Choosing an electronic invoicing service provider is a compliance and business continuity decision, not only a software purchase. The right provider can support accurate invoice data, reliable reporting, secure records, and uninterrupted tax operations.
Revenue Memorandum Circular No. 110-2026 sets accreditation requirements for Electronic Invoicing Service Providers (ESPs), covering technical capability, security, data governance, interoperability, operations, and continuing compliance. For businesses evaluating providers, accreditation is a key factor in assessing solution reliability and regulatory readiness.
However, ESP accreditation does not replace your company’s own obligations. Before signing or renewing an agreement, verify the provider’s certificate and solution scope while confirming your responsibilities for the Permit to Issue Electronic Invoice, EIS Certification, accurate invoice data, record retention, and audit readiness.
Key Takeaways
BIR accreditation applies to the ESP and its approved solution, not automatically to your company’s PTI or tax obligations.
Your business remains responsible for EIS Certification, accurate invoice data, record retention, and audit readiness.
Verify the provider’s certificate scope, solution version, service controls, fallback process, and migration plan before signing.
What RMC 110-2026 Regulates and What It Does Not
RMC No. 110-2026 regulates Electronic Invoicing Service Providers (ESPs) and the electronic invoicing solutions they offer to taxpayers. Depending on the provider’s scope, this may cover invoice generation, data validation, sales reporting, system integration, transmission, storage, record retrieval, reconciliation, migration, and audit support.
Accreditation assesses whether the provider and its covered solution can operate securely, reliably, and consistently, including their technical architecture, data flows, security controls, interoperability, recovery capabilities, and operational readiness.
The circular focuses on ESP eligibility and accreditation, the approved solution, data privacy and cybersecurity, interoperability and transmission testing, business continuity, disaster recovery, and continuing compliance. Accreditation therefore requires more than a product presentation or a provider’s claim that its software is “BIR-ready.”
RMC No. 110-2026 does not replace the taxpayer’s own obligations, including applicable electronic invoicing deadlines, PTI Electronic Invoice and EIS Certification requirements, system registrations, accurate invoice information, internal controls, record retention, and audit readiness.
Under RMC No. 98-2026, taxpayers may use an in-house solution, a commercial solution, or an ESP, making ESP services one available compliance option.
Who Counts as an Electronic Invoicing Service Provider?
An Electronic Invoicing Service Provider (ESP) may handle one part of the invoicing process or provide a complete solution using ERP integrated system. The examples below show the types of services an ESP may offer and what businesses should check before choosing one.
Entities that provide electronic invoicing services: Electronic Invoicing Service Provider (ESP) is an entity that provides electronic invoicing, sales reporting, or related data services to taxpayers.
Providers of one or several service functions: Their services may include the creation, validation, transmission, storage, maintenance, retrieval, reconciliation, migration, or audit support of electronic invoice and sales data.
Cloud platforms for invoice creation: Examples include cloud-based invoicing platforms used to create and manage electronic invoices.
Integration layer with ERP or BIR systems: ESPs may also provide an integration layer that connects ERP or accounting systems with BIR systems.
Managed transmission and storage services: Some providers handle the transmission of data to relevant authorities, invoice storage, and maintenance of transaction archives.
Complete electronic invoicing and sales reporting packages: Providers may combine invoice creation, sales reporting, data validation, transmission, storage, and reconciliation in one package.
Difference between internal systems and ESP services: A system used only by one company for internal needs may be treated differently from a commercial platform offered to other companies or taxpayers.
Ensure the scope of services before signing a contract: Identify whether the provider offers software, infrastructure, managed service, transmission, storage, or a combination of several functions.
Match the services with accreditation evidence: The scope of services purchased must correspond to the solution scope stated in the provider’s accreditation evidence.
Why BIR Accreditation Is Solution-Specific
A provider may offer several invoicing products, modules, and deployment options, but accreditation should be assessed against the specific solution a business plans to use. The following points explain what buyers should verify before treating a provider’s accreditation as evidence for their chosen setup.
Commercial Deployment Requires Accreditation
An ESP should obtain the applicable Electronic Invoicing Solutions Accreditation Certificate before commercially offering a covered solution. Ask for the certificate and confirm that it applies to the service being purchased.
An application, demonstration, pilot, software registration, or internal review is not proof of accreditation for live commercial use. If a provider says it is “BIR-ready,” ask whether that means testing is underway or accreditation has been granted.
Accreditation Applies to the Approved Solution
Request evidence showing the accredited solution name and version, approved functions, interfaces, integrations, and deployment configuration. Check whether your intended setup falls within that scope.
A provider may sell several products or editions. Accreditation for one solution should not be assumed to cover every module, service, or deployment option it offers.
What the Accreditation Evaluation May Include
The evaluation may cover documentation, provider eligibility and capacity, technical architecture, privacy and cybersecurity controls, solution demonstrations, and transmission testing. It may also assess scalability, failover, backup, and recovery.
Ask the provider how the solution handles failed transmissions, downtime, security incidents, data recovery, and version changes. Its answers should reflect the configuration you intend to use.
Validity, Renewal, and Material Changes
Verify the exact validity period, review and renewal requirements, and rules for material changes against the latest RMC No. 110-2026. Avoid stating a fixed timeline until those details are confirmed.
For procurement, ask whether the provider has changed its architecture, hosting, interfaces, data-processing locations, ownership, security controls, or core invoicing functions since accreditation. Confirm whether any such change requires BIR review for the solution you plan to deploy.
What Accredited ESPs Must Continue Doing
Accreditation is not permanent. Accredited ESPs must continue meeting technical, operational, security, legal, and reporting requirements. Buyers should verify these controls and understand that while ESPs manage invoice transmission and system operations, businesses remain responsible for invoice accuracy, taxpayer registration, internal approvals, and record retention.
Accreditation is not permanent. Accredited ESPs must continue meeting technical, operational, security, legal, and reporting requirements. Buyers should verify these controls and understand that while ESPs manage invoice transmission and system operations, businesses remain responsible for invoice accuracy, taxpayer registration, internal approvals, and record retention.
| Provider obligation | Why it matters to your business | Evidence to request |
|---|---|---|
| Security and access controls | Protect invoice, customer, transaction, and sales data | Security control summary, access policies, audit evidence, and relevant certifications |
| Critical incident reporting | Helps your teams respond when an outage or security event affects invoicing | Incident escalation procedure, notification contacts, and response timelines |
| Service availability | Supports timely invoice generation, transmission, retrieval, and reporting | SLA, availability definition, exclusions, and measurement method |
| Manual fallback | Provides a documented response when the system is unavailable | Fallback workflow, taxpayer responsibilities, and reconciliation process |
| Business continuity and disaster recovery | Protects access to invoice records after outages or major incidents | BCP/DR summary, recovery objectives, backup policy, and test evidence |
| Data custody and portability | Supports retrieval and migration when changing providers | Export formats, migration process, retention period, and handover responsibilities |
| Fee and liability disclosure | Clarifies costs during migration, termination, or downtime | Commercial agreement, fee schedule, exit terms, liability limits, and exclusions |
How to Check a Provider’s Status Before You Commit
Do not rely only on a provider’s website, proposal, sales presentation, or verbal claim. Check the provider’s status against official BIR information and request evidence that identifies the exact solution being offered.
Request certificate-level evidence
Ask the provider for its certificate number or official reference, accredited solution name, approved version, validity dates, approved modules and interfaces, deployment configuration, material changes since accreditation, revalidation or renewal status, and transition plan.
If the provider cannot identify the solution and version covered by its certificate, treat the claim as incomplete until verified.
Keep a dated verification record
| Evidence | Where to check | Date checked | Checked by |
|---|---|---|---|
| ESP accreditation certificate | BIR official source and provider documentation | [Insert date] | [Insert owner] |
| Solution and version scope | Certificate, technical documentation, and contract | [Insert date] | [Insert owner] |
| Material changes | Provider notices and revalidation evidence | [Insert date] | [Insert owner] |
| Current BIR status | BIR website or official EIS page | [Insert date] | [Insert owner] |
| Continuity and migration plan | SLA, contract, and transition documentation | [Insert date] | [Insert owner] |
A dated verification record helps your business distinguish between the provider’s status at the time of procurement and its status at a later renewal or expansion.
If no official BIR list of accredited ESPs is available in the sources checked, state the date and sources reviewed. Do not publish a provider list or describe a provider as BIR-accredited without official evidence.
Review Your E-Invoicing Route
Choosing an e-invoicing provider requires more than checking whether it can generate digital invoices, your team should also review the area of electronic invoicing requirements:
electronic invoicing requirements
ERP and accounting integration: Confirm how the provider connects with your existing ERP or accounting system and how invoice data moves between platforms.
PTI and EIS Certification responsibilities: Clarify who manages the PTI process, supports EIS Certification, and handles taxpayer or branch requirements.
Data transmission and audit access: Check how invoice data is transmitted, retrieved, preserved, and made available for reporting or audits.
Fallback and service continuity: Review the provider’s manual fallback process, service levels, outage response, and business continuity arrangements.
Data portability and migration: Confirm how your records can be exported and transferred if you change providers or the service becomes unavailable.
Workflow readiness with HashMicro: Review your e-invoicing route with the HashMicro team to see how accounting software can support invoice generation, reporting, reconciliation, and continuity across your operations.
Conclusion
RMC No. 110-2026 provides a framework for evaluating e-invoicing providers and their approved solutions. Accreditation applies to the provider and specific solution, while your business remains responsible for its PTI, EIS Certification, invoice data, records, and operational continuity.
Before signing with an ESP, verify its current status, certificate scope, solution version, material changes, service levels, security controls, fallback procedures, and migration plan. Confirm which compliance responsibilities must be completed by your own finance, tax, procurement, and IT teams.
To assess how an e-invoicing solution fits your ERP and accounting workflow, book a free consultation with HashMicro. Our team can help you review invoice workflows, reporting needs, data integration, and continuity considerations while your business confirms regulatory requirements with a qualified tax advisor.
Frequently Asked Questions About ESP Accreditation
No. RMC No. 98-2026 allows taxpayers to use an in-house solution, a commercially acquired electronic invoicing solution, or the services of an ESP. The selected route must still satisfy the requirements that apply to the taxpayer.
Yes, subject to applicable BIR requirements. A system used solely within one organization may fall outside the ESP accreditation scope. However, the taxpayer must still review its PTI, EIS Certification, invoice controls, data transmission, and record-keeping responsibilities.
No. ESP accreditation and the taxpayer’s PTI Electronic Invoice are separate. Ask the provider which parts of the PTI process it supports and which registrations, applications, and branch-level obligations remain with your company.
Do not assume that a grace period exists. Review the available in-house and commercially acquired routes, assess your current system capability, and confirm your position with the BIR or a qualified tax adviser.
Review the provider agreement carefully. Check the fee schedule, termination terms, data export process, migration support, record retention, and responsibilities during a provider change. These terms should be clear before implementation.
Ask which exact solution and version are covered, what certificate evidence is available, which modules and interfaces are approved, how material changes are handled, what PTI and EIS Certification support is included, how downtime is managed, how records will be exported, and which fees apply during migration or termination.
