EazLink guide
RR 11-2025 vs RR 26-2025: what changed for electronic invoicing?
Compare the underlying electronic invoicing rules with the later amendment to the compliance period.
Updated 2026-09-06 by the EazLink team. Editorial review: EazLink Editorial Team.
Direct answer
RR 11-2025 defines electronic invoices, electronic invoicing, electronic sales reporting and the taxpayer groups in scope. RR 26-2025 amends the transitory provisions and gives specified groups until December 31, 2026 for electronic invoice issuance. It does not erase the definitions or the rest of the operating framework in RR 11-2025.
What to remember
- Read RR 26-2025 together with RR 11-2025.
- The later regulation changes the transitory timetable for named groups.
- The definition of an electronic invoice still depends on structured, extractable data.
- POS and sales reporting conditions need their own review.
What each regulation covers
The documents answer different questions.
| Document | Main purpose | Project use |
|---|---|---|
| RR 11-2025 | Definitions, scope and operating requirements | Build the compliance and data model |
| RR 26-2025 | Amended transitory period | Set the timetable for named groups |
| Current BIR portal notices | Operational availability and instructions | Plan testing and day-to-day procedures |
RR 11-2025 supplies the working definitions
The regulation distinguishes an electronic invoice from a scan or an ordinary paper output. It focuses on system-generated structured data that can be extracted and transmitted electronically.
That definition affects architecture. A PDF can be part of delivery to a buyer, but a picture of paper does not create the structured data needed for automated processing.
RR 26-2025 changes the timetable
The amendment responds to the time needed for system reconfiguration and transition. It names four groups for the December 31, 2026 compliance period.
The text also keeps conditional language for POS users, exporters, registered business enterprises and electronic sales reporting. Those parts require attention to later BIR action.
Use one legal matrix and one technical backlog
Put every requirement in a matrix with its source, affected taxpayer, trigger and owner. Then create technical work only for confirmed requirements.
This is less exciting than buying software first, but it prevents expensive rework.
How to read the two rules together
- Mark the definitions in RR 11-2025.
- List the groups in the amended transitory section.
- Separate issuance from sales reporting.
- Record conditional groups and missing later guidance.
- Have tax and technology owners sign off on one scope.
Quick questions
Did RR 26-2025 replace RR 11-2025?
No. It amends the transitory provisions. The two documents should be read together.
What changed most clearly?
The compliance period for specified electronic invoice issuance groups was extended to December 31, 2026.
Can a project rely on the digest alone?
Use the full regulation for decisions. A digest is useful for orientation, not for resolving detailed scope questions.
Continue the preparation
Sources and verification
Check the current BIR rules and portal notices before making a compliance decision.