RMC No. 112-2026: Which CWT-on-Invoice Deadline Applies to Your Business?

RMC No. 112-2026, issued by the Bureau of Internal Revenue (BIR) on October 22, 2026, sets a tiered compliance deadline for the separate withholding-tax line that Revenue Regulations (RR) No. 6-2026 added to sales invoices. Businesses on a Computerized Accounting System (CAS) or another electronic invoicing system already covered by mandatory e-invoicing must add the line by December 31, 2026; businesses still on point-of-sale (POS), cash register, or other non-covered systems get until March 31, 2027.

What is RMC No. 112-2026 and why did the BIR issue it? #

RMC No. 112-2026 is the BIR’s clarifying circular for RR No. 6-2026, the regulation that requires creditable withholding tax (CWT) to appear as its own line item on a sales invoice whenever the transaction is subject to withholding. News coverage reported the circular was issued to ease an unusually tight implementation window — RR No. 6-2026 took effect just 15 days after its BIR website publication, leaving little time for businesses to reprogram invoicing systems or exhaust old invoice stock.

RR No. 6-2026 itself, and the mechanics of where the withholding line goes on an invoice, are covered in depth elsewhere on this site — see RR No. 6-2026: Invoices Must Now Show Creditable Withholding Tax as a Separate Item and RR No. 6-2026 and the BIR Electronic Invoicing System. This post focuses on what RMC No. 112-2026 changed on top of that rule: when each type of business actually has to comply, and what to do with invoice stock printed before the rule existed.

Which compliance deadline applies to your invoicing system? #

RMC No. 112-2026 splits compliance into two tracks based on what kind of invoicing system a business already runs, not on the business’s size or industry. The dividing line is whether that system is already covered by the BIR’s mandatory electronic invoicing rollout — if it is, the business gets less time, because it was already expected to be system-ready.

Both deadlines come from the same circular and were reported consistently across multiple outlets covering the BIR’s October 22, 2026 announcement, including Tribune and PAGEONE. As Tribune’s coverage of the circular put it:

“Businesses using computerized accounting systems, computerized books of accounts and other electronic invoicing systems covered by mandatory electronic invoicing must incorporate the required CWT functionality by 31 December 2026[; taxpayers] using existing cash register machines, point-of-sale systems and other invoicing systems not yet covered by mandatory electronic invoicing have until 31 March 2027.”

— as reported by Tribune, “BIR Extends Deadlines for New CWT Invoicing Rules,” October 23, 2026, summarizing RMC No. 112-2026 (October 22, 2026)

If your business doesn’t know which e-invoicing tier it falls under, check the BIR notice or Letter of Authority that originally enrolled you in the Electronic Invoicing System (EIS) — that enrollment, not your invoice format alone, is what decides your deadline.

A worked example: two businesses, two deadlines #

Business A — Meridian Home Furnishings (CAS-based retailer). Meridian runs a Computerized Accounting System integrated with its POS terminals and was already enrolled in the BIR’s mandatory e-invoicing program ahead of the December 31, 2026 structured e-invoice deadline. Under RMC No. 112-2026, Meridian must have its system add the separate withholding-tax line for any invoice subject to CWT — for example, a bulk office-furniture sale to a Top Withholding Agent client — by December 31, 2026, the same date, giving its IT vendor one combined deployment window instead of two.

Business B — Dela Cruz Hardware Supply (manual invoice booklets). Dela Cruz still issues pre-printed, government-registered manual invoice booklets and has never been part of the mandatory e-invoicing rollout. Under RMC No. 112-2026, Dela Cruz has until March 31, 2027 to transition. In the meantime, it keeps using its existing unused booklets — it does not need to throw them out or apply for a new Authority to Print — but for any sale where withholding applies, the cashier stamps the withholding tax phrase and the peso amount withheld directly onto the invoice by hand before handing it to the customer.

What transition relief applies to invoice stock you already printed? #

RMC No. 112-2026 lets a business keep using manual or loose-leaf invoices it already had printed before the rule took effect, rather than forcing an immediate reprint of every invoice booklet in the building. Existing unused stock may continue to be used until it is fully consumed, and a business does not need to surrender that stock or secure a new Authority to Print just because the pre-printed format has no dedicated withholding-tax box.

That relief comes with one condition that doesn’t disappear: for a transaction where CWT actually applies, the required withholding notation and amount must still be stamped, printed, or legibly written on the invoice before it is issued — the leftover stock is exempt from reprinting, not from disclosing the withholding tax itself. A new Authority to Print issued after RR No. 6-2026’s effectivity date must already build the separate CWT field into the invoice design; the leftover-stock relief only applies to invoices printed under an Authority to Print obtained before that date.

What is a “Limited System Change,” and why does it matter for CAS and POS users? #

A business updating its CAS or POS software to show the CWT line does not automatically have to go through the BIR’s full system re-registration or re-accreditation process. RMC No. 112-2026 reportedly classifies a system update made solely to add the CWT line item as a “Limited System Change,” a category that skips full re-accreditation as long as the update doesn’t materially affect the system’s other core functions — the invoicing, inventory, or accounting logic a business already has BIR sign-off on.

This distinction matters because CAS/POS re-accreditation is its own multi-week process involving test invoices and BIR review; a business that mistakenly files for full re-accreditation over a single added line item wastes time it doesn’t have against the December 31, 2026 deadline. If a planned update touches anything beyond the CWT line — a new module, a different invoice layout, a change to how VAT is computed — that broader change may fall outside the Limited System Change category and require the fuller process instead.

Who actually needs the withholding tax line on their invoice? #

Not every sales invoice needs a CWT line under either RR No. 6-2026 or RMC No. 112-2026 — the requirement is tied to whether the specific transaction is subject to withholding, not to the seller’s invoice format in general. A supplier selling to an ordinary walk-in customer, or to a buyer with no withholding obligation, issues the same invoice it always has.

The line is required only where the buyer or payor is legally obligated to withhold — commonly, a sale to a Top Withholding Agent buying goods or services from a regular supplier, which triggers the familiar 1% (goods) or 2% (services) creditable withholding tax under Revenue Regulations No. 11-2018. In that scenario, the invoice now has to show the withholding amount on its face, matching what the buyer will later report on the BIR Form 2307 it issues to the seller.

What should a business do before its deadline? #

1. Identify which tier applies. Confirm whether your invoicing system is already enrolled in mandatory e-invoicing (December 31, 2026) or not (March 31, 2027) by checking your EIS enrollment status with the BIR, not just your invoice’s physical format.
2. Inventory existing invoice stock. Count unused manual or loose-leaf invoices and plan whether to exhaust them under the transition relief or reprint early, especially if volume means the booklets won’t run out before the deadline anyway.
3. Loop in your POS/CAS vendor early. If a system update is needed, confirm with your vendor whether the change qualifies as a Limited System Change or triggers full re-accreditation, and get it scheduled well before the deadline rather than during the final weeks of December 2026.
4. Train staff on the manual stamp. For any business still relying on manual invoices in the interim, make sure whoever issues invoices knows which transactions require the withholding notation and amount, and has a stamp or standard annotation ready.
5. Reconcile against BIR Form 2307. Whatever appears on the invoice as withheld should match what eventually appears on the BIR Form 2307 certificate the buyer issues — a mismatch between the two is the kind of discrepancy a BIR desk audit is built to catch.

Frequently asked questions #

What is RMC No. 112-2026? #

RMC No. 112-2026 is a Revenue Memorandum Circular dated October 22, 2026, in which the Bureau of Internal Revenue (BIR) clarified how Revenue Regulations No. 6-2026 is actually rolled out. RR No. 6-2026 requires creditable withholding tax (CWT), where applicable, to appear as a separate line item on sales invoices; RMC No. 112-2026 sets the tiered compliance deadlines and transition relief businesses get to meet that requirement.

What is the BIR’s new deadline for showing withholding tax on invoices? #

Under RMC No. 112-2026, businesses using a Computerized Accounting System (CAS), computerized books of accounts, or another electronic invoicing system already covered by the BIR’s mandatory e-invoicing rules must add the CWT line by December 31, 2026. Businesses still using cash register machines, point-of-sale (POS) systems, or other invoicing systems not yet covered by mandatory e-invoicing have until March 31, 2027, unless the BIR sets an earlier date.

Can I keep using the manual invoices I already had printed before RR No. 6-2026? #

Yes. RMC No. 112-2026 lets businesses keep using existing unused manual or loose-leaf invoices until the stock is fully consumed, without surrendering the booklets or applying for a new Authority to Print solely because the pre-printed format has no dedicated withholding-tax field. Any invoice subject to withholding still needs the withholding tax phrase and amount stamped, printed, or legibly written on it before it’s issued.

Do I need new BIR accreditation just to add a withholding-tax line to my POS or CAS system? #

Generally no. RMC No. 112-2026 treats a system update made solely to incorporate the CWT line item as a “Limited System Change,” which does not by itself require new system registration or accreditation, as long as the change does not materially affect the system’s other core functions.

Does every sales invoice now need a withholding tax line? #

No. The separate CWT line only applies to a transaction where the buyer or payor is legally required to withhold tax from the payment — for example, a payment a Top Withholding Agent makes to a regular supplier. An invoice for a sale with no withholding obligation, such as an ordinary walk-in retail sale, doesn’t need the line at all.

What happens if I miss the December 31, 2026 or March 31, 2027 deadline? #

RMC No. 112-2026’s news coverage and the BIR’s own framing treat these dates as the outer limit for incorporating the CWT line into each system category, not a grace period with no consequence — missing it exposes a business to the same invoicing-deficiency and recordkeeping penalties that apply to any sales invoice that doesn’t carry information the BIR has made mandatory. Confirm your own exposure with a tax professional rather than assuming a blanket extension applies.

Summary #

RMC No. 112-2026 doesn’t change what RR No. 6-2026 requires — a separate withholding-tax line on invoices subject to CWT — it changes when each category of business has to get there. CAS and other mandatory-e-invoicing systems have until December 31, 2026; POS, cash register, and other non-covered systems have until March 31, 2027; and businesses on manual invoices can finish using existing stock under a stamped-notation workaround rather than reprinting everything overnight. The safest move before either date is to confirm which tier your invoicing system actually falls under, because the circular’s relief is tied to system category, not to business size or industry.