15/10/2026
๐ฃ๐ฎ๐ฎ๐ป๐ผ ๐ป๐ฎ ๐ฎ๐ป๐ด ๐บ๐ด๐ฎ ๐บ๐ฎ๐น๐ถ๐น๐ถ๐ถ๐ ๐ป๐ฎ ๐๐ถ๐น๐ถ๐ฝ๐ถ๐ป๐ผ ๐๐ผ๐ณ๐๐๐ฎ๐ฟ๐ฒ ๐ฑ๐ฒ๐๐ฒ๐น๐ผ๐ฝ๐ฒ๐ฟ๐ ๐๐ฎ ๐ฏ๐ฎ๐ด๐ผ๐ป๐ด ๐๐๐ฅ ๐ฒ-๐ถ๐ป๐๐ผ๐ถ๐ฐ๐ถ๐ป๐ด ๐ฟ๐ฒ๐พ๐๐ถ๐ฟ๐ฒ๐บ๐ฒ๐ป๐๐?
I have been following the BIR's electronic invoicing program for quite some time. As a CPA practicing taxation, I genuinely support this initiative. Alam ko kung gaano kalaking improvement ito sa tax compliance, recordkeeping, at ease of doing business kung maayos ang implementation.
In fact, isa rin ako sa mga naglaan ng panahon, effort, at resources para makapag-develop ng software na makakatulong sa mga taxpayers na mag-comply.
Pero after reading RMC No. 110-2026 and the newly announced accreditation requirements, I can't help but question the fairness of how this is being implemented.
Under Section V(C)(4), an Electronic Invoicing Service Provider (ESP) must demonstrate experience, for each of the immediately preceding THREE YEARS, operating or supporting systems capable of processing at least 5 MILLION transactions annually and supporting at least 1,000 active user or customer accounts per year.
On top of that, may ISO/IEC 27001, 27017, 27018, SOC 1, SOC 2 or equivalent assessments, financial assurance, third-party security certifications, and several other requirements.
I understand the need for security. Taxpayer data is sensitive, and the BIR has every reason to ensure that providers are technically capable and reliable.
But here's what I find difficult to accept.
For years, software developers have been preparing based on the BIR's published issuances. RMO No. 24-2023 even provided an accreditation framework that expressly covered subscription-based electronic invoicing software.
Then came RMC No. 98-2026 last September, informing everyone that separate ESP guidelines would follow.
Now, RMC No. 110-2026 is dated October 12. The application period was announced today, October 15, and applications will already be accepted from October 16 to 30.
Meanwhile, the compliance deadline for covered taxpayers remains December 31, 2026.
Sa mga na-review kong publicly available BIR issuances at announcements before this circular, wala akong nakitang advance disclosure ng specific three-year track record, 5-million-transaction, at 1,000-account thresholds.
๐๐ป๐ด ๐๐ฎ๐ป๐ผ๐ป๐ด, ๐ฝ๐ฎ๐ฎ๐ป๐ผ ๐บ๐ผ ๐ฝ๐ฎ๐ด๐ต๐ฎ๐ต๐ฎ๐ป๐ฑ๐ฎ๐ฎ๐ป ๐ฎ๐ป๐ด ๐ฟ๐ฒ๐พ๐๐ถ๐ฟ๐ฒ๐บ๐ฒ๐ป๐ ๐ป๐ฎ ๐ป๐ด๐ฎ๐๐ผ๐ป ๐บ๐ผ ๐น๐ฎ๐ป๐ด ๐ป๐ฎ๐น๐ฎ๐บ๐ฎ๐ป, ๐ฝ๐ฒ๐ฟ๐ผ ๐๐ฎ๐๐น๐ผ๐ป๐ด ๐๐ฎ๐ผ๐ป ๐ฝ๐ฎ๐น๐ฎ ๐ฎ๐ป๐ด ๐ธ๐ฎ๐ถ๐น๐ฎ๐ป๐ด๐ฎ๐ป ๐บ๐ผ ๐ฝ๐ฎ๐๐๐ป๐ฎ๐๐ฎ๐ป?
Imagine a small group of Filipino developers who saw an opportunity to help local businesses comply. They invested their savings, spent months building their software, studied the regulations, worked on the required reports and integrations, and prepared for accreditation.
Hindi naman lahat ng gustong gumawa ng compliant software ay malalaking technology companies. May mga independent developers, startups, at maliliit na Filipino teams na may kakayahan at magandang solusyon.
They may be able to demonstrate that their systems are secure, accurate, scalable, and compliant.
But how can they demonstrate three years of historical operating experience if they only started developing because of this very government initiative?
You can improve your software. You can subject it to rigorous testing. You can invest in better infrastructure.
๐๐๐ ๐๐ผ๐ ๐ฐ๐ฎ๐ป๐ป๐ผ๐ ๐ฏ๐๐ถ๐น๐ฑ ๐๐ต๐ฟ๐ฒ๐ฒ ๐๐ฒ๐ฎ๐ฟ๐ ๐ผ๐ณ ๐ต๐ถ๐๐๐ผ๐ฟ๐ ๐ถ๐ป ๐ณ๐ถ๐ณ๐๐ฒ๐ฒ๐ป ๐ฑ๐ฎ๐๐.
And this is not just about software developers.
Think about the small business owners who are also expected to comply.
Yung maliliit na negosyo na ang gusto lang naman ay makapagbenta, makapag-issue ng tamang invoice, makapagbayad ng tamang buwis, at makasunod sa batas nang hindi gumagastos nang higit sa kaya nila.
Hindi naman lahat ng taxpayers may sariling IT department, accounting system, o malaking budget para sa software.
Many of them will depend on affordable third-party solutions.
But if accreditation requirements become so difficult that only a limited number of established providers can realistically qualify, what happens to competition? What happens to pricing? What happens to the choices available to ordinary taxpayers?
We should be asking these questions now, not when businesses are already struggling to comply.
Nakakalungkot lang isipin na habang hinihikayat natin ang mga Pilipino na mag-innovate, magtayo ng negosyo, at gumawa ng sariling technology solutions, maaari rin pala tayong magpatupad ng requirements na halos hindi na kayang abutin ng mga nagsisimula pa lamang.
And I want to be clear. I'm not asking the BIR to lower its cybersecurity or technical standards. By all means, test the systems rigorously. Require independent assessments. Verify data security, reliability, transmission capacity, and compliance.
But shouldn't a technically capable new provider have a reasonable opportunity to demonstrate those capabilities?
Why not consider provisional accreditation, supervised technical testing, or alternative qualifications for emerging providers?
And more importantly, can the BIR explain the necessity of these particular historical thresholds and whether they were subjected to adequate stakeholder consultation?
I am not concluding that the requirements were designed to favor anyone. But the practical consequences deserve serious scrutiny, especially when the qualifications appear to favor providers with an established scale of operations.
๐ ๐๐๐๐๐ฒ๐บ ๐๐ต๐ผ๐๐น๐ฑ ๐ฏ๐ฒ ๐ท๐๐ฑ๐ด๐ฒ๐ฑ ๐ฏ๐ ๐๐ต๐ฒ๐๐ต๐ฒ๐ฟ ๐ถ๐ ๐ฐ๐ฎ๐ป ๐บ๐ฒ๐ฒ๐ ๐๐ต๐ฒ ๐๐๐ฎ๐ป๐ฑ๐ฎ๐ฟ๐ฑ๐, ๐ป๐ผ๐ ๐๐ถ๐บ๐ฝ๐น๐ ๐ฏ๐ ๐ต๐ผ๐ ๐น๐ผ๐ป๐ด ๐ถ๐๐ ๐ฝ๐ฟ๐ผ๐๐ถ๐ฑ๐ฒ๐ฟ ๐ต๐ฎ๐ ๐ฏ๐ฒ๐ฒ๐ป ๐ถ๐ป ๐ฏ๐๐๐ถ๐ป๐ฒ๐๐.
I sincerely hope the BIR will reconsider the proportionality of these requirements and provide a fair transition period and alternative accreditation pathways.
Because behind these applications are real people who invested time, money, and effort in good faith, believing that they could participate in building solutions for Filipino taxpayers.
And behind the taxpayers' compliance deadlines are small businesses that will ultimately have to live with the cost and consequences of these policies.
I support digitalization. I support strict compliance. I support better tax administration.
But I also believe that regulation should give capable Filipino innovators a fair opportunity to participate.
๐๐ถ๐ด๐ถ๐๐ฎ๐น๐ถ๐๐ฎ๐๐ถ๐ผ๐ป ๐๐ต๐ผ๐๐น๐ฑ ๐ผ๐ฝ๐ฒ๐ป ๐ฑ๐ผ๐ผ๐ฟ๐, ๐ป๐ผ๐ ๐ฐ๐น๐ผ๐๐ฒ ๐๐ต๐ฒ๐บ ๐ฏ๐ฒ๐ณ๐ผ๐ฟ๐ฒ ๐ป๐ฒ๐ ๐ฝ๐น๐ฎ๐๐ฒ๐ฟ๐ ๐ฒ๐๐ฒ๐ป ๐ด๐ฒ๐ ๐ฎ ๐ณ๐ฎ๐ถ๐ฟ ๐ฐ๐ต๐ฎ๐ป๐ฐ๐ฒ.
