Philippines Introduces E-Invoicing Accreditation Requirements With Safeguards to Protect Taxpayers

The Philippines has introduced e-invoicing accreditation requirements with some interesting safeguards to protect taxpayers against poor practices within the service provider market.

Revenue Memorandum Circular No. 110-2026 requires providers to obtain accreditation for their solutions before deploying them commercially, demonstrating technical capability, financial sustainability, information security and business continuity.

Nothing too surprising there. For global providers, securing and maintaining accreditation country by country is becoming a familiar and expensive exercise.

For end users, accreditation offers reassurance when choosing a partner to handle business-critical processes and sensitive data. I’m not sure we have found the right balance yet between providing that reassurance and the cost of repeatedly demonstrating capability across different markets.

What particularly interests me, though, is the protection around the commercial relationship.

The circular stipulates that providers must not withhold, delete or restrict access to taxpayer records because of unpaid fees, contractual disputes, termination or a change of provider. They must support the transfer of data and audit trails without loss, unreasonable delay or unreasonable cost.

Fees must also be transparent, reasonable and disclosed before onboarding, with exit, data retrieval and migration charges clearly set out in the service agreement.

These are useful protections in what sometimes feels like a Wild West environment, where businesses are buying services to meet rules they are often still trying to understand.

Mandates create a commercial opportunity, and inevitably attract some providers whose appetite for winning business runs ahead of their ability or commitment to serve customers properly. For a taxpayer under pressure to comply, that distinction is not always easy to spot before signing.

With deadlines approaching, technical requirements evolving and providers offering very different services, there is plenty of scope to choose a partner that turns out to be the wrong fit. Leaving that relationship should not create another compliance problem.

There are two developments here I’ll be watching:

1. Where country-by-country accreditation goes next

The cumulative cost for global providers deserves attention. How much of the assurance process might eventually be recognised across borders, while retaining the checks needed for local compliance?

2. How countries govern provider behaviour

The Philippines has put some practical protections into its accreditation framework, covering access to records, switching providers and visibility of charges.

As more mandates come online, I’ll be interested to see which countries introduce similar rules, how they enforce them, and how much protection taxpayers experience when a commercial relationship breaks down.

This content is intended to share insights and practical considerations based on industry experience. It does not constitute legal, regulatory, or financial advice. Regulatory requirements vary by jurisdiction and circumstance, so any compliance-related matters should be reviewed and validated with your own professional advisors.