Philippines Sets E-Invoicing Accreditation Rules to Prevent Vendor Lock-In
The Philippines’ Bureau of Internal Revenue (BIR) has introduced accreditation requirements for electronic invoicing solutions, including safeguards against unexpected charges and restrictions on access to invoice records.
Revenue Memorandum Circular No. 110-2026, dated 12 October and effective immediately, requires service providers to obtain accreditation for their solutions before deploying them commercially. Approval covers the specific system, version, interfaces and deployment configuration evaluated by the BIR.
Accreditation is valid for five years, subject to annual compliance reviews and continuous monitoring. Providers must demonstrate technical capability, financial sustainability, information security and business continuity, alongside successful testing of their systems.
The circular places explicit limits on vendor lock-in. Providers cannot withhold, delete or restrict access to 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 be transparent, reasonable and disclosed before onboarding. Exit, data-retrieval and migration charges must be disclosed in the service agreement and cannot exceed the provider’s documented cost.
For finance and tax teams selecting a solution, the rules make data access, migration terms and pricing transparency part of the compliance assessment. The circular also confirms that using an accredited provider does not remove a taxpayer’s responsibility to issue accurate invoices, maintain records and pay the correct taxes.
Source: BIR
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.
