RMC No. 110-2026: What to Check Before Signing Up With an E-Invoicing Service Provider
Revenue Memorandum Circular (RMC) No. 110-2026, reported as issued around October 12-13, 2026, sets BIR accreditation and continuing-compliance requirements for Electronic Invoicing Service Providers (ESPs) — the third-party platforms many businesses rely on to issue and transmit electronic invoices — and a taxpayer using an unaccredited provider’s live solution is still the one on the hook for the result. This matters directly to any business shopping for an e-invoicing vendor ahead of the BIR’s phased Electronic Invoicing System (EIS) compliance dates.
Handle Your RELIEF, QAP, and SAWT Filings FREE →This post covers what multiple independent tax and business publications report RMC No. 110-2026 requires of an ESP, and what a taxpayer evaluating a vendor should verify before signing a contract. For the underlying EIS framework, see BIR Electronic Invoicing System (EIS) Explained; for the separate POS/SDTS accreditation track, see How to Choose an EIS-Compliant POS or Sales Data Transmission System.
A note on sourcing: this site could not reach the BIR’s CDN directly to pull RMC No. 110-2026’s own text, so the specifics below reflect reporting corroborated across several independent tax-alert and business-press sources (including Grant Thornton, Sunstar, and Inquirer Business coverage), not a verified quote of the primary circular. Confirm exact requirements against the official issuance before relying on them for a vendor contract or compliance decision.
What does an ESP actually have to do under RMC No. 110-2026? #
Reported coverage describes a pre-deployment accreditation requirement: an ESP cannot process a taxpayer’s live transactions through a given e-invoicing solution until that specific solution has been accredited by the BIR. The requirement is reportedly tied to the exact solution deployed, not to the company generically:
| Requirement (as reported) | What it covers |
|---|---|
| Pre-deployment accreditation | No live taxpayer transactions through a solution until it holds a BIR Electronic Invoicing Solutions Accreditation Certificate |
| Solution-specific scope | Accreditation covers the approved version, modules, interfaces, and configuration — a material change can require reaccreditation |
| Five-year validity, annual review | Accreditation reportedly runs five years, subject to annual review, with renewal required at least 60 days before expiration |
| Documentation and personnel | ESPs must disclose authorized technical/compliance officers, beneficial owners, and key personnel, updating the BIR on material changes |
| Technical readiness testing | Interoperability, load, failover, and recovery testing, not documentation alone |
| Data portability on exit | Fees for exit or migration must be disclosed and capped at documented cost; providers can’t withhold client records over a dispute |
Pre-production demonstrations and controlled testing are reportedly still allowed before accreditation — the restriction is specifically on processing real taxpayer transactions live.
Why does this matter to the taxpayer, not just the vendor? #
A taxpayer’s own duty to issue accurate invoices, keep correct records, and file correct returns doesn’t transfer to its e-invoicing vendor just because that vendor holds (or claims to hold) BIR accreditation. This is consistent with how the EIS framework has worked from the start: BIR Electronic Invoicing System (EIS) Explained already establishes that the taxpayer named under NIRC Section 237-A is the one legally covered by the e-invoicing mandate, with the vendor’s Sales Data Transmission System acting as the mechanism, not the obligated party. RMC No. 110-2026’s accreditation framework reportedly reinforces that same division: accreditation is about whether the platform is fit to operate, not a substitute for the taxpayer’s own compliance.
A taxpayer that signs with an unaccredited provider and goes live anyway is reported to risk its own invoices and transmitted sales data being treated as non-compliant — the same exposure as if it had built a non-compliant in-house system itself. The underlying transmission standard an ESP’s solution has to meet is the same one Revenue Regulations (RR) No. 8-2022 already set for every covered taxpayer regardless of which vendor they use:
“Transmission of sales data shall be done real-time or near real-time provided that it should be done within three (3) calendar days from the date of the transaction.”
Source: RR No. 8-2022, quoted as reflected in tax-practitioner summaries of the regulation, as cited in this site’s EIS coverage. An ESP’s accreditation under RMC No. 110-2026 is reportedly, in part, a check that its platform can actually meet that three-calendar-day transmission standard at scale — not a new, separate timing rule.
How is this different from choosing an EIS-compliant POS system? #
RMC No. 110-2026’s ESP accreditation and the POS/SDTS accreditation covered in How to Choose an EIS-Compliant POS or Sales Data Transmission System are two separate tracks for two different kinds of vendor. A Sales Data Transmission System or point-of-sale vendor is accredited under Revenue Memorandum Order No. 24-2023 for the hardware/software that captures and transmits sales data. An Electronic Invoicing Service Provider under RMC No. 110-2026 is a broader category of third-party platform — potentially including the same vendors, but accredited under a distinct framework specifically for e-invoicing solutions.
A business evaluating a vendor that offers both functions should ask which accreditation applies to which part of what it’s buying, rather than assuming one accreditation certificate automatically covers both roles.
A checklist before signing with an e-invoicing provider #
- Ask the vendor directly for its Electronic Invoicing Solutions Accreditation Certificate covering the specific solution, version, and modules it will deploy for you — not just a general claim of “BIR accreditation.”
- Confirm the certificate is current, given the reported five-year validity with annual review — an older accreditation on a since-updated solution may need to have been renewed or reaccredited.
- Ask what changes would require reaccreditation under the vendor’s understanding of the rule, so you know what to expect if they push a major platform update mid-contract.
- Get exit and data-migration terms in writing, including any fees, before signing — not after a dispute arises.
- Remember your own compliance duty doesn’t move. Even with an accredited vendor, keep your own invoice and sales-data records as if you were responsible for their accuracy directly — because you are.
Frequently asked questions #
What does RMC No. 110-2026 require of an e-invoicing service provider? #
Reported details indicate RMC No. 110-2026, issued around October 12-13, 2026, requires an Electronic Invoicing Service Provider (ESP) to obtain BIR accreditation for a specific invoicing solution before processing any taxpayer’s live transactions through it, with that accreditation valid for five years subject to annual review and renewal at least 60 days before expiration.
Can an ESP demonstrate or test its solution before getting accredited? #
Yes, reportedly. Coverage of RMC No. 110-2026 indicates an ESP may conduct disclosed demonstrations and controlled pre-production testing before accreditation, but it cannot process a taxpayer’s actual live transactions through that solution until the BIR issues the required Electronic Invoicing Solutions Accreditation Certificate.
Does using an accredited e-invoicing provider shift compliance responsibility away from the taxpayer? #
No. Using an accredited provider doesn’t shift a taxpayer’s own responsibility for accurate invoices, records, and tax payments. The provider’s accreditation addresses whether its platform is fit to handle e-invoicing data; it doesn’t substitute for the taxpayer’s own duty to issue correct invoices and file correct returns.
Is choosing an EIS service provider the same as choosing an EIS-compliant POS system? #
No — these are two different accreditation tracks covering different vendors. A Sales Data Transmission System (SDTS) or POS vendor is accredited under Revenue Memorandum Order No. 24-2023 for transmitting sales data. An Electronic Invoicing Service Provider under RMC No. 110-2026 is a separate category of third-party platform that helps a taxpayer issue and transmit electronic invoices under the broader EIS framework established by RR No. 8-2022.
Summary #
RMC No. 110-2026 reportedly closes a real gap in the EIS framework by requiring third-party e-invoicing platforms, not just taxpayers, to clear a specific BIR accreditation before going live — complete with a five-year validity period, annual review, and documented exit terms. None of that removes the taxpayer’s own responsibility for its invoices and records; it adds a vendor-side check on top. A business shopping for an e-invoicing provider should verify accreditation for the exact solution being deployed, not take a general compliance claim at face value. See BIR Electronic Invoicing System (EIS) Explained for the underlying mandate and How to Choose an EIS-Compliant POS or Sales Data Transmission System for the related POS/SDTS accreditation track.
Sources: This post relies on corroborated secondary reporting on RMC No. 110-2026 from multiple independent tax-alert and business-press outlets (including Grant Thornton, Sunstar, and Inquirer Business), since this site could not reach the BIR’s CDN directly to verify the circular’s primary text. Confirm specific requirements and dates against the official BIR issuance.