Who Must Issue E-Invoices in the Philippines? Coverage Under RMC 98-2026

"Do we really have to do this?" is the first question most clients ask about e-invoicing. The answer depends on two things: the size of your business and the way you sell and invoice.

Test 1: Are you a micro business? Micro taxpayers, those with annual gross sales below ₱3 million, are not required to issue e-invoices. They may adopt e-invoicing voluntarily if they wish.

Be careful with the ₱3 million figure. It means total sales before any costs, not profit. For online sellers it is the value of what you sold, not the payout you receive from the platform after fees.

Test 2: How do you sell and invoice? A business that is not micro is covered by RMC 98-2026 if any one of these applies: - **You sell online**, including through Shopee, Lazada, TikTok Shop, social media or your own website. The BIR uses a broad definition of e-commerce. - **You are a large taxpayer** under the BIR's Large Taxpayers Service. - **You issue invoices from software**, such as a computerized accounting system (CAS) or other invoicing software.

A common surprise: online sellers For VAT-registered online sellers, the BIR's invoicing guidance calls for an invoice for each order. A store with hundreds of orders a month cannot do that by hand, which is why online sellers are among the first to feel the change.

What "covered" means in practice If you are covered, invoices made in Word, Excel, Google Docs or Sheets will no longer meet the requirement. You will need a system that issues e-invoices in the BIR's format, a Permit to Issue E-Invoices (PTI), and later an EIS Certificate and a Permit to Transmit.

Not sure which side you are on? Coverage turns on figures and facts that are easy to misread: which sales count toward the threshold, whether a side channel counts as online selling, or how a group of related businesses is treated. We review these with clients every day and can tell you quickly whether the rule applies to you and what to do next.