Still Haven't Displayed Your BIR Registration Seal Badge? What to Do Before October 31, 2026

A taxpayer who still hasn’t displayed the BIR Registration Seal Badge needs to do two things before October 31, 2026: confirm their Certificate of Registration (COR) details are current in ORUS, then generate and post the badge — because Revenue Memorandum Circular (RMC) No. 99-2026’s grace period only protects a taxpayer who is actually compliant by that date. After October 31, 2026, non-display reverts to being penalizable under the original RMC No. 38-2026 requirement, with the BIR’s general registration-violation framework — Section 275 of the NIRC and its compromise penalty schedule — as the applicable exposure once the shield lifts.

Who still needs to act before October 31, 2026? #

Anyone covered by the badge requirement who has not yet generated and posted the BIR Registration Seal Badge on every required platform is still exposed, regardless of how long they’ve been registered or how minor their online selling activity is. Run through this before assuming you’re covered:

• You sell through a digital or electronic platform — e-commerce marketplace, your own website, or a social media shop — and have not uploaded the badge to that storefront’s designated display area.
• You generated the badge once but never actually posted it on every platform you sell through, not just one.
• You’re unsure whether your COR is current, which determines whether you qualify for the faster RMC No. 64-2026 no-update path or need to file a correction first.
• You assumed the April 2026 deadline under RMC No. 38-2026 had already passed you by and did nothing since, not realizing RMC No. 99-2026 reopened a compliance window through October 31, 2026.

If any of those describes you, treat October 31, 2026 as the operative deadline — not a soft target.

Step-by-step: getting compliant in ORUS before the deadline #

The fastest path depends entirely on whether your Certificate of Registration already needs no changes — a taxpayer with a current COR skips the update transaction entirely, while one with outdated details must correct the record first. In outline:

1. Log into ORUS and review the registered name, address, RDO, and line of business currently on file.
2. If nothing needs correction, follow the RMC No. 64-2026 no-update path directly to the badge-generation screen — see How to Generate Your BIR Registration Seal Badge in ORUS With No COR Updates for the full walkthrough.
3. If something is outdated — a moved address, an unlisted online-selling line of business — file a Correction/Change/Update of Registration transaction first under the RMC No. 38-2026 process; this step generally carries the standard ₱30 documentary stamp tax.
4. Generate and download the badge once ORUS processes the request.
5. Post the badge on every platform you sell through — marketplace “About Shop” sections, your own website, and social media storefronts alike, not just the first one you update.
6. Screenshot the live result, dated before October 31, 2026, as your own compliance record.

For who is covered and exactly where the badge must appear, see BIR Registration Seal Badge: What Online Sellers and Freelancers Must Display Under RMC No. 38-2026.

What does “penalizable again” under RMC No. 99-2026 actually mean? #

RMC No. 99-2026’s relief is a temporary shield, not a repeal — once October 31, 2026 passes without the badge displayed, the BIR’s position reverts to treating non-display exactly as if the grace period had never existed. Secondary reporting on the circular frames the mechanic plainly:

“Taxpayers who have not yet displayed the BIR Registration Seal Badge shall be given until October 31, 2026 to fully comply with the said requirement, without the imposition of penalties arising solely from the non-display thereof.”

That framing, corroborated across multiple outlets covering RMC No. 99-2026 (including Manila Times and BusinessWorld reporting on the circular), draws a hard line at the specific act — non-display — rather than granting blanket amnesty on any other registration issue a taxpayer might separately have. Compliance by October 31, 2026 clears exposure tied specifically to not having posted the badge; missing that date restores it.

What penalty framework actually applies to non-display? #

Neither RMC No. 38-2026 nor RMC No. 99-2026 publishes a fixed peso amount tied specifically to badge non-display, so the honest answer is that non-display falls under the BIR’s general registration-violation framework rather than a badge-specific fine schedule. That framework starts with Section 275 of the NIRC, the catch-all penalty provision for Tax Code or regulation violations that carry no penalty of their own:

“Any person who violates any provision of this Code or any rule or regulation promulgated by the Department of Finance, for which no specific penalty is provided by law, shall, upon conviction for each act or omission, be punished by a fine of not more than One thousand pesos (₱1,000) or suffer imprisonment of not more than six (6) months, or both.”

— Section 275, National Internal Revenue Code (as amended)

In practice, the BIR resolves most registration-display violations administratively through its compromise penalty schedule rather than criminal prosecution. Revenue Memorandum Order (RMO) No. 7-2015’s Revised Schedule of Compromise Penalties lists a ₱1,000 compromise amount for failure to display a Certificate of Registration (BIR Form No. 2303) — the closest existing analog, since the Registration Seal Badge functions as the digital-economy successor to posting a physical COR. Whether the BIR applies that same figure to badge non-display specifically has not been confirmed in available reporting on RMC No. 99-2026, so treat ₱1,000 as the general order of magnitude the existing framework points to, not a confirmed badge-specific amount.

How would the BIR actually catch non-display? #

For a brick-and-mortar business, the BIR’s usual enforcement tool for registration-display violations is tax mapping — unannounced inspection visits sometimes called Oplan Kandado — but an online-only seller’s storefront is inspected differently, by BIR personnel or automated monitoring reviewing the platform itself rather than a physical premises visit. Tax mapping inspections check registration, invoicing, and bookkeeping compliance at a business location and can result in compromise penalties ranging from roughly ₱1,000 to ₱50,000 depending on the violation, with more serious cases risking temporary closure under NIRC Section 115. For a purely online seller, the equivalent check is a review of the storefront or profile page itself — which is precisely why the badge requirement is built around digital display rather than a posted physical certificate.

Worked example: a seller who does nothing by October 31 #

Consider a home-based online seller who read about the badge requirement back in April 2026, generated nothing, and still has not acted as October 31, 2026 approaches. Two outcomes branch from that single date:

The only difference between the two outcomes is whether the badge was actually live before the deadline — not intent, not awareness, not how long either seller has been registered.

Frequently asked questions #

I still haven’t displayed my BIR Registration Seal Badge. What’s the first thing I should do? #

Log into ORUS and check whether your Certificate of Registration details — registered name, address, RDO, and line of business — are current. That determines whether you can use the direct RMC No. 64-2026 badge-generation path or must first file a registration-update transaction under RMC No. 38-2026.

Is there a specific peso penalty for not displaying the BIR Registration Seal Badge? #

RMC No. 99-2026 and the earlier badge circulars do not publish a fixed peso penalty specifically tied to non-display of the badge. The general framework that applies to unaddressed BIR registration-display violations is Section 275 of the NIRC — a fine of not more than ₱1,000, imprisonment of not more than six months, or both — administered in practice through the BIR’s compromise penalty schedule rather than criminal prosecution for most first-time cases.

Does the October 31, 2026 deadline apply to every online seller? #

RMC No. 99-2026’s grace period applies to online sellers, merchants, and other taxpayers already covered by the badge requirement under RMC No. 38-2026 — persons selling goods or services through digital or electronic platforms, including e-commerce and social media storefronts. A taxpayer outside that covered population is not subject to the badge requirement in the first place.

Can I still get the grace period if I only start the ORUS process on October 30, 2026? #

RMC No. 99-2026’s relief is tied to the badge actually being displayed by October 31, 2026, not to when the process started. Beginning on October 30 leaves very little room for a registration-update transaction to process if your Certificate of Registration needs correction first, so the safer course is to start well before the deadline.

What should I keep as proof that I complied before the deadline? #

Keep a dated screenshot of your storefront, marketplace page, or social media profile showing the badge displayed, timestamped before October 31, 2026, along with the ORUS confirmation or download record for the badge itself. That record is your own evidence of timely compliance if the display status is ever questioned.

Summary #

A taxpayer who still hasn’t displayed the BIR Registration Seal Badge has one practical task before October 31, 2026: confirm the Certificate of Registration is current in ORUS, then generate and post the badge on every platform used to sell. Miss that date, and non-display becomes penalizable again under RMC No. 38-2026’s original terms, with Section 275 of the NIRC and the BIR’s ₱1,000-range compromise penalty framework for registration-display violations as the general exposure, even though no badge-specific fine has been published. For who is covered and where the badge belongs, see BIR Registration Seal Badge: What Online Sellers and Freelancers Must Display; for the fastest ORUS path when your COR needs no changes, see How to Generate Your BIR Registration Seal Badge in ORUS With No COR Updates; for the deadline extension itself, see RMC No. 99-2026: BIR Extends the Registration Seal Badge Deadline to October 31, 2026.