Am I covered? Who must switch to e-invoicing

Not every business has to switch. The line is drawn by your sales, how you sell and how you make your invoices.

By the PrimerLedger accounting team · Updated October 8, 2026 · 4 min read

BusinessAnnual gross salesHow it invoicesCovered?
Café₱5 millionInvoicing appYes: not micro, invoices from software
Shopee seller₱4 millionMarketplace ordersYes: e-commerce
Facebook seller₱3.2 millionChat ordersYes: e-commerce includes social media
Sari-sari store₱900,000Paper bookletNo: micro (may join voluntarily)
Trading company₱3.5 millionExcel templateAsk your accountant: Excel invoices are not e-invoices
Any sizeAnyWith the Large Taxpayers ServiceYes
Covered or not: common cases Source: RMC 98-2026 III, IV.1, IV.16; RR 11-2025

The short answer

Ask two questions. First: are your annual gross sales ₱3 million or more? If not, you are a micro business and you do not have to switch, unless you are with the Large Taxpayers Service. Second, if you are above ₱3 million: do you sell online, or make your invoices from accounting or invoicing software? Then you are covered. Our three-question check does this for you in your browser.

Who is covered, in BIR's words

RMC 98-2026, Section III, lists five groups. Micro businesses are left out of all of them.

  • E-commerce businesses: small, medium and large. RR 11-2025 counts marketplace sellers, social media sellers and online stores.
  • Taxpayers with the Large Taxpayers Service.
  • Large taxpayers under the Ease of Paying Taxes classification.
  • Users of CAS, Computerized Books of Accounts, or other invoicing software.
  • Others the Commissioner may name later.

Common cases

A café or a shop with ₱5 million a year, invoicing from an app

Covered. It is not micro, and its invoices come from software.

A Shopee seller with ₱4 million a year

Covered as an e-commerce business.

A sari-sari store with ₱900,000 a year

Micro, so exempt. It may still switch voluntarily.

A business with ₱3.5 million a year that writes invoices in Excel

This is the case to check with your accountant. Excel invoices are not e-invoices (RMC 98-2026, IV.4), and once you move to invoicing software you fall in the software group. See why Excel and Word invoices no longer count.

If you are micro

You may start voluntarily (IV.1). Think about it before you do: once a business is covered, it stays covered, even if its sales later fall below ₱3 million (IV.16). A voluntary business also needs its own PTI.

Branches

The rule covers the head office and every branch (IV.10). Branches on the same system share one PTI; a branch on a different system needs its own.

If you are covered

Read the plain-English guide to e-invoicing and which permits you need, then apply for your PTI early: BIR takes up to 20 working days.

How PrimerLedger helps

BIR e-invoicing in PrimerLedger starts with the same three questions and tells you whether the rule applies, then lists your next steps with their dates. When you are ready, switching your business to e-invoicing is one setting. See BIR e-invoicing with PrimerLedger.

Official sources

  • RMC No. 98-2026 Revenue Memorandum Circular · September 22, 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 Revenue Regulations · February 27, 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.

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