Author Patrick Cahulao

REVENUE REGULATIONS (RR) NO. 026-2025

Pursuant to Sections 244 and 245 of the Tax Code, as amended, in relation to Sections 12 and 13 of Republic Act (RA) No. 12066, these Regulations amend the transitory provisions of RR No. 11-2025, extending the compliance period for taxpayers to issue electronic invoices, considering required operational adjustments, system reconfiguration, and transition to e-invoicing.

The following taxpayers are given until December 31, 2026 to comply with the electronic invoicing requirements (issuance of electronic invoices) under these Regulations:

  1. E-commerce or internet-based taxpayers classified as Small, Medium, or Large (Micro taxpayers exempted);
  2. Taxpayers under the Large Taxpayers Service (LTS);
  3. Large Taxpayers as defined under RA 11976 (EOPT Act) and RR 8-2024;
  4. Taxpayers using a Computerized Accounting System (CAS) and Computerized Books of Accounts (CBA), with Accounting Records (with electronic invoicing) and other invoicing software.

Once a system capable of storing and processing the required data for transmission to the Bureau of Internal Revenue (BIR) is in place, the following taxpayers must issue electronic invoices, subject to separate issuance of RRs:

  1. Exporters of goods and services under Sections 106 and 108 of the Tax Code (except those covered by Section 3(A)(4) of RR 11-2025);
  2. Registered Business Enterprises with tax incentives under Section 304(D) of the Tax Code (except those under Section 3(A)(4) of RR 11-2025);
  3. Taxpayers using Point of Sale (POS) systems; and
  4. Other taxpayers as may be required by the Commissioner.

RMO No. 37-2024 set forth the criteria in classifying business taxpayers into four categories:

  • Micro taxpayers – gross sales for a taxable year is less than ₱3,000,000
  • Small taxpayers – gross sales for a taxable year is at least ₱3,000,000 but less than ₱20,000,000
  • Medium taxpayers – gross sales for a taxable year is at least ₱20,000,000 but less than ₱1,000,000,000
  • Large taxpayers – gross sales for a taxable year exceed ₱1,000,000,000

Taxpayers using CAS, and CBA with Accounting Records (with electronic invoicing) and other invoicing software

Once a system capable of storing and processing the required data for BIR transmission is established, the following taxpayers shall be required to comply with the Electronic Sales Reporting System (ESRS), subject to separate issuance of RRs:

  1. E-commerce or internet-based taxpayers classified as Small, Medium, and Large (Micro taxpayers exempted);
  2. Taxpayers under the LTS;
  3. Large Taxpayers as defined under RA 11976 and RR 8-2024;
  4. Taxpayers using CAS, CBA with electronic invoicing, or other invoicing software;
  5. Exporters of goods and services under Sections 106 and 108 of the Tax Code;
  6. Registered Business Enterprises with tax incentives under Section 304(D) of the Tax Code;
  7. Taxpayers using POS systems; and
  8. Other taxpayers as may be required by the Commissioner.

The Commissioner of Internal Revenue may further extend the compliance period under these Regulations as may be deemed necessary. Any invalid provision will not affect the rest of the Regulations, and all inconsistent issuances are repealed or amended. These regulations shall take effect immediately upon publication on the BIR official website.