Regulatory updates - Philippines

The RMC states the suspension aims to protect taxpayers from irregular, untimely or intrusive audits by limiting the field operations conducted by the authority.

The issuance of the circular stems from complaints from taxpayers, stakeholders and internal units reporting on irregularities and inconsistencies in audit operations.

During the suspension, the BIR will conduct a review of existing policies and procedures. Issuance of written orders to audit or investigate taxpayer liabilities is suspended during this period, except for in the following cases:

• Investigation of cases prescribing within six (6) months from the date of this Order
• Processing and verification of estate tax returns, donor's tax returns, capital gains tax returns, and withholding tax returns on the sale of real properties or shares of stocks, together with the documentary stamp tax returns related thereto
• Examination or verification of internal revenue tax liabilities of taxpayers retiring from business
• Letters of Authority (LOA)/ Mission Orders (Mo) necessary for active criminal probes conducted by duly authorized enforcement units through verified intelligence reports, inter-agency referrals, third-party data validation, or risk-scoring anomalies that require immediate audit action where delay would prejudice the government's case
• Claims for refund where the issuance of an LOA is statutorily required
• Other matters/concerns where deadlines have been imposed or under the orders of the Commissioner

The suspension took immediate effect on November 24, 2025, and will remain in force until lifted by the Commissioner.

On October 16 2025, the Bureau of Internal Revenue (BIR) published Revenue Regulations No. 026-2025 amending the transitory provisions of Revenue Regulations No. 011-2025.

Extension to e-invoicing compliance deadline

The amendment postpones the deadline for taxpayers in scope of the requirements to issue electronic invoices according to the below:

• Previous deadline: March 14, 2026
• Current deadline: December 31, 2026.

By the deadline, in-scope taxpayers must issue electronic invoices in XML, JSON or any other format as prescribed by the BIR from an invoicing system accredited by the BIR.

Taxpayers affected by the extension

The following taxpayers are in scope of the obligation, and thus affected by the postponement:

• Taxpayers engaged in e-commerce or internet transactions
• Taxpayers under the jurisdiction of the Large Taxpayers Service (LTS)
• Large Taxpayers
• Taxpayers using Computerized Accounting System (CAS), and Computerized Books of Accounts (CBA), or other invoicing software

Sales Data Reporting upon establishment of BIR system

The amendment reemphasizes that the sales data reporting obligation remains dependent on the establishment of a BIR system capable of storing and processing the required data.

On February 10, 2025, the Philippine Bureau of Customs issued Customs Administrative Order (CAO) 001-2025, providing guidelines to Administrative Order No. 23-2024. The order introduces two new procedures relating to customs processing, as the Pre-border Technical Verification (PTV) and the Cross-border E-Invoicing (CEI) system are implemented. Both procedures aim to streamline import flows to the Philippines.

Cross-border E-invoicing (CEI)

The CEI system is an electronic platform for e-invoice issuance operated by the Philippine government. Through the order, e-invoicing via the CEI system is mandated for transactions relating to all goods imported by sea or air.

To fulfill the obligations and issue invoices via the system, foreign exporters will be required to apply for registration annually to the CEI system, upon which they will receive a digital certificate required for signing the electronic invoices.

The obligation to implement the CEI will be rolled out in three stages:

• Mandatory registration of foreign exporters: 30 days after the publication of the customs administrative order providing the specific procedures for the CEI system;
• Mandatory use of the CEI system for all imports covered by the BOC Bulk and Break-Bulk Cargo Clearance Enhancement Program: 60 days after the publication of the customs administrative order referred to above;
• Mandatory use of the CEI system for all other imports: 90 days after the publication of the customs administrative order referred to above.

Pre-border Technical Verification (PTV)

The Pre-border Technical Verification verifies certain goods’ characteristics and ensures imports comply with regulatory requirements before reaching the Philippine border. As part of the PTV, the foreign exporter must engage with a PTV Accredited Testing, Inspection, and Certification Company (ATICC) in their country of origin and submit documents and provide for inspection of any goods in the scope. The ATICC will, in turn, issue a Certificate of Conformity to the foreign exporter, enabling advanced customs clearance upon arrival in the Philippines.

The obligation to implement the PTV will be phased depending on the characteristics of the goods:

• Phase 1 - Agricultural goods: 30 days after the publication of the CAO providing for the specific procedures for the PTV;
• Phase 2 - Non-agricultural products with health and safety issues: 60 days after the publication of the CAO mentioned above;
• Phase 3 - Other goods susceptible to misdeclaration to avoid duties and taxes: 90 days after the publication of the CAO mentioned above.

Penalties

Non-compliance with the CEI or PTV requirements may result in various penalties, including fines, revocation of importer accreditation, and slower customs processing.

Timeline

According to the regulation, the full implementation of the PTV and CEI systems will enter into force within two years of the effective date for Administrative Order No. 23/2024.