RMC No. 112-2026: The Compliance Deadline for Showing CWT on Your Invoice
Revenue Memorandum Circular (RMC) No. 112-2026, issued October 22, 2026, is the BIR’s implementing circular for Revenue Regulations (RR) No. 6-2026’s rule that an invoice must show creditable withholding tax (CWT) as a separate item — and it fills a gap the original regulation left open by clarifying the compliance mechanics and giving businesses additional time to update their invoicing systems. RR No. 6-2026’s own effectivity date was never confirmed on this site; RMC No. 112-2026 is the clarification that followed.
Reconcile Your Invoice Withholding Line Against a BIR Form 2307 FREE →This post picks up where RR No. 6-2026: Invoices Must Now Show Creditable Withholding Tax as a Separate Item left off, and covers what the implementing circular clarifies, what stays the same, and what sellers should check now.
What gap was RMC No. 112-2026 meant to close? #
RR No. 6-2026 added one requirement — a separate CWT line on the invoice — but left its own effectivity timing genuinely unclear, since sources disagreed on whether the regulation’s clock started from its BIR date stamp, its Department of Finance approval date, or its Records Management Division receipt date. This site’s earlier coverage of RR No. 6-2026 flagged exactly that gap:
“This site has not confirmed the exact publication date, so it does not state a calendar effectivity date.”
RMC No. 112-2026 is the BIR’s own follow-up addressing that uncertainty. Tax-alert coverage of the circular reports that it was issued specifically to clarify how RR No. 6-2026 is implemented and to give businesses more runway to update invoicing systems — rather than leaving taxpayers to guess at an effectivity date from conflicting document stamps.
| Document | Date | What it does |
|---|---|---|
| RR No. 6-2026 | BIR date stamp Aug. 25, 2026; published on BIR website per reports around Oct. 1, 2026 | Adds the CWT-as-separate-item requirement to invoice content |
| RMC No. 112-2026 | Oct. 22, 2026 | Clarifies implementation and gives additional time to update invoicing systems |
This site could not reach the BIR’s CDN directly to pull RMC No. 112-2026’s exact text, so the description above reflects corroborated reporting from multiple tax and business publications rather than a verified primary-source quote of the circular itself — confirm the specific compliance date against the official issuance before relying on it for a filing position.
What does RMC No. 112-2026 confirm about unused invoice stock? #
The circular reaffirms the same transition allowance RR No. 6-2026 already set out, rather than replacing it: unused or unissued invoices in stock when the rule takes effect can still be used until fully consumed, as long as the phrase “Less: Withholding Tax” is stamped conspicuously on the invoice face. The operative transition language, from RR No. 6-2026 itself, remains the governing text:
“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, Revenue Regulations No. 6-2026, as quoted in this site’s earlier coverage of RR No. 6-2026, where it was pulled directly from the BIR’s published PDF. News coverage of RMC No. 112-2026 reports that the circular’s main practical addition is extra lead time for businesses still updating invoicing software and templates to show the new line, rather than a change to this stamping mechanic.
What should sellers and buyers check now? #
With an implementing circular in place, the open question shifts from “when does this even start” to “is our invoicing actually compliant yet.” Practical steps:
- Confirm your invoice template or system already shows a CWT line for transactions where withholding applies — the line called for is a number, not just a note folded into the description.
- Stamp remaining unused invoice stock with “Less: Withholding Tax” if it will still be issued after the rule’s effectivity, rather than discarding usable booklets.
- Check your electronic invoicing system if you’re enrolled in the BIR’s Electronic Invoicing System (EIS) — see RR No. 6-2026 and the BIR Electronic Invoicing System for how the withholding line interacts with e-invoice schemas.
- Reconcile the invoice’s CWT figure against the BIR Form 2307 you issue or receive for the same transaction, since the two are separate documents that should state the same withheld amount.
- Don’t treat RMC No. 112-2026 as changing who is covered — only the compliance mechanics and timeline moved; the underlying obligation from RR No. 6-2026 and RR No. 7-2024 did not.
Frequently asked questions #
What does RMC No. 112-2026 add to RR No. 6-2026? #
RMC No. 112-2026, issued October 22, 2026, is the implementing circular for Revenue Regulations No. 6-2026’s requirement that an invoice show the amount of creditable withholding tax (CWT), if applicable, as a separate item. News coverage reports that it clarifies how the disclosure rule applies and gives businesses additional time to update their invoicing systems, after RR No. 6-2026 itself left its own effectivity date unclear.
Does RMC No. 112-2026 change who has to show CWT on an invoice? #
No. The underlying scope is still set by RR No. 6-2026 and the invoice-content rules of RR No. 7-2024 — any seller issuing a BIR invoice on a transaction where creditable withholding tax applies must show the withheld amount as a separate item. RMC No. 112-2026 clarifies the compliance mechanics and timeline, not who is covered.
Can I still use my old invoice stock after RMC No. 112-2026? #
Yes, under the same transition rule RR No. 6-2026 already set: unused or unissued invoices in stock may continue to be used until fully exhausted, provided the phrase “Less: Withholding Tax” is stamped conspicuously on the face of the invoice. News coverage of RMC No. 112-2026 reports that the circular reaffirms this allowance while giving businesses more time to update their systems going forward.
Does the invoice CWT line replace BIR Form 2307? #
No. Neither RR No. 6-2026 nor RMC No. 112-2026 changes who issues BIR Form 2307 or when. The invoice line is a second, parallel disclosure of the same withheld amount — the withholding agent still issues the Certificate of Creditable Tax Withheld at Source to the payee as proof of the tax withheld.
Summary #
RMC No. 112-2026 is the clarifying circular RR No. 6-2026 needed: it addresses the compliance mechanics and gives businesses more time to update invoicing systems, while reaffirming the same “Less: Withholding Tax” stamping allowance for unused stock that the regulation itself already set out. It does not expand or narrow who must show creditable withholding tax on an invoice, and it does not touch BIR Form 2307. For the underlying rule, see RR No. 6-2026: Invoices Must Now Show Creditable Withholding Tax as a Separate Item; for how it interacts with e-invoicing, see RR No. 6-2026 and the BIR Electronic Invoicing System.
Sources: Revenue Regulations No. 6-2026 (BIR, quoted directly from its published PDF in this site’s earlier coverage); tax-alert and business-press reporting on RMC No. 112-2026 (October 22, 2026), corroborated across multiple independent outlets. This site could not reach the BIR’s CDN directly to re-verify RMC No. 112-2026’s exact text.