Invoice vs Official Receipt under the EOPT Act

Reviewed by the Oojeema team · Last checked against BIR sources: November 4, 2026

I. Summary #

Since April 27, 2024, the invoice is the only primary document that proves a sale in the Philippines, whether you sell goods or services. The Official Receipt (OR) did not disappear, but it was demoted. It is now a supplementary document that proves you received payment. It does not prove a sale, and your customer cannot use it to claim input VAT.

This change came from Republic Act (RA) No. 11976, the Ease of Paying Taxes (EOPT) Act, and the BIR rules that implement it, mainly Revenue Regulations (RR) No. 7-2024 (invoicing), RR No. 11-2024 (transition deadlines), RR No. 3-2024 (VAT and percentage tax), and Revenue Memorandum Circular (RMC) No. 77-2024 (questions and answers). For service businesses, the bigger change is on the VAT side. Output VAT on services is now recognized when you bill, not when you collect.

Key points #

• One document for every sale. VAT-registered sellers issue a VAT invoice for every sale regardless of amount. Non-VAT sellers issue an invoice for sales of ₱500 or more, when the buyer asks for one, or for the day’s total small sales once that total reaches ₱500 (NIRC Sec. 113(A) and Sec. 237(A), as amended; RR 7-2024 Secs. 3 and 6).
• The OR is now proof of payment only. ORs, collection receipts, acknowledgement receipts, billing statements, and statements of account are “supplementary documents.” They are not valid support for input VAT (RR 7-2024 Sec. 2(2)).
• Service VAT moved from collection to billing. “Gross receipts” became “gross sales” for services, so output VAT follows the invoice, not the deposit slip (NIRC Sec. 108(A), as amended; RR 3-2024 Secs. 2 and 3).
• Input VAT needs a VAT invoice. Your input tax is creditable only if it is evidenced by a VAT invoice issued under Sec. 113 (NIRC Sec. 110(A)(1), as amended).
• Old ORs could be stamped and used as invoices until consumed, but only if they were reported to the BIR by July 31, 2024 and carry all required invoice details (RR 11-2024). Unconverted ORs are supplementary documents only.
• Issuing only an OR, billing statement, or statement of account for a sale is treated as failure to issue an invoice. The penalty under NIRC Sec. 264(a) is a fine of ₱1,000 to ₱50,000 and imprisonment of 2 to 4 years for each act, on conviction (RMC 77-2024, Q26 and Q27).

What to do now #

• Check that every sales document you hand to a customer has the word “Invoice” printed prominently and carries the information listed in Part VI of this article.
• If you sell services, review how you record output VAT. It should follow your billing date.
• Stop treating a supplier’s OR as support for input VAT. Ask the supplier for the invoice.
• If you still hold old OR booklets, confirm which ones were converted and reported. The rest should carry the stamp “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.”
• If you use a computerized accounting system or invoicing software, read Part X on the 2026 electronic invoicing rules.

II. What Changed and Why #

The old two-document system #

Before the EOPT Act, the Tax Code drew a line between goods and services. Sellers of goods issued a sales invoice when the sale happened. Sellers of services issued an official receipt when they were paid. VAT followed the same split. For goods, VAT was based on the gross selling price at the time of sale. For services, VAT was based on gross receipts, so a consultant who billed in January and was paid in April paid the output VAT in April’s quarter.

The split created practical problems. Businesses that sold both goods and services needed two sets of accountable forms. Buyers of services could only claim input VAT once the seller had been paid and issued an OR, so the buyer’s input VAT depended on the buyer’s own payment timing. VAT refund claims were often disallowed because the “wrong” document supported a transaction. The BIR’s own EOPT flyer notes that refund claims had been disallowed for non-compliance with invoicing requirements.

What the EOPT Act did #

RA 11976 was signed on January 5, 2024, published in the Official Gazette on January 7, 2024, and took effect on January 22, 2024 (BIR EOPT flyer). Its stated policy includes modernizing tax administration and replacing antiquated procedures (RA 11976, Sec. 2).

For invoicing, the Act did four things:

1. It required a single document, the invoice, for both goods and services. Sec. 113(A) now reads that a VAT-registered person “shall issue a VAT invoice for every sale, barter, exchange, or lease of goods or properties, and for every sale, barter or exchange of services.”
2. It changed the VAT base for services from gross receipts to gross sales, so goods and services are both on an accrual basis (Sec. 108(A), as amended; RR 3-2024 Sec. 2(A)).
3. It raised the threshold for mandatory invoice issuance by non-VAT sellers to ₱500, to be adjusted every three years using the consumer price index (Sec. 237(A), as amended).
4. It removed “business style” as a required invoice detail (BIR EOPT flyer; RMC 77-2024, Q7).

When the rules took effect #

The law took effect on January 22, 2024, but the invoicing and VAT rules took effect through the regulations. RR 3-2024 and RR 7-2024 were both posted on the BIR website on April 12, 2024 and took effect on April 27, 2024 (RMC 77-2024, Q30). RR 11-2024, posted June 13, 2024, then amended the transition rules in RR 7-2024 and took effect immediately on publication.

For most day-to-day questions, April 27, 2024 is the date to remember. From that date, a sale needs an invoice, and a manual OR issued without the “Invoice” stamp is treated as a supplementary document only (RR 11-2024, amending RR 7-2024 Sec. 8(2.2)).

III. Definitions #

Term	What it means now	Legal basis
Invoice	A written account evidencing the sale of goods and/or services issued to customers in the ordinary course of business. Includes Sales Invoice, Commercial Invoice, Cash Invoice, Charge/Credit Invoice, Service Invoice, and Miscellaneous Invoice. Also called the “principal invoice.”	RR 7-2024 Sec. 2(1)
VAT Invoice	An invoice for sales subject to VAT. It is the basis of the seller’s output VAT and the buyer’s input VAT claim.	RR 7-2024 Sec. 2(1.1); NIRC Sec. 110(A)(1)
Non-VAT Invoice	An invoice for sales not subject to VAT. It is the basis of the seller’s percentage tax, if any.	RR 7-2024 Sec. 2(1.2)
Supplementary document	Any document other than the invoice that is a source of accounting entries: official receipt, delivery receipt, order slip, debit and credit memo, purchase order, acknowledgement or cash receipt, collection receipt, bill of lading, billing statement, statement of account, and similar documents. Not valid support for input VAT.	RR 7-2024 Sec. 2(2)
Official Receipt (OR)	Now a supplementary document that serves as proof of payment, together with collection receipts, acknowledgement receipts, and payment receipts.	RR 7-2024 Sec. 8(2.1), as amended by RR 11-2024
Gross sales (services)	The total contract price, fee, rental, or royalty, including materials charged, for services already rendered or properties already supplied, excluding VAT and pass-through amounts that do not benefit the seller.	NIRC Sec. 108(A), as amended; RR 3-2024 Sec. 3 (Sec. 4.108-4 of RR 16-2005)

Sales Invoice vs. Service Invoice #

This is where many staff get confused, so we will be direct. A “Sales Invoice” and a “Service Invoice” are both invoices. They have the same legal weight. The name on top only describes the transaction, and the law lets you choose it.

RMC 77-2024 (Q13) lists the descriptive names a business may use:

Name	Typical use (per RMC 77-2024)
Invoice	Both sales of goods and services rendered
Sales Invoice	General purpose invoice for any sales transaction
Cash Invoice	Cash sales, where payment is received right away
Charge/Credit Invoice	Sales on credit, where payment comes later
Service Invoice	Transactions where a service is provided
Billing Invoice	Billing charges, similar to a charge invoice, and may include statement of account details
Commercial Invoice	Export transactions
Miscellaneous Invoice	Other income of the seller

Two rules apply whatever name you pick. First, the word “Invoice” must be printed prominently, or larger than the word describing the transaction (RR 7-2024 Sec. 6(A)(3)). Second, if you use more than one type, each type needs its own serial series, which you can distinguish with a prefix or suffix (RMC 77-2024, Q18).

A Pasig design studio that only sells services can use one “Invoice” or “Service Invoice” for everything. A hardware supplier that also does installation might use “Sales Invoice” for materials and “Service Invoice” for labor, or a single “Invoice” that covers both lines. Both setups are allowed.

Is the OR gone? #

No. The OR is still allowed, and many customers still ask for one. What changed is its role. RR 7-2024 Sec. 6(A)(4) says the EOPT Act “no longer requires the issuance of Official Receipts” and establishes the invoice as the primary evidence for both goods and services. You may issue an OR, collection receipt, or payment receipt as a supplementary document showing proof of payment.

Any supplementary document you issue to customers must carry the phrase “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” in bold letters on its face (RR 7-2024 Sec. 6(B)(15)).

IV. Who Must Issue What, and When #

The basic rule #

Seller	Must issue an invoice	Legal basis
VAT-registered	For every sale, barter, exchange, or lease of goods or properties, and every sale of services, regardless of amount	NIRC Sec. 113(A) and last proviso of Sec. 237(A); RR 7-2024 Sec. 3(A)(1)
Non-VAT (including percentage taxpayers and VAT-exempt sellers)	For each sale of ₱500 or more; for any amount if the buyer asks for one; and one invoice at the end of the day for the total of small sales below ₱500, if that total reaches ₱500	NIRC Sec. 237(A); RR 7-2024 Sec. 6(A)(1)-(2); RMC 77-2024, Q2

The ₱500 amount will be adjusted to its present value every three years using the consumer price index published by the Philippine Statistics Authority, counted from January 22, 2024 (RMC 77-2024, Q4). As of our last check, we did not find a BIR issuance announcing an adjusted amount.

We follow the wording of RR 7-2024 Sec. 6(A)(1), the latest regulation on this point: a non-VAT seller issues an invoice for each sale valued at ₱500 or more. A sale of exactly ₱500 needs an invoice.

A sari-sari supplier example #

Mang Ben runs a small non-VAT wholesale business in Marikina that supplies snacks and canned goods to sari-sari stores. On one Tuesday he makes these sales:

Customer	Amount	Invoice needed?
Aling Nena’s store	₱2,350	Yes, the sale is ₱500 or more
Walk-in buyer	₱180	Not individually, unless the buyer asks
Walk-in buyer	₱220	Not individually, unless the buyer asks
Walk-in buyer, asks for an invoice	₱90	Yes, the buyer asked
Walk-in buyer	₱150	Not individually

At the end of the day, his small sales without individual invoices total ₱550 (₱180 + ₱220 + ₱150). Because that total reached ₱500, he issues one invoice for ₱550 covering those sales (Sec. 237(A)).

If Mang Ben were VAT-registered, every one of those five sales would need its own VAT invoice, including the ₱90 sale (Sec. 113(A)).

Timing: when the invoice is issued #

For goods, the invoice is issued at the point of each sale and transfer of merchandise (Sec. 237(A)).

For services, the invoice is issued when the service is rendered and billed. Service providers who bill customers must now issue a Billing Invoice upon billing instead of a billing statement or statement of account (RMC 77-2024, Q14). For long-term contracts of one year or more, the invoice is issued in the month the service, or the use or lease of property, is rendered or supplied (Sec. 108(A), as amended).

One invoice per sale, not one per payment #

Do not issue a second invoice when the customer pays. RMC 77-2024 (Q15) is clear: “Sellers cannot issue an invoice upon receipt of payment.” You have two correct options:

1. For a cash sale, issue one invoice that covers both the sale and the receipt of payment.
2. For a credit sale, issue the invoice on the sale date. When the customer pays later, issue a supplementary document such as an OR, payment receipt, or acknowledgement receipt.

What about donations and non-profits? #

A non-stock, non-profit organization that receives a donation issues a supplementary document, such as a Non-VAT Official Receipt, acknowledgement receipt, or donation receipt, showing the donor’s name, the date, a description of the donation, and its intended purpose. If the organization runs a business activity, it issues invoices for those business transactions (RMC 77-2024, Q32).

Tickets #

Transport, event, movie, parking, and similar tickets count as both an invoice and proof of payment, but only if the word “Invoice” is printed on them and they contain all the required invoice information. Otherwise they are supplementary documents and a separate invoice is needed (RR 7-2024 Sec. 6(C)).

V. Registering Your Invoices: ATP, CAS, CRM and POS #

An invoice is valid only if it is “duly registered.” The registration route depends on how you issue invoices (RR 7-2024 Sec. 5(C)(2)):

How you issue	What you need
Manual (printed booklets)	Authority to Print (ATP), or BIR-printed invoices
Computer-aided (loose-leaf)	Permit to use loose-leaf invoice, and ATP
Computerized Accounting System (CAS) or its components	Acknowledgement Certificate (AC)

The ATP is free, and a printer may only print invoices that are serially numbered and show the name, TIN, and business address of the user (NIRC Sec. 238, as amended; RR 7-2024 Sec. 7). A business that shifts from ORs to invoices must apply for a new ATP for its invoices (RMC 77-2024, Q12 and Q18).

The bottom of a manual invoice must show the ATP number or Outbound Correspondence Number (OCN) and date issued, the BIR permit number if loose-leaf, and the approved serial range. System-generated invoices from CAS or computerized books show the PTU number or Acknowledgement Certificate Control Number (ACCN), the series range, and the date issued. CRM and POS invoices show the Machine Identification Number (MIN), machine serial number, and PTU number (RR 7-2024 Sec. 6(B)(19)-(21)).

An invoice typed up in a word processor or spreadsheet and printed on plain paper, without an ATP or a registered system behind it, is not a duly registered invoice. We see this most often with freelancers and new service businesses.

VI. Required Information on an Invoice #

RR 7-2024 Sec. 6(B) lists what every invoice must contain. Sec. 3(B) adds the VAT-specific items that come from NIRC Sec. 113(B). We have merged the two lists below.

#	Required item	Notes	Basis
1	Seller’s registered name as shown in the BIR Certificate of Registration	You may add your DTI business name or trade name	RR 7-2024 Sec. 6(B)(1)
2	Statement that the seller is VAT or Non-VAT registered, followed by TIN and branch code	Example: “VAT Reg TIN 123-456-789-00000”	Sec. 113(B)(1); RR 7-2024 Sec. 6(B)(2)
3	Registered business address where the invoice is used		RR 7-2024 Sec. 6(B)(3)
4	The word “Invoice”	Alone or with a description, such as “Service Invoice”	RR 7-2024 Sec. 6(B)(4)
5	Date of transaction		Sec. 237(A); RR 7-2024 Sec. 6(B)(5)
6	Space for buyer’s registered name, registered address, and TIN	For B2C sales to end consumers, the buyer’s address and TIN are not required. For VAT sales of ₱1,000 or more to a VAT-registered buyer, the buyer’s name, address, and TIN must be shown	Sec. 113(B)(4); RR 7-2024 Secs. 3(B)(4) and 6(B)(6)
7	Serial number, printed prominently		RR 7-2024 Sec. 6(B)(7)
8	Quantity		Sec. 237(A); RR 7-2024 Sec. 6(B)(8)
9	Unit cost		Sec. 237(A); RR 7-2024 Sec. 6(B)(9)
10	Description of goods or nature of service		Sec. 237(A); RR 7-2024 Sec. 6(B)(10)
11	Total amount of sale, stating that VAT is included if VAT-registered		Sec. 113(B)(2); RR 7-2024 Sec. 6(B)(11)
12	VAT shown as a separate item		Sec. 113(B)(2)(a); RR 7-2024 Sec. 6(B)(12)
13	Breakdown into VATable sales, VAT amount, zero-rated sales, and VAT-exempt sales, for mixed transactions	Or issue separate invoices, each marked “VAT-Exempt Sale” or “Zero-Rated Sale”	Sec. 113(B)(2)(b)-(d); RR 7-2024 Sec. 6(B)(13)-(14)
14	“EXEMPT” on the face, for sellers whose sales are not subject to VAT or percentage tax		RR 7-2024 Sec. 6(B)(16)
15	Breakdown of sales subject to percentage tax and exempt sales, for non-VAT percentage taxpayers with exempt sales		RR 7-2024 Sec. 6(B)(17)
16	Spaces for senior citizen, PWD, national athlete and coach, solo parent, or Medal of Valor ID number, discount breakdown, and signature	Only if you have these transactions. Physical signature is not required for online or app purchases by SCs and PWDs	RR 7-2024 Sec. 6(B)(18)
17	ATP/OCN, permit, serial range (manual); or PTU/ACCN, series, date issued (system-generated)	See Part V	RR 7-2024 Sec. 6(B)(19)-(21)

Business style is no longer required for the buyer or the seller, although you may still show your business name for branding (RMC 77-2024, Q7).

Sample invoice (fictional company, for illustration only) #

The sample below is entirely made up. The names, TINs, and ATP details are placeholders. It shows a VAT-registered service business billing a VAT-registered corporate client for completed work.

SAMPLE ONLY. NOT A REAL INVOICE.

LIKHA LIWANAG DESIGN STUDIO, INC.	SERVICE INVOICE
Unit 5B, Sample Building, Sample St., Kapitolyo, Pasig City 1603	No. SI-0001024
VAT Reg TIN 123-456-789-00000	Date of transaction: February 20, 2026
☐ Cash Sales ☑ Charge Sales	Terms: 60 days

Billed to
Registered name	Bituin Food Products Corporation
TIN	987-654-321-00000
Registered address	88 Sample Avenue, Barangay Sample, Quezon City

Qty	Unit	Description / nature of service	Unit cost (₱)	Amount (₱)
1	lot	Packaging design, 3 SKUs of banana chips (work completed Feb. 18, 2026)	60,000.00	60,000.00
1	set	Brand guidelines manual, 24 pages	25,000.00	25,000.00
10	hrs	Revision rounds at client request	1,500.00	15,000.00

Summary	₱
VATable Sales	100,000.00
VAT (12%)	12,000.00
Zero-Rated Sales	0.00
VAT-Exempt Sales	0.00
Total Amount Due (VAT inclusive)	112,000.00

Footer (manual invoice)
ATP No. / OCN: [sample number] · Date issued: [sample date]
Approved serial nos.: SI-0001001 to SI-0002000

A few things to notice. The word “Invoice” is larger than “Service.” The VAT is shown separately. Because the client is VAT-registered and the sale is over ₱1,000, the client’s registered name, TIN, and address are filled in. Each line has quantity, unit cost, and a description of the service, which Sec. 237(A) requires even for services. If Likha Liwanag issued this from a registered CAS instead of a booklet, the footer would show the PTU or ACCN, series range, and date issued instead of the ATP details.

When Bituin pays in May, Likha Liwanag may issue an OR or collection receipt as proof of payment. That receipt must say “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” It should reference invoice no. SI-0001024 so both sides can match it, but it is not a second invoice.

What happens if information is missing #

The consequences depend on what is missing (NIRC Sec. 113(D), as amended; RR 7-2024 Sec. 3(D); RMC 77-2024, Q28 and Q29):

Situation	Consequence to seller	Consequence to buyer
VAT invoice to a VAT-registered buyer is missing some required details	Liable for non-compliance with invoicing requirements	Can still claim the input VAT, unless the missing item is the amount of sales, the VAT amount, the registered name and TIN of buyer or seller, the description of goods or nature of service, or the date of transaction
Non-VAT seller issues an invoice showing “VAT” after its TIN	Liable for VAT under Sec. 106 or 108 without input tax credit, plus a 50% surcharge under Sec. 248(B), on top of percentage tax	Can claim the VAT as input tax if the other required information is present
VAT-registered seller issues a VAT invoice for an exempt sale but fails to mark it “VAT-Exempt Sale” or show the breakdown	Liable for VAT as if the sale were not exempt

VII. VAT Treatment #

Output VAT on goods #

Nothing dramatic changed for goods. VAT is 12% of gross sales, which is the total amount the buyer pays or is obligated to pay, excluding VAT (NIRC Sec. 106(A), as amended). Output VAT is recognized in the period of sale.

Output VAT on services: from collection to billing #

This is the change that hurts cash flow, and it is the one we most want accounting staff to understand.

Under the old Sec. 108, VAT on services was based on gross receipts, meaning the amount actually or constructively received. Under the amended Sec. 108(A), VAT is 12% of gross sales, meaning the amount “which the purchaser pays or is obliged to pay” for services “that ha[ve] already been rendered.” RR 3-2024 Sec. 2(C) states that all references to receipts or payments as the basis for recognizing sales of services under the VAT and percentage tax titles “shall now be referred to as ‘BILLING’ or ‘BILLED.'”

The old provisions on deposits and advance payments for services to be performed were removed from the definition. VAT on services is now tied to services already rendered and billed.

The same shift applies to percentage tax. RR 3-2024 covers Title V of the Tax Code, so non-VAT service providers also compute percentage tax on gross sales.

Input VAT: what supports your claim #

Under Sec. 110(A)(1), as amended, input tax is creditable only if it is “evidenced by a VAT invoice issued in accordance with Section 113.” For purchases of services, input tax is credited on services “on which a value-added tax has accrued” (Sec. 110(A)(1)(b)).

In practice this means:

1. Your input VAT on a purchase of services is now claimed when you receive the supplier’s VAT invoice, not when you pay and get an OR.
2. A supplier’s OR, collection receipt, or statement of account does not support input VAT, even if it shows VAT (RR 7-2024 Sec. 2(2)).
3. A manual OR issued from April 27, 2024 without the “Invoice” stamp is a supplementary document and “ineligible for input tax claims” (RR 11-2024, amending RR 7-2024 Sec. 8(2.2)).

Output VAT credit on uncollected receivables #

Because service VAT now follows billing, the EOPT Act added a relief for customers who do not pay. A seller of goods or services may deduct the output VAT on uncollected receivables from its output VAT in the next quarter after the agreed payment period lapses (NIRC Sec. 110(D), as amended). RR 3-2024 Sec. 5 adds Sec. 4.110-9 to RR 16-2005 and lists the requirements:

1. The sale took place after RR 3-2024 took effect (April 27, 2024).
2. The sale was on credit.
3. There is a written agreement on the period to pay, such as credit terms on the invoice or another document.
4. VAT is shown separately on the invoice.
5. The sale is reported individually in the Summary List of Sales for the period of sale, not lumped under “various.”
6. The seller declared the output VAT on time.
7. The agreed period, whether extended or not, has lapsed.
8. The VAT component was not claimed as a bad debt deduction for income tax.

If the receivable is later collected, the output VAT is added back in the period of recovery (Sec. 110(D)).

This is why we keep telling clients to write the credit terms on the invoice. Without them, requisite 3 is hard to prove.

VIII. Worked Examples #

Example 1: Computing VAT from a VAT-inclusive price #

A VAT-registered distributor sells assorted canned goods to a sari-sari store for a total of ₱5,600, VAT included.

Step	Computation	Amount (₱)
Total amount due (VAT inclusive)		5,600.00
VATable sales	5,600 ÷ 1.12	5,000.00
VAT	5,000 × 12%, or 5,600 − 5,000	600.00

On the invoice, the distributor shows VATable sales of ₱5,000, VAT of ₱600, and a total of ₱5,600. A shortcut many bookkeepers use is to multiply the VAT-inclusive amount by 12/112. Both methods give ₱600.

If the sari-sari store is not VAT-registered, the distributor still issues a VAT invoice. The store simply has no input VAT to claim. Because the sale is above ₱1,000, the buyer’s name, address, and TIN are required only if the buyer is VAT-registered (Sec. 113(B)(4)). For an end consumer, they are not required (RR 7-2024 Sec. 6(B)(6)). A sari-sari store buying for resale is not an end consumer, so we would fill in its details anyway if it has a TIN.

Example 2: Service billed in one quarter, collected in another #

Likha Liwanag Design Studio, the fictional Pasig studio from our sample invoice, finishes packaging design work and bills Bituin Food Products on February 20, 2026 for ₱112,000 (₱100,000 plus ₱12,000 VAT), on 60-day terms. Bituin pays on May 15, 2026.

	Old rule (before EOPT, gross receipts)	Current rule (after EOPT, gross sales)
Document at billing, Feb. 20	Billing statement or statement of account (no VAT effect)	Service Invoice or Billing Invoice no. SI-0001024
Document at collection, May 15	Official Receipt	OR, collection receipt, or acknowledgement receipt (supplementary)
Quarter when studio reports ₱100,000 sale and ₱12,000 output VAT	Q2 2026 (April to June), when collected	Q1 2026 (January to March), when billed
Return and deadline	2550Q for Q2, due July 25, 2026	2550Q for Q1, due April 25, 2026
Quarter when Bituin claims ₱12,000 input VAT	Q2 2026, on the OR	Q1 2026, on the invoice

The quarterly return deadline is 25 days after the close of each taxable quarter (NIRC Sec. 114(A), as amended).

The practical effect is that the studio pays ₱12,000 output VAT on April 25, 2026, about three weeks before it collects from Bituin. For a small studio, that can be a real cash squeeze. Owners should plan for it in pricing and credit terms.

Now suppose Bituin does not pay at all. The 60-day term lapses on April 21, 2026, which falls in Q2. If all eight requisites in Part VII are met, the studio may deduct the ₱12,000 output VAT in the next quarter after the lapse. If Bituin later pays, the ₱12,000 is added back to output VAT in the quarter of recovery (Sec. 110(D); RR 3-2024 Sec. 5).

Example 3: Transition case, service rendered before April 27, 2024 #

The same studio rendered and billed a service in March 2024 for ₱56,000 including VAT, and was paid in June 2024.

RR 3-2024 Sec. 7(a) says the new rules apply to sales of services that took place on or after its effectivity. For receivables on services rendered before that date, output VAT is declared when collected, in the quarterly return for the quarter of collection, and the collection is supported by an invoice under the transitory invoicing rules (RR 3-2024 Sec. 7(a)).

Item	Treatment
Quarter to report the sale and ₱6,000 output VAT	Q2 2024 (quarter of collection)
Document to issue on collection in June 2024	An Invoice, or a converted OR (struck through and stamped “Invoice”) under the transition rules (RMC 77-2024, Q31)

For goods, the uncollected receivables credit in Example 2 does not apply to credit sales made before April 27, 2024 (RR 3-2024 Sec. 7(b)).

Example 4: Mixed sale on one invoice #

A VAT-registered agricultural supply store sells fertilizer (VAT-exempt), packaging film (VATable), and goods to an export customer (zero-rated) to the same buyer. If it issues one invoice, it must show each component, following the format in RMC 77-2024 (Q25):

Line	Amount (₱)
VATable Sales	200,000.00
VAT	24,000.00
VAT-Exempt Sales	50,000.00
Zero-Rated Sales	26,000.00
Total	300,000.00

It may instead issue separate invoices, each marked “VAT-Exempt Sale” or “Zero-Rated Sale” as applicable. (The VAT treatment of specific products is a separate question. The point here is the presentation.)

IX. Old ORs and Old Invoices: The Transition Rules #

Unused manual and loose-leaf ORs #

RR 7-2024 originally allowed converted ORs only until December 31, 2024. RR 11-2024 changed this. Under Sec. 8(2) of RR 7-2024, as amended by RR 11-2024, a taxpayer had two options for unused ORs.

Option 1. Keep using them as supplementary documents. Unused ORs may be used as proof of payment until fully consumed, provided “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” is stamped on the face. RMC 77-2024 (Q9) adds that each page must be stamped. If you skip the stamp, the document is not a valid replacement for the invoice and you may be treated as not issuing an invoice.

Option 2. Convert them into invoices. You strike through the words “Official Receipt” and stamp “Invoice,” “Cash Invoice,” “Charge Invoice,” “Credit Invoice,” “Billing Invoice,” “Service Invoice,” or another name that describes the transaction. Billing statements, statements of account, and statements of charges may be converted to “Billing Invoice” the same way. The converted document must contain all information required by RR 7-2024 Sec. 6(B), including quantity, unit cost, and description or nature of service. Missing details may be stamped on (RR 11-2024; RMC 77-2024, Q10 and Q11).

Converted documents are valid for the buyer’s input VAT and serve as proof of both the sale and payment, from April 27, 2024 until they are fully consumed, provided none of the critical details listed in RR 7-2024 Sec. 3(D)(3) is missing. No RDO approval is needed for the stamping (RR 11-2024; RMC 77-2024, Q20).

The conversion came with a reporting step. Unused manual and loose-leaf ORs to be converted had to be reported to the RDO (or LT Office/Division) where the head office or branch is registered, through an inventory showing the number of booklets and serial numbers, in duplicate, on or before July 31, 2024 (RR 11-2024, amending RR 7-2024 Sec. 8(2.3); RMC 77-2024, Q21, using the Annex C format). Taxpayers that had already submitted an inventory before RMC 77-2024 was published did not need to resubmit. Branch inventories could be filed with the head office RDO (RMC 77-2024, Q22).

Taxpayers should obtain newly printed invoices with an ATP before the converted ORs run out (RR 11-2024).

Steps for a business that still has OR booklets today #

If you find old OR booklets in the cabinet in 2026, work through them in this order:

1. Check your files for a stamped receiving copy of the inventory report (or the TRRA portal email) filed on or before July 31, 2024, and list which booklets and serial numbers it covered.
2. For booklets covered by the inventory, you may continue issuing them as converted invoices until consumed, as long as each one is struck through, stamped “Invoice,” and carries all Sec. 6(B) details.
3. For booklets not covered by the inventory, use them only as supplementary documents (proof of payment), with “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” stamped on every page.
4. Make sure you already have ATP-approved invoices on hand, so the converted booklets are never your only sales document.
5. If the coverage of your 2024 inventory is unclear, ask your RDO before issuing more converted ORs.

CRM, POS, e-receipting, and invoicing software #

For machine- and system-generated documents, the rules were different (RR 11-2024, amending RR 7-2024 Sec. 8(3); RMC 77-2024, Q19 to Q24):

Item	Rule
Renaming “Official Receipt” to “Invoice” on CRM/POS/e-receipting/e-invoicing software	Treated as a minor enhancement. No RDO approval and no new PTU needed
CAS or computerized books with accounting records	Treated as a major enhancement. The taxpayer updates its system registration; the old AC or PTU is surrendered and a new AC is issued
Deadline to reconfigure	On or before December 31, 2024. Extensions, if approved by the Regional Director or the LTS Assistant Commissioner, could not run longer than six months from December 31, 2024
Serial numbers	The renamed invoice continues the last OR series (e.g., last OR# 0005000, first INV# 0005001)
Notice to the BIR	Notice of the starting serial number of the converted invoice, filed within 30 days from completion of the reconfiguration or on December 31, 2024, whichever came first (Annex D format)
System-generated ORs issued April 27, 2024 until reconfiguration	Valid for input VAT until December 31, 2024 or completion of reconfiguration, whichever came first, if struck through and stamped “Invoice” and no critical detail is missing

Read together, these rules mean that by mid-2025 at the latest, no machine or system should still be producing documents titled “Official Receipt” as the sales document.

Existing “Sales Invoice” booklets #

Booklets titled “Sales Invoice” that were printed under a valid ATP are valid invoices. You can keep issuing them. They need no stamping or conversion, because the title already carries the word “Invoice.” Just make sure the details you fill in cover the Part VI list, especially the VAT breakdown lines and, if you have such sales, the senior citizen and PWD fields.

What counts as non-issuance #

Under RR 11-2024 (amending RR 7-2024 Sec. 8(4)) and RMC 77-2024 (Q26 and Q27), each of these is treated as failure to issue an invoice:

• Issuing an unconverted manual or loose-leaf OR for a sale on or after April 27, 2024.
• Issuing a machine- or system-generated OR, with or without strike-through, for a sale after December 31, 2024 or after reconfiguration, whichever came first.
• Issuing only an OR, payment receipt, collection receipt, billing statement, or statement of account for a sale, with no invoice.

X. Electronic Invoicing: 2025 to 2026 Updates #

This part is a status note, not a compliance guide. Electronic invoicing rules have changed several times, and we expect more guidance.

RR 11-2025, dated February 25, 2025, implements Secs. 237 and 237-A of the Tax Code as amended by RA 12066 on electronic invoices and electronic sales reporting. It defines an electronic invoice as a system-generated invoice issued electronically with structured data that can be extracted and transmitted to the BIR. A photo or scan of a paper invoice is not an electronic invoice.

RR 26-2025, dated September 5, 2025, extended the compliance period. The following taxpayers have until December 31, 2026 to issue electronic invoices:

1. Taxpayers engaged in e-commerce or internet transactions classified as small, medium, or large (micro taxpayers are exempt).
2. Taxpayers under the Large Taxpayers Service.
3. Taxpayers classified as large under the EOPT Act and RR 8-2024.
4. Taxpayers using CAS, and computerized books of accounts with accounting records (with electronic invoicing) and other invoicing software.

Exporters, registered business enterprises with incentives, and POS users will be covered later, once the BIR’s system is in place and separate regulations are issued (RR 26-2025 Sec. 2). The Commissioner may extend the deadlines further (RR 26-2025 Sec. 3).

RMC 98-2026, dated September 22, 2026, sets operational guidelines. Among other points, it says covered taxpayers other than micro taxpayers must issue electronic invoices on or before December 31, 2026; that e-invoicing is separate from electronic sales reporting under Sec. 237-A, which applies only once the BIR issues its own implementing guidelines; that covered taxpayers must secure a Permit to Issue (PTI) Electronic Invoice from their RDO before issuing; that invoices made manually in office applications such as Word, Excel, Google Docs, or Google Sheets are not valid electronic invoices; and that during system downtime the taxpayer issues manual invoices duly registered with the BIR and later replaces them with electronic invoices referencing the manual ones.

Our advice for now is simple. Find out whether your business falls into one of the four covered groups, using your BIR classification under RR 8-2024 rather than how big the business feels. Then read RR 26-2025 and RMC 98-2026 in full and confirm the requirements with your RDO. We will update this section when the BIR issues further guidance.

XI. Penalties #

Violation	Penalty	Basis
Failure or refusal to issue an invoice, issuing an invoice that does not truly reflect or contain all required information, or using multiple or double invoices	Fine of ₱1,000 to ₱50,000 and imprisonment of 2 to 4 years, for each act or omission, upon conviction	NIRC Sec. 264(a); cited in RR 11-2024 and RMC 77-2024, Q26 and Q27
Printing-related violations listed in Sec. 264(b), including printing fraudulent invoices	Fine of ₱500,000 to ₱10,000,000 and imprisonment of 6 to 10 years	NIRC Sec. 264(b), as amended by RA 10963 (TRAIN)
Non-VAT seller issuing an invoice showing “VAT”	VAT under Sec. 106 or 108 without input tax credit, plus 50% surcharge	NIRC Sec. 113(D)(1) and Sec. 248(B)
VAT-registered seller issuing a VAT invoice for an exempt sale without “VAT-Exempt Sale” or the breakdown	Liable for VAT as if the sale were not exempt	NIRC Sec. 113(D)(2)
Failure to issue invoices by a VAT-registered person	Suspension of business operations and temporary closure of the establishment	NIRC Sec. 115(a)(1), as amended
Failure to transmit sales data from CRM/POS to the BIR’s electronic sales reporting system, once required	Per day, the higher of ₱10,000 or 1/10 of 1% of annual net income per the audited FS of the second preceding year; permanent closure if violations exceed 180 days in a year	NIRC Sec. 264-A
Using, selling, or keeping sales suppression devices or software	Fine of ₱500,000 to ₱10,000,000 and imprisonment of 2 to 4 years	NIRC Sec. 264-B

In practice, invoicing violations found during audits or Tax Compliance Verification Drives are commonly settled through a compromise penalty rather than a criminal case. The amounts follow the schedule in Annex A of Revenue Memorandum Order (RMO) No. 7-2015 and its amendments. For micro and small taxpayers, RR 6-2024 reduces the compromise penalty for violations of Secs. 113, 237, and 238 not involving fraud to 50% of the scheduled amount, implementing RA 11976 Sec. 45(e). Under RR 8-2024, micro taxpayers have gross sales below ₱3 million a year, and small taxpayers have ₱3 million to below ₱20 million.

A compromise is still a penalty. It is cheaper to issue the correct document.

XII. Common Mistakes #

1. Issuing an OR upon collection and treating it as the sales document. For services, the invoice should have gone out at billing. The OR at collection is proof of payment only.
2. Issuing a second invoice when the customer pays. One sale, one invoice. Use an OR or payment receipt for the collection (RMC 77-2024, Q15).
3. Still sending a “Statement of Account” as the bill. Service providers now issue a Billing Invoice upon billing (RMC 77-2024, Q14). A statement of account is still useful as a summary of unpaid invoices that you send to remind the customer of what is due. It is not proof of sale and does not replace the invoice.
4. Recording service output VAT on collection. For services rendered from April 27, 2024, output VAT follows billing.
5. Claiming input VAT on a supplier’s OR. Ask for the VAT invoice. A supplementary document is not valid support (RR 7-2024 Sec. 2(2)).
6. Forgetting the stamp on supplementary documents. “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” must appear on each one.
7. Leaving out the buyer’s TIN on B2B VAT sales of ₱1,000 or more. The buyer’s input VAT claim depends on it.
8. Omitting quantity and unit cost for services. Sec. 237(A) requires them. For services, use a sensible unit such as hours, sessions, lots, or months.
9. Non-VAT sellers using “VAT Reg TIN” on their invoices. This exposes the seller to VAT plus a 50% surcharge.
10. Using unregistered spreadsheet or word-processor invoices. Without an ATP or a registered system, the document is not a duly registered invoice.
11. Using one serial series for different invoice types. Each type needs its own series (RMC 77-2024, Q18).
12. No credit terms on the invoice. Without written terms, the uncollected receivables credit is hard to claim.

XIII. Frequently Asked Questions #

Our client still asks for an Official Receipt. Can we give one?
Yes. You may issue an OR as a supplementary document upon collection, stamped “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.” Explain to the client that the invoice is the document that supports their input VAT and expense.

We are a non-VAT freelancer. Do we still need invoices?
Yes, for each sale of ₱500 or more, when the client asks, and for the day’s aggregate small sales once they reach ₱500 (Sec. 237(A)). Your invoice is a Non-VAT Invoice and shows “Non-VAT Reg TIN.”

Can one invoice serve as both the sale document and proof of payment?
Yes, for a cash sale. One invoice can cover both the sale and the receipt of payment (RMC 77-2024, Q15 and Q16). For a credit sale, issue the invoice at the sale and a supplementary document at collection.

What if a client pays in advance before we render the service?
The amended Sec. 108(A) defines gross sales by reference to services already rendered, and the old deposit and advance payment language was dropped. Issue an acknowledgement or collection receipt for the advance and the invoice when the service is rendered. This is an area where we suggest confirming your specific contract terms with your tax adviser, because some contracts treat advances differently.

Do we need RDO approval to stamp old ORs as invoices?
No approval was needed for the stamping, but the inventory report of the booklets had to be filed by July 31, 2024 (RR 11-2024; RMC 77-2024, Q20 and Q21).

How long do we keep invoices?
Five years. RR 7-2024 Sec. 4, implementing amended Sec. 235, treats invoices and receipts as “other accounting records” that are kept with the books of accounts for five years from the day after the deadline for filing the return (or from the actual filing date, if late) for the year of the last entry. Keep them longer if there is a pending protest or refund claim involving those records. You may still see three years in the text of Sec. 237 of the Tax Code, but RR 7-2024 is the later rule, so use five years.

Are we covered by the December 31, 2026 e-invoicing deadline?
It depends on your classification and how you issue invoices. See Part X and confirm with your RDO.

Where do I get help with this in Oojeema?
Open a support ticket or chat with Jema from inside Oojeema, and our team will help you set up your invoice types and series.

XIV. Quick Checklist #

Use this as a monthly or pre-audit check. The letters suggest a light order to work through them.

• (A) Documents. Every sales document has “Invoice” printed prominently, a registered serial number, and all items in Part VI. Each invoice type has its own series.
• (B) Registration. Your invoices are covered by an ATP, or by your CAS registration (AC/PTU), CRM/POS permit, or other registered system. The footer details match.
• (C) Supplementary documents. ORs, collection receipts, delivery receipts, and statements of account carry “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX.”
• (D) Old ORs. You know which booklets were in the July 31, 2024 inventory. Unreported booklets are used only as supplementary documents.
• (E) Output VAT. Service sales are recorded in the month and quarter they are billed. Long-term contracts are invoiced monthly as services are rendered.
• (F) Input VAT. Every input VAT claim in your purchase journal is backed by a supplier’s VAT invoice, not an OR.
• (G) Credit terms. Credit sales show the agreed payment terms on the invoice, and uncollected items are listed individually in your Summary List of Sales.
• (H) E-invoicing. You have checked whether your business falls under RR 26-2025 and RMC 98-2026.
• (I) Records. Invoices and supplementary documents are kept for five years, longer if a protest or refund claim is pending.

XV. Conclusion #

The EOPT Act made the invoice the single document that proves a sale, and it put services on the same billing basis as goods. For most businesses the paperwork side is now settled: one invoice per sale, ORs only as proof of payment, and the “not valid for input tax” stamp on everything else. The part that still causes trouble is timing. Service businesses pay output VAT when they bill, so they need clean billing records, written credit terms, and a plan for the cash gap between billing and collection.

The transition rules for old ORs are mostly behind us, but they still matter when an examiner asks why a 2024 booklet was used in 2026. Keep the inventory report and stamped copies where you can find them. Electronic invoicing is the next change, and it is still moving, so treat Part X as a starting point and check the latest BIR issuances before you decide anything.

Oojeema can generate invoices, supplementary documents, and BIR reports such as the Summary List of Sales from the same transactions, which keeps your billing date and your VAT period in line. If you need help setting that up, open a support ticket or chat with Jema.

Related guides #

• BIR Form 2307: Filled-In Sample and How to Fill Out
• BIR Books of Accounts
• BIR Sales RELIEF
• BIR Form 2550Q: Quarterly VAT Return Guide
• Creating a Billing Invoice
• Creating a Sales Invoice

XVI. References #

Laws

1. Republic Act No. 11976, “An Act Introducing Administrative Tax Reforms, Amending [various sections] and Repealing Section 34(K) of the National Internal Revenue Code of 1997, as Amended, and for Other Purposes” (Ease of Paying Taxes Act), approved January 5, 2024. Text: https://lawphil.net/statutes/repacts/ra2024/ra_11976_2024.html. Publication and effectivity dates per BIR EOPT flyer: https://bir-cdn.bir.gov.ph/BIR/pdf/flyer-eopt.pdf
2. Republic Act No. 10963, Tax Reform for Acceleration and Inclusion (TRAIN) Law, December 19, 2017, for NIRC Secs. 237-A, 254, 264, 264-A, and 264-B. Text: https://lawphil.net/statutes/repacts/ra2017/ra_10963_2017.html
3. National Internal Revenue Code of 1997, as amended, Secs. 106, 108, 110, 113, 114, 115, 235, 236, 237, 237-A, 238, 248, 264, 264-A, and 264-B (as amended by RA 10963 and RA 11976, sources above).

Revenue Regulations

4. RR No. 3-2024, “Implementing the Amendments Introduced by Republic Act No. 11976, Otherwise Known as the ‘Ease of Paying Taxes Act’, on the Relevant Provisions of Title IV – Value-Added Tax (VAT) and Title V – Percentage Tax of the National Internal Revenue Code of 1997, as amended,” issued April 11, 2024, effective April 27, 2024. BIR digest: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%203-2024.pdf
5. RR No. 6-2024, implementing Section 45 of RA 11976 on reduced interest and penalty rates for micro and small taxpayers, issued April 11, 2024. BIR digest: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%206-2024.pdf
6. RR No. 7-2024, “Implementing Sections 113, 235, 236, 237, 238, 242, 243 of the National Internal Revenue Code of 1997, as Amended by Republic Act No. 11976, otherwise known as the ‘Ease of Paying Taxes Act’, on the Registration Procedures and Invoicing Requirements,” issued April 11, 2024, effective April 27, 2024. BIR digest: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%207-2024.pdf
7. RR No. 8-2024, implementing Section 21(b) of the Tax Code, as amended by RA 11976, on the classification of taxpayers, issued April 11, 2024. BIR digest: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%208-2024.pdf
8. RR No. 11-2024, “Amending the Transitory Provisions of Revenue Regulations No. 7-2024 Relative to the Deadlines for Compliance with the Invoicing Requirements,” dated May 27, 2024, posted June 13, 2024. Full text: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%20No.%2011-2024.pdf
9. RR No. 11-2025, “Implementing Sections 237 and 237-A of the National Internal Revenue Code of 1997 (Tax Code), as Amended by Republic Act No. 12066,” dated February 25, 2025. Full text: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%20No.%2011-2025.pdf
10. RR No. 26-2025, “Amending the Transitory Provisions of Revenue Regulations No. 11-2025 Extending the Compliance Period for Electronic Invoice Issuance by Covered Taxpayers,” dated September 5, 2025. Full text: https://bir-cdn.bir.gov.ph/BIR/pdf/RR%20No.%2026-2025.pdf

Revenue Memorandum Circulars and Orders

11. RMC No. 77-2024, “Clarification on the Invoicing Requirements Provided Under Revenue Regulations (RR) No. 7-2024, as Amended by RR No. 11-2024,” July 11, 2024. Full text: https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2077-2024.pdf. Digest: https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2077-2024%20Digest.pdf
12. RMC No. 98-2026, “Prescribing Policies and Guidelines on the Issuance of Electronic Invoice under Revenue Regulations (RR) No. 8-2022 and RR No. 11-2025, as Amended by RR No. 26-2025,” September 22, 2026. Full text (redacted copy): https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2098-2026%20redacted.pdf
13. RMO No. 7-2015, Annex A, schedule of compromise penalties, as referenced in RR 6-2024.