RMC No. 113-2026: BIR Suspends the Mandatory Registration Seal Badge Display

Revenue Memorandum Circular (RMC) No. 113-2026, dated October 26, 2026, suspends the mandatory display of the BIR Registration Seal Badge until further notice — lifting the October 31, 2026 compliance deadline that RMC No. 99-2026 had set just weeks earlier. For now, no online seller, freelancer, or other covered taxpayer has to display the badge, and the BIR has said no penalty will attach solely for not displaying it during the suspension.

This post covers what RMC No. 113-2026 actually suspends, why the BIR issued it, and what a taxpayer who was racing toward the October 31 deadline should do now. For the badge requirement’s original scope, see BIR Registration Seal Badge: What Online Sellers and Freelancers Must Display, and for the deadline this circular supersedes, see RMC No. 99-2026: BIR Extends the Registration Seal Badge Deadline.

What does RMC No. 113-2026 actually suspend? #

RMC No. 113-2026 suspends the entire mandatory display requirement built up across three prior circulars — not just the deadline, but the obligation itself — until the BIR issues further notice. The Registration Seal Badge was introduced under RMC No. 38-2026 on April 29, 2026, with implementation details added by RMC No. 64-2026 and a compliance deadline most recently set at October 31, 2026 by RMC No. 99-2026. RMC No. 113-2026 reaches back and suspends all of that at once.

News coverage of the circular quotes BIR Commissioner Charlito Martin Mendoza directly on the practical consequence for taxpayers who haven’t displayed the badge:

“No penalties shall be imposed solely on account of non-display of the BIR Registration Seal Badge during the period of suspension.”

Source: Commissioner Mendoza, as quoted in contemporaneous Philippine news coverage of RMC No. 113-2026 (this site was unable to reach the BIR’s own PDF of the circular directly to re-verify the exact wording against the primary text — confirm against the official issuance before relying on this for a formal compliance position).

Why did the BIR suspend a requirement it had just extended? #

Multiple independent news outlets attribute the suspension to data privacy and technical concerns raised by the online sellers, content creators, and other taxpayers the badge requirement covers, plus pressure from lawmakers for a pause. The badge is a QR-coded image tied to a taxpayer’s registration details, posted on a storefront, social media page, or website — and critics reportedly raised concerns both about what the QR code exposes and about technical glitches in generating it correctly.

Coverage attributes this explanation directly to the Commissioner:

“We have heard the concerns of online sellers, content creators, and other taxpayers regarding data privacy, technical issues, and the scope of the BIR Registration Seal Badge requirement.”

Separately, senators are reported to have pressed the BIR over the badge requirement’s privacy implications before the suspension was announced. None of this site’s sources suggest the underlying registration or Certificate of Registration (COR) requirements changed — only the badge display mandate.

What should a taxpayer who was about to display the badge do now? #

A taxpayer who was racing to meet the October 31 deadline can stand down from that specific deadline, but should not treat this as the end of BIR compliance attention on the digital-economy sector. A few practical points:

1. No display deadline currently applies. There is nothing to file or post by a specific date for the seal badge itself while the suspension is in effect.
2. A badge already posted can stay up. RMC No. 113-2026 doesn’t require removing a badge generated and displayed under the earlier circulars — voluntary display is still allowed.
3. Watch for the BIR’s “further notice.” The suspension is not a repeal; the BIR can reinstate a display requirement and a new deadline later, likely with a fresh RMC.
4. Keep the underlying registration current regardless. The seal badge was always a display of existing registration data, not a substitute for it — a current Certificate of Registration, correct RDO, and up-to-date books and receipts obligations are untouched by this suspension.
5. Don’t let the pause distract from filings that are still due. RELIEF, SAWT, QAP, and BIR Form 2307/2316 deadlines continue on their normal schedule regardless of what happens with the seal badge.

Frequently asked questions #

Is the BIR Registration Seal Badge still required after RMC No. 113-2026? #

No, not for now. RMC No. 113-2026, dated October 26, 2026, suspends the mandatory display requirement introduced under RMC No. 38-2026 (as supplemented by RMC Nos. 64-2026 and 99-2026) until further notice. Taxpayers may still display the badge voluntarily, but nothing requires them to.

What happened to the October 31, 2026 seal badge deadline? #

It no longer applies for now. RMC No. 99-2026 had extended the display deadline to October 31, 2026. RMC No. 113-2026 suspends that compliance deadline along with the underlying display requirement itself, so there is currently no date by which a taxpayer must display the badge.

Will a business be penalized for not displaying the seal badge right now? #

No. The BIR has stated that no penalties will be imposed solely for non-display of the Registration Seal Badge during the suspension period. This removes the exposure under Section 275 of the NIRC and the BIR’s compromise penalty schedule that applied once the prior October 31 grace period was set to lapse.

Why did the BIR suspend the seal badge requirement? #

News coverage attributes the suspension to data privacy and technical concerns raised by online sellers, content creators, and other affected taxpayers, along with pressure from lawmakers for a pause. BIR Commissioner Charlito Martin Mendoza is reported to have cited these concerns in announcing the suspension.

Should a taxpayer take down a badge they already generated and posted? #

RMC No. 113-2026 only lifts the mandatory requirement — it does not require taking an already-displayed badge down. A taxpayer who already generated and posted the badge under RMC No. 38-2026 or RMC No. 64-2026 may simply leave it as is, since voluntary display remains permitted.

Summary #

RMC No. 113-2026 suspends, indefinitely and until further notice, the Registration Seal Badge display requirement that RMC No. 38-2026 created and RMC No. 99-2026 had just extended to October 31, 2026 — and the BIR has said no penalty applies for non-display during the suspension. This is a pause, not a repeal: taxpayers should expect the BIR to revisit the requirement later, likely addressing the data-privacy and technical concerns that news coverage says drove the suspension. Everything else about BIR registration — the Certificate of Registration, RDO assignment, and ordinary filing deadlines — continues unaffected. For background on the badge itself, see BIR Registration Seal Badge: What Online Sellers and Freelancers Must Display and How to Generate Your BIR Registration Seal Badge in ORUS.

Sources: Contemporaneous Philippine news coverage of RMC No. 113-2026 (October 26, 2026), including reporting that quotes BIR Commissioner Charlito Martin Mendoza; this site could not reach the BIR’s own CDN to verify the circular’s exact text directly and relies on multiple independent news reports that corroborate the date, number, and substance of the suspension.