpayer's own permissions separately. | ESP for its solution; taxpayer for its own permissions | Applicable solution certificate and taxpayer approvals |
| Your proposed system is for one taxpayer and its registered branches | Check the Section III exclusion in RMC 110-2026 against the actual development, licence, hosting and user arrangements. | Taxpayer and provider | Documented service model and any BIR clarification needed |
Keep source data, test payloads and results traceable. Do not expose production credentials or personal data in test evidence.
Sources: Revenue Memorandum Circular No. 98-2026, II.7 and IV.12-15; Revenue Regulations No. 8-2022, Section 4.2-5; Revenue Memorandum Circular No. 110-2026, III and V.A.1-2, V.A.5
Quick questions
Can we issue electronic invoices after CAS registration?
A CAS AC or PTU alone is not enough. A taxpayer covered by RMC 98-2026 must obtain the required PTI before generating or issuing electronic invoices through the covered system.
Must we obtain PTT immediately after receiving PTI?
RMC 98-2026 ties the PTT requirement to a Commissioner notification or directive for electronic sales reporting. The six-month EIS Certification requirement is a separate obligation for taxpayers required to issue electronic invoices.
Can an overseas software company support our application?
Yes. It can support technical preparation under the taxpayer's authorization. Check whether the actual service model falls within ESP scope under RMC 110-2026. If it does, check the applicable Philippine legal-presence and solution-accreditation requirements. Confirm any unresolved Annex E signing requirements with BIR. The taxpayer remains the holder of its own permissions.
Does an ESP's accreditation replace our PTI or EIS Certification?
No. RMC 110-2026 accredits the provider's specified solution. The taxpayer still needs its applicable system registration, PTI and EIS Certification. Check PTT requirements against the taxpayer's BIR reporting directive.
Sources: Revenue Memorandum Circular No. 110-2026, III, V.A.2-3 and V.A.5; Revenue Memorandum Circular No. 98-2026, IV.15
Does buying commercial software always require Annex E?
Not necessarily. The BIR checklist looks at who uses and maintains the system. Confirm whether Annex C or Annex E fits the real arrangement.
Continue the preparation
Sources and verification
Check the current BIR rules and portal notices before making a compliance decision.
- Revenue Memorandum Circular No. 98-2026 (Philippines Bureau of Internal Revenue)
- Revenue Memorandum Circular No. 110-2026 (Philippines Bureau of Internal Revenue)
- Revenue Regulations No. 8-2022 (Philippines Bureau of Internal Revenue)
- Revenue Regulations No. 26-2025 Digest (Philippines Bureau of Internal Revenue)
- Revenue Memorandum Order No. 9-2021 (Philippines Bureau of Internal Revenue)
- RMC No. 5-2021 Annex A (Philippines Bureau of Internal Revenue)
- BIR Citizen's Charter 2026 (Philippines Bureau of Internal Revenue)