Stop BIR from shutting out e-invoicing startups. Only giants can do e-invoicing.
The Issue
My wife runs a small online shop. She started it in 2020, and three people work in it today. Its sales crossed ₱3 million, so like thousands of online sellers, she must issue structured electronic invoices and transmit them to the BIR by December 31, 2026.
We both support e-invoicing. It makes tax compliance simpler, faster and harder to cheat. So she went looking for a provider. The quote she got was ₱960,000 for the first year, plus up to ₱576,000 every year after. For a business her size, that isn't a compliance cost. It's the business.
The cheap tools didn't solve it either. They make her type in every order by hand, about a thousand a month, and they produce PDFs that never reach the BIR.
I'm a software developer, so we decided to build what sellers like her actually need: e-invoicing a small seller can afford. Then, on October 12, 2026, the BIR issued RMC No. 110-2026, effective the same day. It decides who may provide e-invoicing services, and only providers the size of today's largest vendors can ever qualify.
Under the circular, no e-invoicing service provider may serve a taxpayer without BIR accreditation. To be accredited, a provider must show that in each of the three preceding years it operated systems capable of processing 5,000,000 transactions and supporting 1,000 active accounts. It must also hold ISO 27001, 27017 and 27018 certification and a SOC report, pass source code review and penetration testing, have every cloud provider and subcontractor approved by the BIR, and accept unlimited liability. Applications are reportedly open for only 15 days, from October 16 to 30.
The security requirements are fair. The three-year track record is not. A company founded this year can never meet it, however good its software is. A new provider cannot build a track record, because it cannot legally serve its first customer.
Who pays for this:
Small sellers stuck between typing and paying. Online sellers earning ₱3 million to ₱20 million a year are "small" taxpayers under the BIR's own classification, and at that size a seller issues around a thousand invoices a month. Sellers like her face the same choice: affordable tools that are manual and never reach the BIR, or full-service providers sold by quote at close to ₱1 million for the first year. For a seller just past ₱3 million, that is about a third of a year's sales. Some will close. Others will stay under the threshold on paper, or move their sales off the record. Either way, the BIR loses the tax base this mandate was meant to capture.
Competition itself. The circular does not ask where the three-year track record was earned. Large, mostly foreign e-invoicing vendors qualify on volume built in other countries; a Filipino provider has no way to build it here. The rule hands them the Philippine market by default, before any local provider can compete. The BIR has rightly warned providers against excessive fees, and competition from new providers is what brings fees down. Meanwhile, cross-border sellers on the same marketplaces carry none of this cost, so the rule puts Filipino sellers further behind on their own platforms.
Filipino startups. Local teams building affordable tools for MSMEs are locked out before they begin. That runs against the spirit of the Innovative Startup Act (RA 11337) and the Ease of Doing Business Act (RA 11032).
The BIR's own goal. Fewer providers means slower adoption, more manual workarounds, and more taxpayers missing the deadline.
We ask the BIR to:
Create a provisional accreditation track for new providers, judged on what can be tested today: source code review, penetration testing, conformance testing in the BIR's EIS sandbox, and taxpayer records kept in the Philippines. Replace the three-year track record with ongoing supervision.
Phase in the certifications (ISO, SOC) over 24 months, scaled to the number of taxpayers a provider serves.
Allow a transition period. While accreditation applications are being processed, let providers in controlled pilots keep serving taxpayers, and do not penalize taxpayers for the gap.
Protect taxpayers when a provider fails. If a provider loses its accreditation, give its taxpayers a fixed window to move to another provider instead of losing their permit to issue invoices.
Consult before finalizing. Hear from providers, MSMEs and accountants before the requirements bind.
We are not asking the BIR to lower the bar on security or accuracy. We are asking for a way for new providers to get over it.
Every capable provider deserves the right to join, and every seller deserves more than one expensive door.
Sign to tell the BIR: e-invoicing should be open to every capable Filipino provider, not only the largest ones.
Started by Aga Anciano, Tri-Point Axis. Disclosure: my company builds Resibo, an e-invoicing service for online sellers, which RMC 110-2026 currently stops from serving other sellers. My wife came up with the idea, and her shop is its first user.
5
The Issue
My wife runs a small online shop. She started it in 2020, and three people work in it today. Its sales crossed ₱3 million, so like thousands of online sellers, she must issue structured electronic invoices and transmit them to the BIR by December 31, 2026.
We both support e-invoicing. It makes tax compliance simpler, faster and harder to cheat. So she went looking for a provider. The quote she got was ₱960,000 for the first year, plus up to ₱576,000 every year after. For a business her size, that isn't a compliance cost. It's the business.
The cheap tools didn't solve it either. They make her type in every order by hand, about a thousand a month, and they produce PDFs that never reach the BIR.
I'm a software developer, so we decided to build what sellers like her actually need: e-invoicing a small seller can afford. Then, on October 12, 2026, the BIR issued RMC No. 110-2026, effective the same day. It decides who may provide e-invoicing services, and only providers the size of today's largest vendors can ever qualify.
Under the circular, no e-invoicing service provider may serve a taxpayer without BIR accreditation. To be accredited, a provider must show that in each of the three preceding years it operated systems capable of processing 5,000,000 transactions and supporting 1,000 active accounts. It must also hold ISO 27001, 27017 and 27018 certification and a SOC report, pass source code review and penetration testing, have every cloud provider and subcontractor approved by the BIR, and accept unlimited liability. Applications are reportedly open for only 15 days, from October 16 to 30.
The security requirements are fair. The three-year track record is not. A company founded this year can never meet it, however good its software is. A new provider cannot build a track record, because it cannot legally serve its first customer.
Who pays for this:
Small sellers stuck between typing and paying. Online sellers earning ₱3 million to ₱20 million a year are "small" taxpayers under the BIR's own classification, and at that size a seller issues around a thousand invoices a month. Sellers like her face the same choice: affordable tools that are manual and never reach the BIR, or full-service providers sold by quote at close to ₱1 million for the first year. For a seller just past ₱3 million, that is about a third of a year's sales. Some will close. Others will stay under the threshold on paper, or move their sales off the record. Either way, the BIR loses the tax base this mandate was meant to capture.
Competition itself. The circular does not ask where the three-year track record was earned. Large, mostly foreign e-invoicing vendors qualify on volume built in other countries; a Filipino provider has no way to build it here. The rule hands them the Philippine market by default, before any local provider can compete. The BIR has rightly warned providers against excessive fees, and competition from new providers is what brings fees down. Meanwhile, cross-border sellers on the same marketplaces carry none of this cost, so the rule puts Filipino sellers further behind on their own platforms.
Filipino startups. Local teams building affordable tools for MSMEs are locked out before they begin. That runs against the spirit of the Innovative Startup Act (RA 11337) and the Ease of Doing Business Act (RA 11032).
The BIR's own goal. Fewer providers means slower adoption, more manual workarounds, and more taxpayers missing the deadline.
We ask the BIR to:
Create a provisional accreditation track for new providers, judged on what can be tested today: source code review, penetration testing, conformance testing in the BIR's EIS sandbox, and taxpayer records kept in the Philippines. Replace the three-year track record with ongoing supervision.
Phase in the certifications (ISO, SOC) over 24 months, scaled to the number of taxpayers a provider serves.
Allow a transition period. While accreditation applications are being processed, let providers in controlled pilots keep serving taxpayers, and do not penalize taxpayers for the gap.
Protect taxpayers when a provider fails. If a provider loses its accreditation, give its taxpayers a fixed window to move to another provider instead of losing their permit to issue invoices.
Consult before finalizing. Hear from providers, MSMEs and accountants before the requirements bind.
We are not asking the BIR to lower the bar on security or accuracy. We are asking for a way for new providers to get over it.
Every capable provider deserves the right to join, and every seller deserves more than one expensive door.
Sign to tell the BIR: e-invoicing should be open to every capable Filipino provider, not only the largest ones.
Started by Aga Anciano, Tri-Point Axis. Disclosure: my company builds Resibo, an e-invoicing service for online sellers, which RMC 110-2026 currently stops from serving other sellers. My wife came up with the idea, and her shop is its first user.
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Petition created on October 22, 2026