Your CAS can generate an invoice in seconds. But before you send it electronically, check what your BIR approval actually covers. A CAS Permit to Use or Acknowledgement Certificate authorizes the system itself, it does not authorize electronic invoicing.
Under RMC No. 98-2026, covered taxpayers must secure a Permit to Issue Electronic Invoice (PTI) before issuing their first e-invoice, then obtain EIS Certification within six months. With BIR evaluation taking up to 20 working days and the compliance deadline set for 31 December 2026, starting late can leave your finance and IT teams racing against time.
This guide explains the difference between CAS authorization and PTI, identifies who must comply, clarifies what qualifies as an e-invoice, and shows how to plan the approval process for your Philippine business.
Key Takeaways
A CAS Authority to Print does not authorize e-invoice issuance, because issuing e-invoices requires a separate PTI approval from the BIR.
The BIR evaluates a PTI application within 20 working days, and the taxpayer's system must then pass EIS Certification within six months.
One PTI covers the head office and its branches, but every distinct invoicing system needs its own PTI, and changes to a certified system require a new or amended PTI.
All covered taxpayers must comply by 31 December 2026, so CAS and ERP users must map their invoicing systems and plan their PTI filing backward from that deadline.
What Is a PTI Electronic Invoice?
A PTI electronic invoice is an invoice issued through a system operated by a Platform and Technology Intermediary (PTI), a provider that the Bureau of Internal Revenue (BIR) has evaluated and approved to generate, transmit, and store e-invoices for taxpayers. Under RMC 98-2026, a taxpayer's invoicing system must run through an approved PTI before it can issue invoices as part of the BIR's electronic invoicing and e-sales reporting program.
A PTI approval is different from the Authority to Print (AC) that a Computerized Accounting System (CAS) already holds. The AC authorizes a computerized accounting system to produce books and receipts. The PTI approval covers the invoicing system itself. The BIR evaluates each PTI application within 20 working days, and the approved system must then pass EIS Certification within six months.
One PTI covers a taxpayer's head office and its branches, but each distinct invoicing system needs its own PTI. Covered taxpayers must comply by 31 December 2026, and micro taxpayers are exempt. CAS and ERP users should confirm which of their systems generate invoices before they file.
Why a CAS Acknowledgement Certificate Is Not a Permit to Issue
The two documents answer different questions. The Acknowledgement Certificate (AC) tells you the BIR has acknowledged your computerized accounting information system. The PTI tells you that you may issue electronic invoices through an approved system. EIS Certification comes later, and the Permit to Transmit (PTT) is a separate permission that applies only in specific cases.
| Document | What it authorizes | Issued or managed by | When it is needed | Source |
|---|---|---|---|---|
| Acknowledgement Certificate | Acknowledges the registration or use of CAS within its scope | BIR | During CAS registration | RMC 98-2026 II.6 to II.7: RMO 9-2021 |
| PTI Electronic Invoice | Allows issuing e-invoices through the approved system | RDO or LT Office | Before the first e-invoice | RMC 98-2026 IV.9, IV.12 to IV.13 |
| EIS Certification | Confirms the system completed EIS testing | EIS Certification Portal | Within six months after the PTI is issued | RMC 98-2026 IV.15 |
| Permit to Transmit | Permission to transmit data when the Commissioner requires it | BIR | Only after a Commissioner notice | RMC 98-2026 II.6 |
Are CAS and CBA Users Covered by the December 31, 2026 Requirement?
The 31 December 2026 issuance deadline applies to several taxpayer groups (RR 11-2025 Sec. 3(A), 3(B), 4: RMC 98-2026 III):
E-commerce taxpayers, by the small, medium, and large categories in the rules
Taxpayers under the Large Taxpayers Service (LTS)
Large taxpayers covered by the Ease of Paying Taxes (EOPT) framework
Users of CAS, Computerized Books of Accounts (CBA), and other invoicing software covered by the rules
CAS and CBA users are among the groups that must issue e-invoices by this date, unless they are micro taxpayers.
Exceptions and Delays to Check
Each of these follows its own rule, so check them one by one.
Micro taxpayers. They are exempt. Confirm the conditions in RMC 98-2026 and RR 11-2025 before relying on the exemption.
POS users. Enforcement for POS users is deferred. Do not treat a POS user as a CAS or CBA user without checking the taxpayer category.
Exporters and Registered Business Enterprises (RBEs). Enforcement is also deferred for these groups.
Electronic sales reporting. It is deferred. Do not describe it as already in force.
Difference Between CAS and CBA
A CAS processes accounting records and related transactions. CBA refers to computerized books of accounts within the scope the BIR defines. They have different registration scopes under RMO No. 9-2021 (Section III). For the PTI, what matters is the system that actually issues your invoices, whatever label it carries.
A Quick Coverage Check
Answer in order. Each path ends in covered, not covered, or confirm with your adviser.
Are you a micro taxpayer?
Yes: check the exemption conditions. If met, the result is not covered. If unsure, confirm with your adviser.
No: go to question 2.
Do you use CAS, CBA, or other invoicing software to issue invoices?
Yes: go to question 3.
No: check whether e-commerce, LTS, or EOPT large taxpayer rules apply. If none do, the result is not covered.
Does the system produce structured invoice data and send invoices digitally?
Yes: the result is covered. Plan for the PTI and EIS Certification.
No: test the system against the e-invoice criteria in the next section.
Does wording such as "(with electronic invoicing)" affect your situation?
Yes: the result is confirm with your adviser.
RMC 98-2026 III.4 contains the phrase "(with electronic invoicing improvement)". It can be read more than one way, and this guide does not settle it. If it could change your coverage, get written confirmation from a tax adviser or the BIR.
What Makes an Invoice From Your CAS an E-Invoice
An invoice printed by accounting software is not automatically an e-invoice. Three criteria apply (RMC 98-2026 IV.4 to IV.7: RR 11-2025 Sec. 3(A)):
The invoice comes from registered or approved software that produces structured invoice data.
The invoice is delivered digitally to the buyer.
The invoice data can be extracted for BIR reporting.
Output Examples to Test Against
JSON is the transmission format.
Printed copies are still allowed, but printing alone does not make an invoice electronic.
Invoices made in Word, Excel, or Google Sheets are not valid e-invoices.
Printed output from a system that cannot transmit data is not an e-invoice.
System Output Checklist
Which system issues the invoice?
What data format does it produce?
How is the invoice delivered to the buyer?
Can the data be extracted for transmission?
Which entities and branches use the system?
If your system cannot produce structured data or transmit it, the question is no longer the PTI application. It is whether the system can support e-invoicing at all.
How the PTI Process Works and How Long It Takes
You file the PTI application with the Revenue District Office (RDO) or LT Office where you are registered. The BIR evaluates it for up to 20 working days from a complete filing (RMC 98-2026 IV.12). The PTI names the approved system and its coverage.
What a PTI Covers
One PTI number covers the head office and its branches. Each distinct system needs its own PTI (RMC 98-2026 IV.9, IV.12 to IV.13). If one branch runs a different invoicing tool, plan a separate application.
This guide does not list the documentary requirements. Check the BIR's official PTI procedure before assembling your file.
Plan Backwards From Your First E-Invoice
Complete this worksheet for each system.
Item | Date or information |
Target first e-invoice | ____ |
PTI filing deadline (complete) | ____ |
BIR evaluation time | 20 working days |
Holidays to deduct | ____ |
Internal owner | ____ |
Document status | ____ |
Illustrative planning arithmetic, not a BIR deadline: if your first e-invoice is on 29 December 2026, subtract 20 working days and the listed holidays. That points to a complete filing around 25 November 2026. Confirm the date against the official holiday list and the completeness of your documents.
Late November is therefore the practical danger zone. A company that starts mapping systems in December will not receive a PTI in time.
EIS Certification Within Six Months of Your PTI
EIS Certification is an online testing stage that follows the PTI (RMC 98-2026 II.6, IV.15). It requires five mandatory tests, or seven if the system uses an API callback. It must be completed within six months of PTI issuance. Failure is a ground for PTI revocation.
Portal and Permit to Transmit
Testing runs through the official EIS Certification portal. Follow the BIR's own documentation for how the tests work.
A PTT is needed only after a notice from the Commissioner. Without such a notice, do not budget for it. For wider context, read our overview of BIR EIS requirements.
Changes That Require a New or Amended PTI
A PTI is tied to a specific system. Review your PTI position before any of these changes go live (RMC 98-2026 IV.12 to IV.13):
A change in system identity, name, or platform
A migration to another system
A replacement of the system
The addition of another system
Adding a Branch on the Same System
A new branch on the same system needs only a notice to the BIR, not a new PTI (RMO 9-2021 V.8). For the registration side, see system changes that affect your CAS registration.
Map Your Invoicing Systems Before Filing
An invoice may look the same to your customer even when it comes from a different system at each branch. Those differences matter when you’re preparing for electronic invoicing in the Philippines.
Start with a simple list for every entity and branch: the system used, whether it is a CAS, CBA, ERP, or service provider, and how it creates and delivers invoice data.
Add the process owner, PTI status, and EIS Certification target. This makes it easier to spot a branch using a separate tool, a system that cannot extract the needed data, or a workflow with no clear owner.
Once you have the full picture, talk to the HashMicro team about how HashMicro accounting software could fit your invoicing workflow and help your team prepare the next steps.
Conclusion
A CAS Acknowledgement Certificate does not authorize electronic invoicing. Covered businesses need a separate PTI before issuing e-invoices and must obtain EIS Certification within six months of the PTI. With BIR allowing up to 20 working days to evaluate a complete application, it pays to prepare ahead of the 31 December 2026 deadline.
Map the systems and branches that issue your invoices, assign a process owner, and set a filing schedule. If you’re reviewing whether your current accounting workflow is ready, book a free consultation with HashMicro to discuss the system side of your next steps. Confirm questions about your tax coverage and filing obligations with your tax adviser.
FAQ
No. A CAS Permit to Use or Acknowledgement Certificate does not by itself authorize e-invoicing (RMC 98-2026 II.7). Covered taxpayers need a PTI first.
Micro taxpayers are exempt, but confirm the conditions under RMC 98-2026 and RR 11-2025 before relying on it (RR 11-2025 Sec. 4).
Enforcement for POS users is deferred. Do not treat POS users as CAS or CBA users, and check your taxpayer category and the current BIR notice (RMC 98-2026 III).
The taxpayer holds the PTI. A provider may help with the application or supply the system, but it does not take over your obligations (RMC 110-2026 V.A.2).
