An e-invoice
- Issued from the system named on your PTI
- Structured data in BIR’s format
- Numbered in sequence by the system
- Locked once issued
- Delivered by e-mail, link or QR code
Not an e-invoice
- Typed in Word, Excel, Google Docs or Sheets
- A PDF exported from those
- Numbers typed by hand
- Can be changed at any time
- Printed from a system that cannot send its data
What the rule says
RMC 98-2026 (IV.4) explains what makes a valid e-invoice and then says plainly that invoices created with word processors and spreadsheets, such as Microsoft Word, Excel, Google Docs and Google Sheets, are not valid e-invoices. RR 11-2025 adds that every accounting system and invoicing software must be able to produce structured invoice data.
Why a spreadsheet isn't enough
A spreadsheet invoice can look perfect and still fail all three tests of an e-invoice:
- Structured data. An e-invoice is data in BIR's format (JSON), not a page layout.
- A registered system. The e-invoice comes from the system named on your PTI, with numbering that can't be skipped or reused.
- Locked once issued. A spreadsheet cell can be changed at any time; an e-invoice can't (IV.8).
What about a PDF?
A PDF is how a buyer reads the invoice, and that is fine. What matters is where it came from: a PDF printed from an e-invoicing system, with the data behind it, is an e-invoice in a readable form (IV.7). A PDF exported from Word or Excel is not.
Who this affects
Businesses covered by the rule: online sellers, large taxpayers, and businesses invoicing from software, all above the micro line of ₱3 million a year. A micro business that is not covered may keep using its current invoices. Check with our three-question check or the guide Am I covered?.
Moving off your template
- List what your template has: your registered name, TIN line, address, the buyer's details, items, VAT and totals.
- Choose e-invoicing software, before you apply for your PTI, because the PTI names it.
- Add your customers and your usual items once; after that each invoice takes a minute.
- Finish the month in the old template, start the new month in the new system, and keep your old invoices as they are.
The guide Excel or an accounting app covers the rest of the move, from sales lists to expenses.
How PrimerLedger helps
PrimerLedger was made for people moving from a spreadsheet: it looks and feels simple. Each invoice carries what RR 7-2024 asks for, including your VAT or non-VAT TIN line with branch code and the VAT breakdown. With e-invoicing switched on, every invoice is issued in sequence, locked, kept in BIR's e-invoice format and sent to the buyer by e-mail with a link and a QR code. Three months free. See BIR e-invoicing with PrimerLedger.
Official sources
- 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.
- RR No. 11-2025 E-invoicing and electronic sales reporting under the CREATE MORE Act: who must comply (micro businesses exempt), a broad definition of e-commerce, structured invoice data from every CAS and invoicing software, and an extra deduction for the cost of setting it up.
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.