RR No. 26-2025: BIR Extends E-Invoicing Compliance Deadline to December 31, 2026

Revenue Regulations (RR) No. 26-2025, issued by the Bureau of Internal Revenue (BIR) on September 5, 2025, extends the mandatory electronic invoicing (e-invoicing) compliance deadline for covered taxpayers to December 31, 2026. The regulation amends the transitory provisions of RR No. 11-2025, which had pointed covered groups toward a March 2026 go-live. The extra months are for system reconfiguration and transition — not a repeal of the e-invoicing mandate.

This guide maps who is in the December 31, 2026 cohort, who waits for later regulations, and what covered businesses should do with the extension. For how invoices replaced official receipts as the primary sales document under the Ease of Paying Taxes (EOPT) Act, see VAT Invoice vs Official Receipt under EOPT and the CREATE MORE Act incentives overview.

What did RR No. 26-2025 change? #

RR No. 26-2025 changes the clock, not the core e-invoicing rules. Covered taxpayers now have until December 31, 2026 to comply with the electronic invoicing requirements (issuance of electronic invoices) prescribed in RR No. 11-2025, which implements Sections 237 and 237-A of the Tax Code as amended by Republic Act No. 12066 (CREATE MORE).

According to firm digests of the regulation (including KPMG’s October 2025 tax newsflash), the prior RR No. 11-2025 timeline targeted compliance around March 14, 2026 for the first covered groups. RR No. 26-2025 recognizes the operational work needed to reconfigure systems and train staff. Secondary summaries also note that the Commissioner may grant further extensions if necessary.

Who must comply by December 31, 2026? #

The December 31, 2026 deadline applies to the first wave of taxpayers required to issue electronic invoices under RR No. 11-2025 as amended by RR No. 26-2025. Digests of the amended transitory section consistently list:

If your business sits in more than one row (for example, an LTS e-commerce seller using CAS), treat December 31, 2026 as the planning deadline for electronic invoice issuance capability.

Who is not yet on the December 2026 clock? #

RR No. 26-2025 reiterates that several groups will be mandated only after the BIR establishes a system capable of storing and processing the required invoice data, with separate future regulations setting their deadlines. Those later-wave categories commonly include:

• Taxpayers engaged in the export of goods and services (with stated exceptions under RR No. 11-2025)
• Registered Business Enterprises availing of tax incentives (with stated exceptions)
• Taxpayers using POS systems
• Other taxpayers as the Commissioner may later require

Electronic sales reporting obligations are likewise described as applying once the supporting system is ready, and firm alerts note that reporting will cover both head offices and branches when mandated. Do not confuse “deadline extended for wave one” with “optional forever for everyone else.”

What should covered businesses do with the extra time? #

Use the extension to finish system work and documentation — not to freeze planning until late 2026. Practical preparation steps:

1. Confirm whether you are in the December 31, 2026 cohort (e-commerce size class, LTS/large-taxpayer status, CAS/invoicing software use).
2. Map current invoice issuance (manual ATP invoices, POS, CAS) to the structured electronic invoice and transmission requirements in RR No. 11-2025 — a printable PDF alone is not the compliance end-state described in CREATE MORE e-invoicing digests.
3. Budget vendor, ERP, and staff-training work against a 2026 go-live buffer well before year-end.
4. Keep ordinary BIR compliance current while systems are upgraded — VAT, withholding, and DAT filings do not pause for e-invoicing projects. Tools such as BIR Online Tools can still handle certificate and alphalist workflows in parallel.

Frequently asked questions #

What is RR No. 26-2025? #

Revenue Regulations No. 26-2025, issued by the BIR on September 5, 2025, amends the transitory provisions of RR No. 11-2025 by extending the electronic invoicing compliance deadline for covered taxpayers to December 31, 2026.

What was the original e-invoicing deadline under RR No. 11-2025? #

Under RR No. 11-2025 (February 27, 2025), covered taxpayers were generally required to comply with electronic invoicing requirements by around March 14, 2026. RR No. 26-2025 moved that deadline to December 31, 2026.

Who must comply with e-invoicing by December 31, 2026? #

Covered groups include taxpayers engaged in e-commerce or internet transactions (excluding Micro taxpayers), taxpayers under the Large Taxpayers Service, large taxpayers under the Ease of Paying Taxes Act and RR No. 8-2024, and taxpayers using Computerized Accounting Systems or computerized books with electronic invoicing and other invoicing software, as summarized in RR No. 26-2025 and secondary digests of the regulation.

Does RR No. 26-2025 change what an electronic invoice must contain? #

No. The regulation extends the transition timeline; it does not rewrite the substantive electronic invoicing and sales-reporting requirements already set in RR No. 11-2025 under the Tax Code as amended by the CREATE MORE Act.

When must exporters and POS users switch to e-invoicing? #

Exporters, POS users, registered business enterprises availing of tax incentives, and certain other groups will be required to issue electronic invoices once the BIR establishes a system capable of storing and processing the required data, with deadlines to be set in separate future revenue regulations.

Summary #

RR No. 26-2025 buys covered taxpayers until December 31, 2026 to issue electronic invoices under RR No. 11-2025 — it does not cancel CREATE MORE’s e-invoicing framework. Confirm whether you are in the first wave, treat exporters/POS/incentive RBEs as later-wave unless a new regulation says otherwise, and use the extension to finish real system work before the new year-end cliff.