What is RMC No. 112-2026?

Revenue Memorandum Circular No. 112-2026, issued by the BIR on October 22, 2026, clarifies the implementation of Revenue Regulations No. 6-2026 and extends the transition period for businesses to add a separate creditable withholding tax (CWT) line to their sales invoices.

What are the new deadlines under RMC No. 112-2026?

Taxpayers using computerized accounting systems or other electronic invoicing/reporting systems already covered by mandatory e-invoicing have until December 31, 2026 to add the CWT line, unless the BIR prescribes a later date. Taxpayers using cash register machines, point-of-sale systems, or other systems not yet covered by mandatory e-invoicing have until March 31, 2027, subject to any earlier date the BIR may later set.

Can a business keep using its existing printed invoices in the meantime?

According to press coverage of the circular, taxpayers may continue using remaining manual or loose-leaf invoice stock until fully consumed, and businesses whose systems are not yet updated may manually annotate the CWT information on invoices in the interim rather than waiting for a system upgrade.

Does omitting the CWT line make an invoice invalid for input VAT or deduction purposes?

Secondary reporting on the circular (via Manila Bulletin) states that omitting a withholding tax entry does not, by itself, invalidate an invoice or automatically disqualify the related input VAT credit or expense deduction, provided the other legal invoicing requirements are met — though taxpayers should confirm this against the circular's own text before relying on it for a specific transaction.

Does adding the CWT field require re-accrediting a CAS or POS system?

Press coverage describes system changes made solely to add CWT information as a limited or minor system change that does not, on its own, require new CAS/POS registration or accreditation, as long as the modification doesn't materially affect the system's core functions. Confirm the exact scope of this carve-out against the circular's own text before relying on it.

RMC No. 112-2026: BIR Extends the Deadline to Show Withholding Tax on Invoices

Revenue Memorandum Circular (RMC) No. 112-2026, issued by the BIR on October 22, 2026, gives businesses more time to comply with the new rule requiring creditable withholding tax (CWT) to be shown as a separate line on sales invoices. Covered electronic invoicing and reporting systems now have until December 31, 2026, and other invoicing systems — cash registers, POS machines, and similar setups not yet mandated to e-invoice — have until March 31, 2027, to add the CWT field, easing the compliance timeline originally set under Revenue Regulations (RR) No. 6-2026.

This guide explains what changed, what stays the same, and where it fits alongside the original invoicing rule. For the underlying mechanics of the CWT-on-invoice requirement itself, see RR No. 6-2026: Creditable Withholding Tax on Invoices and RR No. 6-2026 and the Electronic Invoicing System.

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What does RMC No. 112-2026 actually extend? #

RMC No. 112-2026 doesn’t change the underlying substantive rule in RR No. 6-2026 — invoices must still eventually show the CWT amount when applicable — it extends how long businesses have to get their invoicing systems ready to do it. Multiple contemporaneous reports (BusinessWorld, Manila Bulletin, Grant Thornton, Tribune) describe the circular, issued October 22, 2026, as a direct response to businesses flagging that their point-of-sale, accounting, and e-invoicing systems needed more lead time to add a CWT field correctly rather than risk showing the wrong amount.

The two-track deadline structure tracks the Electronic Invoicing System (EIS) rollout already covered on this site:

Taxpayer category	New CWT-line deadline
Computerized accounting systems and other electronic invoicing/reporting systems covered by mandatory e-invoicing	December 31, 2026 (unless the BIR sets a later date)
Cash register machines, POS systems, and other systems not yet covered by mandatory e-invoicing	March 31, 2027 (subject to any earlier date the BIR may later prescribe)

What can a business do while its system is being updated? #

In the interim before a system upgrade is complete, press coverage of the circular describes two practical options: keep using existing manual or loose-leaf invoice stock until it runs out, or manually annotate the CWT amount on invoices issued in the meantime. Several outlets (BusinessWorld, Manila Bulletin) also report that a system modification made solely to add the CWT field is treated as a limited system change, and does not by itself trigger a fresh CAS/POS re-accreditation requirement — though the circular’s own text should be checked for the precise scope of that carve-out before a business relies on it to skip a planned system review.

BusinessWorld’s and Tribune’s reporting on the circular both describe this carve-out using the same term:

“limited system changes”
— as BusinessWorld and Tribune.net.ph both characterize the CWT-related system modification RMC No. 112-2026 allows without triggering fresh CAS/POS accreditation

Manila Bulletin’s own coverage uses “minor changes” instead. Because these are secondary characterizations of the circular rather than a direct quotation of its operative legal text, a business planning a system change on the strength of this carve-out should confirm the exact wording against the circular itself or a tax advisor before treating a larger modification as “limited.”

What this means for a business with a near-term deadline #

A restaurant chain running a mandatory-e-invoicing POS network, for example, now has until December 31, 2026 rather than an earlier date to confirm its system correctly itemizes CWT on every qualifying invoice — but should not treat the extension as a reason to delay testing, since any system change still needs to be verified against real transactions before the new deadline arrives. A sari-sari store or small retailer still issuing manual receipts, by contrast, falls under the March 31, 2027 track and can continue annotating by hand in the meantime.

Either way, the invoicing requirement itself traces back to RR No. 6-2026’s core rule that CWT, where applicable, must be separately identified on the invoice — RMC No. 112-2026 only moves the compliance date for showing it correctly, it does not remove the obligation.

Summary #

RMC No. 112-2026 gives taxpayers more runway to add a separate creditable withholding tax line to their invoices under RR No. 6-2026 — December 31, 2026 for systems already covered by mandatory e-invoicing, and March 31, 2027 for other invoicing systems — while allowing continued use of existing invoice stock and manual annotation in the interim. See RR No. 6-2026: Creditable Withholding Tax on Invoices for the underlying rule this circular extends, and RR No. 6-2026 and the Electronic Invoicing System for how it interacts with mandatory e-invoicing.