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RMC No. 99-2026: BIR Extends the Registration Seal Badge Deadline to October 31, 2026

·7 mins
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Revenue Memorandum Circular (RMC) No. 99-2026, dated July 22, 2026 and published by the BIR on September 24, 2026, gives online sellers, merchants, and other taxpayers covered by the BIR Registration Seal Badge requirement until October 31, 2026 to display the badge without being penalized for being late. Miss that date, and non-display becomes penalizable again under the original rule. This is a deadline extension, not a new requirement — the badge mandate itself has existed since April 2026 under RMC No. 38-2026.

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What does RMC No. 99-2026 actually change? #

RMC No. 99-2026 does not introduce a new compliance obligation — it resets the enforcement clock on an existing one. The requirement to display the BIR Registration Seal Badge has applied to online sellers, freelancers, and digital-economy taxpayers since RMC No. 38-2026 took effect on April 29, 2026. What RMC No. 99-2026 adds is a firm cutoff date, October 31, 2026, before which a taxpayer who has not yet posted the badge will not be penalized for the delay.

According to secondary reporting corroborating the circular’s content:

Post it by then and you won’t be penalized for being late. Miss that date, and non-display becomes penalizable again.

That framing — reported consistently across multiple secondary sources covering RMC No. 99-2026 — describes the mechanic in plain terms: compliance by October 31, 2026 clears any exposure for the months since the original badge requirement took effect; non-compliance after that date exposes a taxpayer to the same consequences that would have applied all along under RMC No. 38-2026. The BIR’s own PDF for RMC No. 99-2026 was not directly reachable at the time of this write-up (bir.gov.ph and bir-cdn.bir.gov.ph were unreachable from this environment), so the July 22, 2026 issuance date, the September 24, 2026 publication date, and the October 31, 2026 deadline are corroborated across independent secondary sources rather than quoted from the BIR’s original PDF. Confirm the current text directly at the BIR’s Revenue Memorandum Circulars page before relying on a specific procedural detail for a filing decision.

Why did the BIR grant this grace period? #

RMC No. 99-2026 reads as the BIR setting a real enforcement date rather than leaving the original badge requirement open-ended. RMC No. 38-2026 mandated the badge in April 2026, and RMC No. 64-2026 clarified the ORUS generation steps in June 2026 for taxpayers with no pending Certificate of Registration (COR) updates — but neither circular fixed a hard date after which non-display would actually be penalized. RMC No. 99-2026 fills that gap: it draws a line at October 31, 2026, giving taxpayers who registered late, who were unaware of the requirement, or who simply had not gotten around to generating the badge, a defined runway to come into compliance before the BIR begins treating non-display as a penalizable lapse.

This is the same underlying population already covered by two earlier posts on this site:

RMC No. 99-2026 doesn’t change who is covered or how the badge is generated — it only changes when non-display starts costing a taxpayer something. See those two posts for the underlying “what” and “how”; this post covers the “by when.”

Worked example: an online seller who never got around to the badge #

Consider a home-based Shopee seller who read about the Registration Seal Badge requirement back in April 2026 but never generated or posted one — a common gap RMC No. 99-2026’s grace period is aimed at closing. Here is what that seller needs to do before October 31, 2026 to stay on the penalty-free side of the deadline:

  1. Confirm registration status first. The seller logs into ORUS and checks whether their Certificate of Registration is current — same registered name, address, RDO, and line of business as what’s on file with the BIR.
  2. Pick the right ORUS path. If nothing on the COR needs correction, the seller follows the RMC No. 64-2026 no-update path directly to the badge screen. If something is outdated (a moved address, an unlisted online-selling line of business), the seller files a Correction/Change/Update of Registration transaction first, which may carry the standard ₱30 documentary stamp tax.
  3. Generate and download the badge once ORUS processes the request — the badge itself remains free of charge.
  4. Post the badge before October 31, 2026 in the shop’s “About Shop” section, the same location earlier guidance on this site identifies as where the BIR expects it to appear on a Shopee storefront.
  5. Keep a dated record — a screenshot of the storefront showing the badge live, timestamped before the deadline — as the seller’s own evidence of timely compliance if the display status is ever questioned.

A seller who completes steps 1–4 by October 31, 2026 falls squarely within RMC No. 99-2026’s penalty-free window, even though the badge was months overdue against the original RMC No. 38-2026 timeline. A seller who does nothing loses that protection the moment the deadline passes.

What happens after October 31, 2026? #

Once the grace period lapses, the BIR’s position reverts to the original RMC No. 38-2026 posture: non-display of the Registration Seal Badge becomes penalizable again, without the temporary shield RMC No. 99-2026 provided. Available reporting on the circular does not specify a fixed peso penalty tied specifically to non-display — the badge sits alongside a taxpayer’s broader registration and filing obligations rather than carrying its own itemized fine schedule in the sources reviewed for this post. What is consistent across reporting is the mechanic itself: compliance is judged as of October 31, 2026, not as of the original April 2026 rollout date, and a taxpayer who is still not displaying the badge after that date is treated the same as if RMC No. 99-2026 had never been issued.

Practically, that means the safest reading for a taxpayer who has not yet posted the badge is to treat October 31, 2026 as a hard deadline, not a soft target — waiting past it forfeits the very relief RMC No. 99-2026 was issued to provide.

Frequently Asked Questions #

What is RMC No. 99-2026? #

Revenue Memorandum Circular No. 99-2026 is a BIR issuance, dated July 22, 2026 and published/circulated on September 24, 2026, that gives online sellers, merchants, and other taxpayers covered by the BIR Registration Seal Badge requirement until October 31, 2026 to display the badge without being penalized for being late.

What happens if I still don’t display the badge after October 31, 2026? #

Once the October 31, 2026 grace period under RMC No. 99-2026 lapses, non-display of the BIR Registration Seal Badge becomes penalizable again under the original requirement imposed by RMC No. 38-2026, the same as if the grace period had never been granted.

Do I need to do anything extra to get RMC No. 99-2026’s grace period? #

No separate application is required. The grace period under RMC No. 99-2026 applies automatically to covered taxpayers; the only action needed is to actually generate and display the Registration Seal Badge on your storefront or profile by October 31, 2026.

Is RMC No. 99-2026 a new registration requirement? #

No. RMC No. 99-2026 does not create a new obligation — the underlying requirement to display the BIR Registration Seal Badge was already imposed by RMC No. 38-2026 in April 2026. RMC No. 99-2026 only resets the enforcement clock, giving covered taxpayers a defined window to catch up before penalties apply.

How do I generate the BIR Registration Seal Badge? #

The badge is generated through a taxpayer’s BIR ORUS account, either as part of a registration-update transaction or, for taxpayers with no pending Certificate of Registration changes, through the more direct path introduced by RMC No. 64-2026.

Summary #

RMC No. 99-2026 does not change who must display the BIR Registration Seal Badge or how to generate it — it changes the enforcement timeline, giving covered taxpayers until October 31, 2026 to display the badge without being penalized for months of prior non-display. Miss that date, and the BIR’s original RMC No. 38-2026 enforcement posture applies as if no grace period had existed. If you haven’t generated your badge yet, treat this as the moment to do it: see BIR Registration Seal Badge: What Online Sellers and Freelancers Must Display for who’s covered and where to post it, and How to Generate Your BIR Registration Seal Badge in ORUS With No COR Updates for the fastest ORUS path if your registration details are already current.