Permit to Issue
Registering your system isn't permission to issue e-invoices. Online sellers that aren't micro need a Permit to Issue from their RDO before 31 December 2026, and BIR takes up to 20 working days.
← 2.2 CAS and the Acknowledgement Certificate"We have the AC. Are we done?"
Kuting Kitchen's software is registered and it has its Acknowledgement Certificate (Lesson 2.2). Carla thinks the e-invoicing part is handled.
Her accountant: "The AC lets you use the system. It doesn't let you issue e-invoices. For that you need a Permit to Issue."
Who must e-invoice, and by when
RMC 98-2026 lists who must issue electronic invoices on or before 31 December 2026. Online sellers are one group; large taxpayers and businesses already using a computerized system are others. Micro taxpayers, under ₱3,000,000 in sales a year, are exempt.
Kuting Kitchen sells about ₱4.8 million a year, so it's small, and covered.
What counts as an e-invoice
All three must hold: it's made by a registered system as structured data; it reaches the buyer electronically (email, an online page, a QR code, an app); and its data can be pulled out and sent to BIR.
An invoice typed in Word, Excel or Google Sheets doesn't count. Neither does one printed from a system that can't send it electronically. A printout for a buyer who asks is fine.
After the AC: the Permit to Issue
Two papers, two jobs. The Acknowledgement Certificate says your system is registered: you may use it. The Permit to Issue (PTI) Electronic Invoice says you may issue e-invoices through it.
RMC 98-2026 is explicit: the AC alone is not authority to issue e-invoices. You need the PTI before the first one.
Applying
Go back to the same office: the RDO where you're registered (RDO 038 for Kuting Kitchen). Bring the AC with the PTI application, with the documents BIR prescribes. Ask the RDO for its current list.
BIR evaluates within 20 working days from receiving complete documents. The PTI names the approved software and what it covers.
The PTI is for a system that's already registered, so the AC comes first. It takes about 3 working days, so you can file for the PTI right after. Some RDOs may accept both in one visit: ask yours.
Counting back from 31 December
Twenty working days is four weeks of weekdays, and December has holidays: 25 December and 30 December. Counting back from 31 December, the last filing date that still fits is about 1 December, and only if every paper is right the first time.
The clock runs from complete documents, so a returned application starts again. Aim for early November.
One system, one PTI
The head office and each branch get a PTI with the same number. Use different systems for different branches and you need a separate PTI for each system.
Change the software or platform later and you need a new or amended PTI. So choose the system first, then apply.
Not covered? Still a PTI
A micro seller may switch to e-invoices voluntarily, but it needs a PTI from its RDO too. Without one, it keeps issuing registered manual invoices.
Next comes the last step: connecting the system to BIR (Lesson 2.4).
Pop Quiz: on time or not?
Three small online sellers file their PTI applications with complete documents. Who is safe for 31 December 2026?
Dani files on 3 November 2026.
About eight weeks before the deadline: room for the 20 working days and for one round of corrections.
Elle files on 1 December 2026.
Exactly 20 working days remain, if no other day is declared a holiday. One returned document and she misses it.
Ben files on 14 December 2026.
About 11 working days remain. BIR has 20, so the PTI may not arrive before 31 December.
General information for learning, not tax advice. Kuting Kitchen and the sellers in the exercise are fictional. The working-day count assumes only 25 and 30 December are holidays; check the year's declared holidays, and your RDO's current requirements for the Permit to Issue.
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