EazLink guide
Who must issue electronic invoices in the Philippines by December 31, 2026?
A careful reading of the taxpayer groups named in RR 26-2025 and the conditions that do not share the same deadline.
Updated 2026-09-06 by the EazLink team. Editorial review: EazLink Editorial Team.
Direct answer
RR 26-2025 gives four named groups until December 31, 2026: covered ecommerce taxpayers except micro taxpayers, taxpayers under the Large Taxpayers Service, taxpayers classified as large under the cited rules, and users of CAS, CBA with accounting records and other invoicing software. POS users and some other groups are described separately and should not be assumed to share that date without checking later BIR regulations.
What to remember
- December 31, 2026 applies to the groups named in RR 26-2025.
- Micro ecommerce taxpayers are excluded from the first listed ecommerce group.
- POS issuance and electronic sales reporting have separate conditions in the regulation.
- Confirm classification and branch impact before committing to a project scope.
Deadline status by taxpayer group
This table summarizes the wording in RR 26-2025. It is not a substitute for a formal tax opinion.
| Group | December 31, 2026 | What to verify |
|---|---|---|
| Small, medium and large ecommerce taxpayers | Named in the deadline | Taxpayer classification and activity |
| LTS and other classified large taxpayers | Named in the deadline | Current BIR classification |
| CAS, CBA with accounting records and other invoicing software | Named in the deadline | System registration and invoice workflow |
| POS users and other conditional groups | Not automatically the same date | Later regulations and BIR system readiness |
Start with taxpayer classification
Do not begin with the software brand. Begin with the registered taxpayer, its activities and the classification used by the BIR.
A group with several entities may have different answers for each taxpayer. RR 11-2025 also addresses head office and branch office coverage, so the organization chart belongs in the scope review.
Separate invoice issuance from sales reporting
Electronic invoice issuance and electronic sales reporting are related, but the regulations do not treat every obligation as if it starts on one universal date.
A project plan should label each obligation and its legal trigger. That prevents a team from building a reporting flow when the immediate requirement is structured invoice issuance, or the reverse.
Turn the legal answer into a system plan
Once a qualified adviser confirms scope, list the systems that create invoices, the branches that issue them and the formats each system can export.
EazLink can then map the technical work. The legal conclusion remains with the taxpayer and its advisers.
Scope review
- List every Philippine taxpayer entity.
- Record ecommerce, LTS, large taxpayer and system status.
- Identify the invoice-producing system for each entity.
- Map head office and branches.
- Confirm the conclusion against current BIR publications.
Quick questions
Is every Philippine business due by December 31, 2026?
No. RR 26-2025 names specific taxpayer groups. Other groups may be covered under different conditions or later regulations.
Are micro ecommerce taxpayers in the first RR 26-2025 group?
The regulation states that micro taxpayers are exempted from that listed ecommerce group.
Does the deadline automatically mean API transmission on the same date?
Do not assume that. Separate issuance and sales reporting obligations, then confirm the current BIR rules for each.
Continue the preparation
Sources and verification
Check the current BIR rules and portal notices before making a compliance decision.