Tax Alert No. 1 [Revenue Regulations (RR) No. 28-2025]

Implementing the Enhanced Version of the Electronic Documentary Stamp Tax System

Please be informed that Revenue Regulations (RR) No. 28-2025 was issued to implement the enhanced Electronic Documentary Stamp Tax (eDST) System. Under this RR, the following industries are mandated to use the enhanced eDST System for affixing documentary stamps on taxable documents:

1. Bank, quasi-bank or non-bank financial intermediary, finance companies, or insurance, surety, fidelity, or annuity companies;
2. Shipping and airlines companies;
3. Pre-need companies on sale of pre-need plans, as provided under Section 186 of the Tax Code;
4. Educational institutions, with respect to the issuance of taxable certificates such as Diploma, Transcript of Records, and other documents taxable as certificates under Section 188 of the NIRC of 1997, as amended;
5. National Government Agencies and its instrumentalities, including Government-Owned or Controlled Corporations (GOCCs), Local Government Units (LGUs) except barangays, with respect to documents taxable as certificates under Section 188 of the NIRC of 1997, as amended;
6. Notaries Public, including those employed in law firms and other offices, whether public or private; and
7. Such other industries as may be required by the Secretary of Finance, upon recommendation of the Commissioner, through the issuance of a revenue regulation.

Requirement of Online Enrollment on the Used of eDST System

Taxpayers must enroll online via the BIR website and select either the Deposit Module (advance deposit) or Non-Deposit Module (monthly remittance). 

Limitations on the Use of Loose Documentary Stamps and Constructive Affixture

Loose documentary stamps are generally prohibited except for documents with a tax due of ₱30.00, subject to strict conditions. 

The RR also provides rules on excess deposits, phased implementation, and penalties for violations. 

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