Your E-Invoicing Provider Now Needs BIR Accreditation: What RMC 110-2026 Means for Your Business
Three weeks after RMC 98-2026 locked in the December 31, 2026 e-invoicing deadline, the BIR turned its attention to the companies selling e-invoicing systems.
On October 12, 2026, the bureau issued Revenue Memorandum Circular (RMC) No. 110-2026. It takes effect immediately and sets accreditation rules for e-invoicing service providers, or ESPs.
If you plan to buy or subscribe to an e-invoicing solution, this changes the questions you need to ask. Here's what it means in plain language.
What Changed
Before RMC 110-2026, any software vendor could offer an "e-invoicing solution." The BIR certified taxpayers' systems, but it didn't regulate the vendors themselves.
Now it does. A provider can no longer commercially offer e-invoicing or electronic sales reporting services to taxpayers unless its solution has been accredited by the BIR. Approved solutions receive an Electronic Invoicing Solutions Accreditation Certificate.
A few details matter:
- Accreditation is specific. It covers the exact solution, version, modules and deployment setup the BIR evaluated. A vendor's other products, or a heavily customized setup, aren't automatically covered.
- It lasts five years, with an annual compliance review.
- The bar is high. Providers go through documentary, financial, security, data privacy, live demonstration, transmission and load testing stages. They also need a multi-year track record at significant scale and international security certifications.
Who Counts as an E-Invoicing Service Provider
The definition is broader than most people expect. It isn't limited to the system that sends invoices to the BIR.
An ESP is a Philippine-registered company that provides e-invoicing, sales reporting, integration, storage, retrieval, validation, middleware and related services to taxpayers. A system offered to a customer, affiliate, franchisee or any other separate company is treated as an ESP service.
In practice, that means a vendor handling only part of your e-invoicing flow, like storing invoices or connecting your ERP to the BIR, may still need accreditation.
Your Three Paths to Compliance
RMC 110-2026 doesn't force every business to use an outside provider. You have options.
| Path | What it means | Best for |
|---|---|---|
| Use an accredited ESP | Subscribe to a provider holding a valid accreditation certificate | Businesses that want a managed service |
| In-house or licensed software on your own infrastructure | A system you built, or licensed software running on your own servers or cloud account, used only by your company and its branches | Larger companies with IT teams, or those already on ERPs like SAP |
| Request an exemption | Apply in writing with your RDO or the Large Taxpayers Service | Arrangements that don't fit neatly into either path |
The second path matters. Systems used exclusively by one taxpayer and its branches stay under the existing Computerized Accounting System (CAS) and POS registration rules, not ESP accreditation.
Note the word "exclusively." A system shared across a group of separately registered companies may be treated differently. If your group has several legal entities, ask your accountant which path applies.
What Accreditation Doesn't Do for You
An accredited provider is not a compliance shortcut.
You still need your own permits. ESP accreditation does not replace your Permit to Issue (PTI) Electronic Invoice or your EIS Certification. The steps in our December 2026 guide still apply.
You're still responsible for your invoices. Using a provider doesn't shift your obligation to issue accurate invoices, keep proper records and pay the correct taxes.
There is one protection: if an accredited provider alone causes a transmission failure, you won't be penalized for it, provided you were diligent, reported the incident promptly and followed contingency procedures. That protection only applies to accredited solutions.
Protections Built Into the New Rules
RMC 110-2026 also addresses a common worry: getting locked into a vendor.
- Fees must be disclosed upfront, including onboarding, storage, data retrieval, migration and exit charges. Hidden fees aren't allowed.
- No hostage data. Providers cannot withhold, disable or delete your records over unpaid fees, contract disputes or a switch to another provider.
- Portability is required. Providers must let you export your data and move it to another accredited provider without unreasonable delay or cost.
Before signing anything, check that your contract reflects these terms.
Questions to Ask Your Provider This Month
Bring this list to every vendor conversation:
- Do you hold an Electronic Invoicing Solutions Accreditation Certificate? Can we see it?
- If not yet, when did you apply, and what stage are you in?
- Does the certificate cover the exact version and setup we'll be using?
- What are all your fees, including exit and data migration?
- How do we get our data out if we leave?
- What's your contingency procedure if transmission to the BIR fails?
- Who are your subcontractors and cloud providers?
A vague answer to the first question is your cue to keep a backup plan.
The Timing Problem
Here's the uncomfortable part. The first application window for ESP accreditation runs only from October 16 to 30, 2026. The evaluation involves multiple testing stages.
That leaves a tight window between providers getting accredited and the December 31 deadline. Some vendors you're talking to today may not have certificates in time.
Don't wait to find out. Start your PTI application and data cleanup now, keep vendor conversations moving, and ask your accountant whether the in-house or own-infrastructure path is a realistic fallback for you.
Frequently Asked Questions
Does every e-invoicing vendor need BIR accreditation now?
Any provider offering e-invoicing or related services to other businesses needs an accredited solution before going live with real transactions. Demos and clearly labeled pre-production testing are still allowed.
Can we build our own e-invoicing system instead?
Yes. A system you developed, or licensed software running on your own infrastructure and used only by your company and its branches, follows the existing CAS and POS rules rather than ESP accreditation.
If our provider is accredited, are we automatically compliant?
No. You still need your own PTI Electronic Invoice and EIS Certification, and you remain responsible for the accuracy of your invoices and taxes.
Does RMC 110-2026 change the December 31, 2026 deadline?
No. The deadline under RMC 98-2026 stands. RMC 110-2026 adds rules for providers; it doesn't create new e-invoicing obligations for taxpayers.
We're a micro taxpayer. Does this affect us?
Not for this deadline, since micro taxpayers are exempt from this round. See Do Philippine SMEs Need BIR E-Invoicing? for the broader picture.
The Bottom Line
RMC 110-2026 is good news for businesses in the long run. It sets a quality bar for providers, makes pricing transparent and protects your data.
In the short run, it adds one more thing to verify before December 31. Treat "Are you accredited?" as the first question in every vendor conversation, not the last.
Source: Bureau of Internal Revenue, Revenue Memorandum Circular No. 110-2026 (PDF), issued October 12, 2026.
This article is for general information and is not tax or legal advice. Ailalay is not a BIR-accredited e-invoicing service provider. Confirm your specific obligations with your accountant, RDO or the Large Taxpayers Service.
