What the law says
Issuing an invoice for a sale is a duty under the Tax Code (Sections 113 and 237). Section 264(a), as restated in RR 11-2024, sets the penalty for failing to issue one: a fine of not less than ₱1,000 and not more than ₱50,000, and imprisonment of not less than 2 years and not more than 4 years. The e-invoicing rule changes how invoices are made and delivered; it does not remove that duty.
| Situation | What the rules say | Source |
|---|---|---|
| A sale without an invoice | Fine of ₱1,000 to ₱50,000 and imprisonment of 2 to 4 years | Tax Code Sec. 264(a), RR 11-2024 |
| Covered, but still invoicing from Word or Excel after the deadline | Those invoices are not e-invoices | RMC 98-2026 IV.4 |
| Invoicing software that cannot send its data | Its invoices are treated as manual invoices | RMC 98-2026 IV.5 |
| No EIS Certificate within six months of the PTI | The PTI can be cancelled | RMC 98-2026 IV.15 |
| Editing or deleting an issued e-invoice | Not allowed: corrections are credit notes or new invoices | RMC 98-2026 IV.8 |
| E-invoice from a system with a PTI | Valid proof of the expense for your buyer | RMC 98-2026 IV.14 |
Other risks
- Your buyers. Business customers need valid invoices to support their expenses. An invoice that does not follow the rules is a problem for them too.
- Your PTI. It names your software. Missing the certification window or changing systems without telling BIR puts it at risk.
- Platforms. We have not found a published Shopee rule that penalises a missing invoice upload; the legal duty is BIR's.
The Tax Code has other penalties too, for example on records and returns. This guide covers only the invoicing duty; your accountant can tell you what applies to your business.
Safe
- One invoice for every sale, on the day
- Corrections as credit notes
- PTI and EIS Certificate dates in your calendar
- Manual invoices kept for outages, then replaced
- Records kept for at least five years
Risky
- Invoicing "later" in batches by memory
- Editing or deleting issued invoices
- Letting the six-month certificate window pass
- Word or Excel invoices after the deadline
- Switching software without updating the PTI
How PrimerLedger helps
PrimerLedger makes the safe habits the easy ones: invoices are numbered in sequence and locked when issued, corrections are credit notes, online orders are invoiced in bulk without doubles, and BIR e-invoicing e-mails you 60, 30, 14 and 7 days before your PTI and EIS Certificate dates. See BIR e-invoicing with PrimerLedger.
Official sources
- National Internal Revenue Code (Tax Code) Sec. 113 (invoicing requirements), Sec. 237 (issuance of invoices), Sec. 237-A (electronic sales reporting) and Sec. 264 (penalties).
- RR No. 11-2024 Amends the invoicing rules: changing how a CAS prints invoices is a major enhancement that needs a new Acknowledgement Certificate, and it restates the penalty for failing to issue invoices (Tax Code Sec. 264).
- RMC No. 98-2026 The e-invoicing guidelines: who is covered, what makes a valid e-invoice, no editing after issue (credit notes instead), outages, the PTI, the EIS Certificate within six months, and the PTT only when BIR directs.
All in one place: official BIR documents on e-invoicing. Guidance in plain words, not tax advice: your accountant or RDO confirms it for your business.