Philippines: Accreditation framework for e-invoicing service providers

The Philippine Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 110-2026, effective immediately, establishing a comprehensive accreditation framework for e-invoicing service providers (ESPs). The circular introduces specific accreditation and continuing compliance requirements for third-party providers that build and operate e-invoicing technology, rather than focusing solely on taxpayer-level compliance obligations.

Background

Under Sections 237 and 237-A of the National Internal Revenue Code, as amended by the TRAIN Law and the CREATE MORE Act, certain taxpayers in the Philippines are required to issue electronic invoices and report sales electronically. Previous issuances (including RR No. 8-2022, RR No. 11-2025 (as amended by RR No. 26-2025), and RMC No. 98-2026) established the taxpayer-facing rules for e-invoicing and electronic sales reporting (EIS) certification. RMC No. 110-2026 builds on this foundation by introducing accreditation requirements for the service providers enabling this compliance.

Key provisions

• Mandatory accreditation. No ESP may commercially deploy an e-invoicing solution in the Philippines without a valid Electronic Invoicing Solutions Accreditation Certificate. Accreditation is solution-specific, valid for five years, and subject to annual compliance review.
• Stage-gated accreditation process. ESPs must undergo documentary review, financial capacity assessment, technical architecture review, data privacy and cybersecurity evaluation, live system demonstration, interoperability testing, and load/stress testing.
• Eligibility and track record. Applicants must demonstrate operational maturity (by having successfully operated or supported systems collectively capable of processing at least 5 million transactions annually and supporting at least 1,000 active user or customer accounts per year, for each of the immediately preceding three years) along with financial capacity and qualified personnel. Applicants must also be organized or licensed to do business in the Philippines and maintain an authorized representative and accountable technical, compliance, data protection, and security officers in the Philippines.
• Technical and security standards. ESPs must comply with Executive Order No. 119 (s. 2026) on government data classification and data residency, maintain relevant ISO/IEC security certifications, and undergo source code review, vulnerability assessment, and penetration testing.
• Data governance. Taxpayers retain ownership of their data; the BIR retains custody, control, and direct access rights. ESPs must support data portability and migration, and are prohibited from enabling vendor lock-in.
• Accountability and sanctions. ESPs are directly liable to the BIR and to taxpayer-clients for breaches or system failures, including indemnification obligations. The BIR may issue corrective action orders, or suspend or revoke accreditation (including on an emergency basis) where risks are imminent.
• Relationship to existing rules. ESP accreditation does not replace existing taxpayer-level computerized accounting system (CAS) / point-of-sale (POS) registration requirements. Internally developed systems used exclusively by a single taxpayer remain subject to separate CAS/POS rules, though systems shared across affiliated entities may now require ESP accreditation.
• Application period. In a separate tax advisory released on October 15, 2026, the BIR announced that applications for ESP accreditation will be accepted from October 16 through October 30, 2026. Only applications submitted within this period and accompanied by complete documentary requirements will be accepted for evaluation. Applications must be submitted to the ESP Accreditation Board Secretariat at the Client Support Service (CSS), Room 610, 6th Floor, BIR National Office, Quezon City.

KPMG observation

RMC No. 110-2026 represents a notable shift in the BIR's regulatory approach, extending oversight beyond taxpayers to the technology infrastructure underpinning e-invoicing compliance. Businesses operating in the Philippines that rely on third-party e-invoicing providers should confirm their provider's accreditation status without delay, given the circular's immediate effectivity and the absence of a transition period. Moreover, considering the limited application period from October 16 through October 30, 2026, announced by the BIR, ESPs should promptly assess their eligibility and prepare the required documentation to ensure timely submission of their accreditation applications. Renewal deadlines are also critical: ESPs must renew accreditation at least 60 days before expiration, and a lapse could result in suspension of a taxpayer's Permit to Issue (PTI) Electronic Invoice.

Potential actions

• Confirm the BIR accreditation status of current e-invoicing service providers
• Review service agreements to address accreditation maintenance, renewal timelines, and incident response obligations
• Determine whether internally developed systems shared across affiliated entities now require ESP accreditation
• Maintain parallel compliance with existing CAS/POS and PTI/EIS registration requirements, which remain unaffected
• For ESPs, assess eligibility for accreditation and confirm submission of complete documentary requirements within the October 16 through October 30, 2026, application period

For more information, contact a KPMG tax professional:

Julius Acosta | jcacosta@kpmg.com

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com