The Bureau of Internal Revenue (BIR) has given businesses additional time to update their invoicing systems to comply with new rules requiring the separate presentation of creditable withholding tax (CWT) on sales invoices when applicable.
Under Revenue Memorandum Circular (RMC) No. 112-2026, issued on 22 October 2026, the bureau clarified the implementation of Revenue Regulations No. 006-2026 and established different compliance deadlines depending on the invoicing systems used by taxpayers.
Businesses using computerized accounting systems, computerized books of accounts and other electronic invoicing systems covered by mandatory electronic invoicing must incorporate the required CWT functionality by 31 December 2026, unless the BIR prescribes a later date.
Meanwhile, taxpayers using existing cash register machines, point-of-sale systems and other invoicing systems not yet covered by mandatory electronic invoicing have until 31 March 2027 to complete the necessary modifications, subject to any earlier deadline subsequently prescribed by the bureau.
BIR Commissioner Charlito Martin R. Mendoza said the transition periods are intended to give businesses enough time to adjust their systems without interrupting operations.
“We understand that updating invoicing systems requires time and resources. That is why we are giving businesses reasonable transition periods to make the necessary adjustments, comply with the new requirements, and avoid unnecessary disruption to their operations,” Commissioner Mendoza said.
During the transition, businesses may continue using their existing registered invoicing systems. For transactions subject to CWT, however, the prescribed withholding tax phrase and corresponding amount must be stamped, printed or legibly written on the invoice before it is issued.
After the applicable deadline, the prescribed CWT phrase and field must appear on every system-generated invoice. When withholding tax does not apply, the amount may be left blank or indicated as “N/A” or “0.00.”
The BIR also clarified that system modifications made solely to accommodate CWT information qualify as Limited System Changes and do not automatically require new registration or accreditation, provided they do not materially affect the system’s core functions. Existing notification and reporting requirements remain applicable.
Taxpayers using manual or loose-leaf invoices may continue using their unused supplies until fully consumed. They do not need to surrender these invoices or secure a new Authority to Print solely because their current invoice formats lack a separate CWT field. The required notation must be added only to transactions subject to withholding tax.
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