Billing statement vs BIR invoice: what Filipino freelancers can issue

If you're a freelancer, virtual assistant or small business in the Philippines, you've probably been asked for two different things: an invoice by a client abroad, and an official BIR invoice by a client at home. They aren't the same document, and mixing them up is the most common source of confusion since the Ease of Paying Taxes (EOPT) Act changed the rules in 2024.

This guide explains what each document is for, what your BIR invoice needs, and where a free Philippine invoice generator fits in.

The BIR invoice: your primary tax document

Under the EOPT Act (Republic Act No. 11976) and Revenue Regulations No. 7-2024, the invoice became the single primary document for sales of goods and services from April 2024. The official receipt is now only a supplementary document: proof that you were paid, not the basis of your tax.

You must issue an invoice for every sale of ₱500 or more, and for any amount when the buyer asks for one. Small sales below ₱500 can be summarised in one invoice at the end of the day.

What makes an invoice a BIR invoice isn't its layout. It's where it comes from. It must be either:

• printed in a booklet by a BIR-accredited printer under an Authority to Print (ATP), with the ATP number, the printer's accreditation and the serial range at the bottom; or
• generated by a system registered with the BIR: a computerized accounting system (CAS) or an e-invoicing system.

A PDF from a website you haven't registered with the BIR is neither. That's why Invoice Native never calls its documents "Sales Invoice" or "Service Invoice", and never presents them as BIR invoices.

Non-VAT sellers: the input-tax notice

Most freelancers are non-VAT: their gross sales are under the ₱3,000,000 VAT threshold, and they pay percentage tax or choose the 8% income tax rate instead. A non-VAT seller's documents must say, in bold:

THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX

It tells a business buyer that there's no VAT on the document to claim. Invoice Native prints it on every Philippine document it makes, including billing statements, invoices, quotations and credit notes, so you never send one without it.

Once your sales pass ₱3,000,000 in a 12-month period, you must register for VAT. VAT invoices must come from your ATP booklet or registered system, and a generator like this one can't make them for you.

Billing statements for clients at home

Many Philippine businesses send a billing statement or statement of account before the official invoice. It lists the work, the amount due, the due date and how to pay, so the client's accounts team can approve and schedule the payment. When the client pays, you issue the BIR invoice from your booklet or system.

A billing statement is a normal commercial document. It's useful precisely because it's quick to make and easy to send by email. It doesn't replace your BIR invoice. Invoice Native titles documents for clients in the Philippines "Billing Statement" for that reason.

Invoices for clients abroad

Freelancers billing clients in the United States, Australia, the United Kingdom, Singapore or elsewhere are asked for an invoice in the client's own currency, usually US dollars. Those clients pay through PayPal, Wise, Payoneer or a bank transfer, and they don't claim Philippine input tax.

A clean commercial invoice in USD, AUD, GBP, EUR or SGD is what they need. When you choose Client outside the Philippines in Invoice Native, the document is titled "Invoice", asks for your client's country and lets you pick their currency. It still carries the input-tax notice.

For your own books, record the same sale in your BIR invoice booklet or registered system. The BIR looks at your invoices and your books, not at the PDF your client received.

E-invoicing: RMC No. 98-2026

In September 2026 the BIR issued Revenue Memorandum Circular No. 98-2026, setting out the rules for electronic invoicing. Covered taxpayers must issue electronic invoices by 31 December 2026. They include:

1. taxpayers selling through e-commerce or the internet;
2. taxpayers under the Large Taxpayers Service, and large taxpayers;
3. taxpayers using a computerized accounting system, computerized books or other invoicing software.

Micro taxpayers aren't covered: under the EOPT classification, those with gross sales under ₱3,000,000. They may adopt e-invoicing voluntarily, with the BIR's authorization.

Covered taxpayers also need a Permit to Issue electronic invoices and must certify their system. The BIR has said it hasn't accredited any private company as an official e-invoicing provider, so treat anyone claiming to be one with care.

What to do, step by step

1. Register with the BIR and keep your Certificate of Registration (Form 2303) up to date.
2. Get your BIR invoices from an ATP booklet, or register your invoicing system if you use one.
3. Send clients what they ask for: a billing statement for a client at home, or an invoice in their currency for a client abroad.
4. Issue the BIR invoice for each sale and keep your books for five years.
5. Check e-invoicing once your sales near ₱3,000,000, or if you start using invoicing software you register with the BIR.

Paying you

Philippine clients usually pay by GCash, Maya or bank transfer through InstaPay or PESONet. Clients abroad use PayPal, Wise or Payoneer. Put your GCash or Maya number, your bank details or a payment link on the document so clients can pay without asking.