Tax Alert No. 29 [Revenue Regulations (RR) No. 26-2025 dated 16 October 2025]

Amending the transitory provisions of RR No. 11-2025 extending the compliance period for electronic invoice issuance by covered taxpayers 

The Bureau of Internal Revenue (BIR) has issued Revenue Regulations (RR) No. 26-2025, amending RR No. 11-2025 and extending the compliance period for the issuance of electronic invoices to 31 December 2026. 

This extension provides covered taxpayers with additional time to adjust their systems and transition to electronic invoicing. 

1. Taxpayers granted an extension until 31 December 2026 to comply with electronic invoicing requirements:

• Small, Medium, and Large Taxpayers engaged in e-commerce or internet transactions (Micro Taxpayers are exempted) 
• Taxpayers under the Large Taxpayers Service (LTS) 
• Taxpayers classified as Large Taxpayers under RA No. 11976 and RR No. 8-2024 
• Users of Computerized Accounting Systems (CAS), Computerized Books of Accounts (CBA) with accounting records (with electronic invoicing), and other invoicing software 

1. 2. Taxpayers required to issue electronic invoices once a system for storing and processing the required data to be transmitted to the BIR is established (subject to separate regulation):

• Exporters under Sections 106 and 108 (excluding those under Section 3(A)(4) of RR No. 11-2025) 
• Registered Business Enterprises availing of tax incentives under Section 304(D) (excluding those under Section 3(A)(4) of RR No. 11-2025) 
• POS system users 
• Others as may be required by the Commissioner 

1. 3. Taxpayers required to comply with the Electronic Sales Reporting System requirements once a system for storing and processing the required data to be transmitted to the BIR is established (subject to separate regulation):

• Small, Medium, and Large Taxpayers engaged in e-commerce or internet transactions (Micro Taxpayers are exempted) 
• Taxpayers under LTS 
• Taxpayers classified as Large Taxpayers under RA No. 11976 and RR No. 8-2024 
• Users of CAS, CBA with electronic invoicing, and other invoicing software 
• Exporters of goods and services 
• Registered Business Enterprises under Section 304(D) 
• POS system users 
• Others as may be required by the Commissioner 

The Commissioner may further extend the compliance period as necessary. 

RR No. 26-2025 is effective immediately upon publication. 

You may access the full version of the RR through the BIR website.

For any inquiry or request for assistance, please feel free to contact anyone from our Tax Services group. You may also reach us through this link