RMC No. 110-2026: Is Your E-Invoicing Provider BIR-Accredited?
Revenue Memorandum Circular (RMC) No. 110-2026, issued by the BIR on October 12, 2026, requires an electronic invoicing or electronic sales-reporting service provider (ESP) to obtain BIR accreditation before offering its solution commercially to Philippine taxpayers. The requirement lands on the vendor, not directly on the business using the system — but it still matters to any company choosing or renewing an e-invoicing provider, because an unaccredited vendor’s solution may not satisfy the BIR’s own compliance expectations.
This circular sits alongside the taxpayer-facing e-invoicing deadline and the invoicing changes already covered in RR No. 6-2026 and the Electronic Invoicing System and RMC No. 112-2026: BIR Extends the Deadline to Show Withholding Tax on Invoices.
Keep Your BIR Compliance Audit-Ready FREE →What does RMC No. 110-2026 actually require? #
The circular, dated October 12, 2026 per multiple secondary reports (Inquirer, vatupdate.com, Comarch, Reyes Tacandong & Co.), sets up accreditation for ESPs — companies that build or operate electronic invoicing and electronic sales reporting solutions — rather than imposing a new direct obligation on the end taxpayer. Reporting describes the core requirement this way:
An e-invoicing or electronic sales reporting solution requires BIR accreditation before it can be deployed commercially, under RMC No. 110-2026 of October 12, 2026.
— summarizing coverage from vatupdate.com and Inquirer.net
Secondary coverage also describes accreditation as attaching to a specific solution, version, and configuration — not a blanket company-wide approval — and as valid for five years, subject to annual review. Because none of the available reporting quotes the circular’s operative text directly, a business should confirm these specifics against the circular itself before relying on them in a contract negotiation.
Why this matters for a business choosing an e-invoicing vendor #
A company shopping for an e-invoicing or CAS vendor now has a reason to ask directly whether that vendor’s specific solution — not just the company generally — holds current BIR accreditation, since accreditation is reported to attach to a particular solution and configuration rather than to a vendor’s brand name as a whole.
| What to check | Why it matters |
|---|---|
| Is this specific solution/version accredited, not just the vendor’s company name? | Accreditation reportedly attaches to a solution, version, and configuration |
| What happens to our invoice data if we switch providers? | The circular is reported to include protections against a provider withholding or deleting records over fees, disputes, or termination |
| Has the BIR published this provider on an official accredited list? | At least one report found that, shortly after issuance, no accredited-provider list had yet been published and the review body was still being set up |
What this means alongside the taxpayer’s own e-invoicing deadline #
A taxpayer’s obligation to actually issue e-invoices is governed by a separate compliance deadline — reported as RMC No. 98-2026, setting December 31, 2026 for covered taxpayers — and that deadline can be met using an in-house system, a commercial solution, or a provider going through this new accreditation track. RMC No. 110-2026 does not, on the reporting available, change that taxpayer deadline; it changes what a taxpayer should look for when picking a third-party ESP to meet it, especially since one report (as of mid-October 2026) found the BIR had not yet published a list of accredited providers, meaning “BIR-accredited” claims from vendors during this transition window should be verified rather than taken at face value.
Summary #
RMC No. 110-2026 requires electronic invoicing and e-sales-reporting service providers — not taxpayers directly — to secure BIR accreditation for each specific solution and configuration they offer commercially, reportedly valid for five years with annual review and carrying vendor lock-in protections for taxpayer data. A business evaluating an e-invoicing vendor should ask for proof of accreditation on the specific solution being sold, not just a general claim, and verify it against the BIR’s own published list once available. See RR No. 6-2026 and the Electronic Invoicing System for how this fits the broader e-invoicing rollout and RMC No. 112-2026 for the related CWT-on-invoice deadline extension.