RMC No. 112-2026: BIR Extends the Withholding Tax Invoice Deadline to December 31, 2026 or March 31, 2027

BIR Revenue Memorandum Circular (RMC) No. 112-2026, issued around October 22, 2026, extends the deadline for actually showing creditable withholding tax (CWT) as a separate invoice line under RR No. 6-2026. Instead of the regulation’s October 16, 2026 effectivity date applying to everyone immediately, businesses on covered computerized or electronic invoicing systems now have until December 31, 2026, while businesses on cash register machines, point-of-sale systems, or manual and loose-leaf invoices have until March 31, 2027.

This post covers RMC No. 112-2026 specifically — the extended compliance dates. For the underlying content requirement itself, see RR No. 6-2026: Invoices Must Now Show Creditable Withholding Tax as a Separate Item, and for how the rule reaches electronic invoices, see RR No. 6-2026 and the BIR Electronic Invoicing System: Where Does the Withholding Tax Line Appear on an E-Invoice?. RMC No. 112-2026 does not change what either post describes about the invoice content rule — it changes when a taxpayer actually has to have it working.

Why did the BIR issue RMC No. 112-2026? #

RMC No. 112-2026 responds to a timing problem: RR No. 6-2026 took effect October 16, 2026, but many businesses could not reprogram invoicing systems, reprint stock, or update point-of-sale software that fast. Revenue Regulations (RR) No. 6-2026 amended Section 6(B) of RR No. 7-2024 to add a new mandatory invoice item — the CWT amount, if applicable, shown as a separate line — and that regulation took effect 15 days after publication, on October 16, 2026. News coverage of RMC No. 112-2026 reports that the circular was issued to give taxpayers more time to adjust their systems rather than enforce the line-item requirement from day one of the regulation’s effectivity.

Multiple outlets covering the circular frame it the same way: a relief measure, not a reversal. The Daily Tribune reported that the BIR “extends deadlines for new CWT invoicing rules,” and Grant Thornton’s tax alerts on the underlying regulation likewise describe a transition period rather than an immediate, universal cutover.

What are the extended compliance dates under RMC No. 112-2026? #

RMC No. 112-2026 sets two different compliance dates depending on the taxpayer’s invoicing system, not one blanket deadline. Taxpayers using computerized accounting systems, computerized books of accounts, or other invoicing systems covered by the BIR’s mandatory electronic invoicing requirement must incorporate the CWT line-item functionality by December 31, 2026, unless the BIR prescribes a later date. Taxpayers using cash register machines, point-of-sale systems, or manual and loose-leaf invoices not yet covered by mandatory electronic invoicing have until March 31, 2027.

During the transition window, taxpayers keep using their currently registered invoicing systems. For a transaction on which CWT applies, the withholding phrase and amount must still be stamped, printed, or legibly written on the invoice before it is issued — the extension defers the system upgrade, not the obligation to disclose the withholding amount by some means.

What does “Less: Withholding Tax” mean for invoices still in use? #

The transitional phrase tying RR No. 6-2026 to day-to-day invoicing is “Less: Withholding Tax,” which taxpayers stamp, print, or write on the invoice while their systems catch up to the new line-item requirement. This phrase comes from RR No. 6-2026’s own transitory provision for unused invoice stock, and secondary reporting on the compliance-date extension describes the same mechanic continuing to apply during the RMC No. 112-2026 transition period.

“All unused or unissued invoices existing as of the effectivity date of these Regulations may continue to be used by taxpayers until fully consumed, provided that the phrase ‘Less: Withholding Tax’ is stamped conspicuously on the face of the invoice. Thereafter, all newly printed invoices shall reflect the same phrase prior to its use.”

Source: Section 3, RR No. 6-2026, as quoted in RR No. 6-2026: Invoices Must Now Show Creditable Withholding Tax as a Separate Item. Note that this exact sentence is from RR No. 6-2026 itself, not from RMC No. 112-2026’s own text — this site has not located the full text of RMC No. 112-2026 to confirm whether the circular repeats, cross-references, or restates this specific wording. Secondary reports on the circular describe the same stamping mechanic continuing during the extended transition, which is consistent with how RR No. 6-2026 already handles invoice stock on hand.

Worked example: two businesses, two deadlines #

A worked example shows why the same rule produces two different deadlines: the controlling fact is which invoicing system a business runs, not its size or industry. The figures and business names below are fictional, for illustration only.

Business A — a mid-sized trading company on a computerized accounting system (CAS) certified for mandatory electronic invoicing. Because its invoicing software falls under the BIR’s mandatory EIS coverage, Business A must have its system generating the CWT line item correctly by December 31, 2026. Until then, when it bills a client that is a withholding agent — say, ₱100,000 of goods subject to 1% CWT — its system-generated invoice should still carry a “Less: Withholding Tax” line manually stamped or printed for ₱1,000 while the software update is pending.

Business B — a sari-sari-style retailer using a single cash register machine (CRM), not yet enrolled in mandatory electronic invoicing. Because Business B’s invoicing system is a CRM outside mandatory EIS coverage, it falls under the later March 31, 2027 date. If Business B occasionally issues a manual invoice to a corporate buyer who must withhold — for example, ₱20,000 of supplies at a 1% CWT rate — it stamps “Less: Withholding Tax (₱200.00)” on that invoice now, and has until March 31, 2027 to have its invoicing setup handle the line item on a standing basis.

Both businesses are already expected to disclose the withholding amount by some means today; what the extended dates give them is time to get their systems — not their disclosure obligation — into final compliance.

Does the invoice line apply to every transaction? #

No — RR No. 6-2026’s text ties the requirement to transactions where creditable withholding tax actually applies, not to every invoice a seller issues. The amended provision reads “The amount of Creditable Withholding Tax, if applicable, shall be shown as a separate item,” and “if applicable” means the line is relevant specifically to transactions on which the buyer or payor is a withholding agent required to withhold. A retail sale to an ordinary consumer, with no withholding obligation on either side, does not need a CWT line. The extended dates under RMC No. 112-2026 govern when a taxpayer’s system must be able to produce that line for transactions where it is applicable — they do not create a new requirement to show the line on transactions that never carried a withholding obligation in the first place.

What should a business do before its RMC No. 112-2026 deadline? #

1. Identify your invoicing system category. Confirm with your Revenue District Office or your Sales Data Transmission System vendor whether you fall under mandatory electronic invoicing (December 31, 2026) or another system such as CRM/POS or manual invoices (March 31, 2027).
2. Keep disclosing withholding amounts now. Stamp, print, or legibly write “Less: Withholding Tax” and the amount on invoices for transactions where the buyer must withhold, even before your system upgrade is finished.
3. Plan the system or template update early. Don’t wait until the month before your deadline — coordinate with your invoicing software provider or printer well ahead of December 31, 2026 or March 31, 2027.
4. Reconcile the invoice line against BIR Form 2307. The withholding amount shown on the invoice should match the amount that eventually appears on the BIR Form 2307 the payor issues. See the BIR Form 2307 hub for the certificate side of that reconciliation.
5. Watch for further BIR guidance. Both compliance dates are described as subject to a later date the BIR may still prescribe — confirm you’re working from the current deadline before your internal project plan locks in a date.

Frequently asked questions #

What is RMC No. 112-2026? #

RMC No. 112-2026 is a Revenue Memorandum Circular the BIR issued around October 22, 2026 that extends the compliance timeline for showing creditable withholding tax as a separate invoice line under RR No. 6-2026, instead of requiring every taxpayer to comply by the regulation’s October 16, 2026 effectivity date.

Do I need to show withholding tax on my invoice by October 16, 2026? #

No, not in practice. RR No. 6-2026 itself took effect October 16, 2026, but RMC No. 112-2026 gives taxpayers on covered electronic invoicing or computerized systems until December 31, 2026, and taxpayers on other invoicing systems such as cash register machines, POS, or manual invoices until March 31, 2027, to complete the required changes.

Which deadline applies to a small business using a manual or loose-leaf invoice? #

A business issuing manual or loose-leaf invoices, or using a cash register machine or point-of-sale system not yet covered by mandatory electronic invoicing, falls under the later March 31, 2027 compliance date reported for RMC No. 112-2026.

Does RMC No. 112-2026 replace RR No. 6-2026? #

No. RMC No. 112-2026 does not change what RR No. 6-2026 requires on the face of the invoice. It only extends the date by which a taxpayer’s invoicing system must actually show that line, easing the original October 16, 2026 effectivity date.

Do I have to show a withholding tax line on every invoice I issue? #

RR No. 6-2026 requires the creditable withholding tax amount to be shown as a separate item on the invoice only where applicable, meaning the transaction is one on which the buyer or payor is required to withhold. An invoice for a sale with no withholding obligation does not need the line.

Summary #

RMC No. 112-2026 does not change what RR No. 6-2026 requires on a BIR invoice — the creditable withholding tax amount still has to appear as a separate item where applicable. What it changes is the timeline: instead of every taxpayer facing the regulation’s October 16, 2026 effectivity date, businesses on covered computerized or electronic invoicing systems now have until December 31, 2026, and businesses on cash register machines, point-of-sale systems, or manual invoices have until March 31, 2027. Both dates remain subject to any later date the BIR may still prescribe, and the underlying “Less: Withholding Tax” disclosure obligation continues in the meantime. For the regulation’s actual text and the printed-invoice stamping rule, see RR No. 6-2026: Invoices Must Now Show Creditable Withholding Tax as a Separate Item; for how the content rule reaches system-generated invoices, see RR No. 6-2026 and the BIR Electronic Invoicing System.

Sources: Daily Tribune, “BIR Extends Deadlines for New CWT Invoicing Rules,” October 23, 2026 (secondary, on RMC No. 112-2026’s extended compliance dates); Grant Thornton Philippines, “BIR Requires Creditable Withholding Tax to Be Shown Separately on Invoices” and Grant Thornton Philippines, “Invoices Must Now Disclose Creditable Withholding Tax” (secondary, corroborating RR No. 6-2026’s effectivity and transition mechanics); Revenue Regulations No. 006-2026, Bureau of Internal Revenue (primary, for the quoted stamping provision).