With no establishment and no Philippine tax registration, the BIR's e-invoicing rules don't reach you. Revisit if you register for VAT there – the mandate's waves are defined by taxpayer classification, so your status on registration decides when you join.

The first wave is defined by taxpayer classification, and how non-resident registrants – including foreign digital service providers with Philippine VAT registrations – will be treated isn't spelled out in the rules read so far. Nothing is due from you by the 2026 deadline on the face of it, but confirm with the BIR or a local adviser before relying on that.

Most SMEs sit outside the 31 December 2026 wave – but two doors pull smaller businesses in: e-commerce and internet transactions (micro taxpayers excluded), and using a computerised accounting system or invoicing software, per the sources read. If either applies, you share the large-taxpayer deadline. Everyone else follows in later phases once the BIR's platform is ready.

Taxpayers under the Large Taxpayers Service, large taxpayers under RA 11976, e-commerce businesses and anyone already running a computerised accounting system are in the first wave: by 31 December 2026 invoices must be system-generated through BIR-registered or accredited software in the BIR's structured format, with sales data transmitted no later than three calendar days from the transaction. If you lived through the 2022 EIS pilot, note this mandate runs on new rules – RR 11-2025 as amended by RR 26-2025.