E-invoicing vs electronic sales reporting: two different BIR duties

"EIS" is often used for two different things. One is issuing electronic invoices to your buyers. The other is reporting your sales data to the BIR. They come from different sections of the Tax Code, need different permits, and have different start dates. For a business with several branches, it matters which one is due.

Two duties, two sections of the Tax Code

RMC 98-2026 says it plainly: the duty to issue e-invoices "shall be separate and distinct from" the duty to comply with electronic sales reporting. Covered taxpayers must report sales only once the BIR issues "the implementing policies, guidelines, and procedures for such purpose". The PTT likewise applies "only upon notification or directive from the Commissioner".

What the law says about reporting

The CREATE MORE Act (RA 12066, 8 November 2024) rewrote Section 237-A. Once the BIR has a system that can store and process the data, it will require exporters and Large Taxpayers Service taxpayers to report their sales data electronically, and the Finance Secretary can extend this to others.

RR 11-2025, as amended by RR 26-2025, lists who will be covered once that system is ready:

• non-micro e-commerce sellers;
• LTS and large taxpayers;
• CAS and CBA users;
• exporters;
• registered business enterprises with tax incentives;
• taxpayers using a POS system;
• others the Commissioner names.

So POS users are named for sales reporting, but it isn't in force yet.

Setting up a reporting system earns an extra deduction from taxable income, on top of the ordinary one: 100% of the setup cost for micro and small taxpayers, and 50% for medium and large (Section 237-A as amended, and RR 11-2025).

How fast data will have to reach the BIR

The current reporting rules aren't out yet. The last rule the BIR applied, RR 8-2022, required sales data in JSON, sent in real time or near real time, and no later than three calendar days after the sale. Plan for something similar, but wait for the new rules before you build to a deadline.

The Tax Code also has a penalty for failing to transmit when required. Section 264-A, as the TRAIN law wrote it, sets it at the higher of ₱10,000 or one-tenth of 1% of annual net income, per day. If the days of violation add up to more than 180 in a year, the business can also be closed permanently. The penalty doesn't apply if the failure is due to force majeure or causes beyond your control. RR 11-2025 points to it.

Multi-branch stores

• Coverage is for the whole business. If your business is covered, RMC 98-2026 says the head office and every branch must issue e-invoices, even if the covered activity, such as online selling, happens at only one branch. RR 11-2025 applies the same rule to sales reporting.
• One PTI number, marked per branch. The head office and each branch get a PTI with the same number, each showing which branch it covers.
• Different systems, different PTIs. If branches or business lines use different invoicing software, you need a separate PTI for each system.
• New branches on the same system don't need a new PTI number, as long as you notify the BIR under the usual rules.
• Changing software, or migrating to another platform, needs a new or amended PTI.
• Downtime at one branch is handled branch by branch. Issue BIR-authorized manual invoices while the system is down, then replace them with e-invoices that carry the manual invoice numbers.

Don't confuse it with the old eSales report

Registered cash register and POS users have a separate, older monthly report through the BIR's eSales system (RMO 12-2012). It gives each machine's monthly sales totals, due by the 8th of the next month for even last TIN digits and the 10th for odd.

eSales is a monthly total. EIS sales reporting will be per invoice. The BIR took eSales down for maintenance in June 2025, which suggests it is still in use, but we found no 2025 or 2026 issuance confirming or ending it. Ask your RDO whether you still file it.

What to do now

1. Work out whether you're in the e-invoicing group due 31 December 2026. See who must e-invoice.
2. If you are, apply for the PTI in time. It takes up to 20 working days once your documents are complete. Then plan the EIS Certification within six months.
3. Choose invoicing software that can report sales data later. RMC 98-2026 only counts an invoice as electronic if its data can be extracted and sent to the BIR.
4. Watch for the BIR's sales reporting rules and the separate rules for e-invoicing service providers.

Kassly and EIS

Kassly doesn't report anything to the BIR. It has EIS transmission code in development: it would send each sale, void and return as JSON once a store has the BIR's credentials. It is switched off in production, holds no BIR credentials, and Kassly has no EIS Certification. See what Kassly prints for BIR.