What It Means
- The BIR seal badge deadline of October 31, 2026 under RMC 99-2026 waives penalties arising solely from non-display of the badge, and nothing beyond that.
- Online sellers, online merchants, digital platform operators and anyone with an online business presence are covered, including sellers who operate only on Facebook.
- The badge is generated from a valid BIR registration, so a seller with no registration cannot comply by displaying anything.
- New registrants face three working days of Revenue District Office approval against a deadline that falls on a Saturday.
- The circular states no penalty amount and says nothing about what applies after October 31.
The BIR seal badge deadline is October 31, 2026, and it is narrower than most headlines made it sound. Revenue Memorandum Circular No. 99-2026 gives online sellers until that date to display the BIR Registration Seal Badge without penalties arising solely from not displaying it. It does not give anyone more time to register, and it says nothing about November 1.
That difference decides who is protected. The badge is not an image a seller can download on a whim. It is generated from a valid BIR registration, which means a seller with no registration has nothing to display and no waiver that speaks to that situation.
The BIR seal badge deadline waives display penalties only
RMC 99-2026 is dated July 22, 2026. The copy in circulation carries a received stamp from the BIR Records Management Division dated September 24, 2026. Both dates are facts, and the circular does not explain the gap between them.
The circular reiterates the requirement under Section 5(H) of Revenue Regulations No. 7-2024 and Section 7 of Revenue Regulations No. 15-2024 to post proof of BIR registration on online websites, e-commerce or e-marketplace pages, social media pages and other digital platforms. The badge itself comes from RMC 38-2026, issued April 29, 2026, which replaced the earlier practice of posting the full certificate of registration.
The operative language is short. Covered taxpayers are reminded that the display requirement has to be complied with immediately. The BIR then extends the compliance period to October 31, 2026 for those who have not yet displayed the badge, without the imposition of “penalties arising solely from the non-display thereof.”
That much is fact. What follows is interpretation. The BIR seal badge deadline waives one category of penalty, the kind that arises from a missing badge and nothing else. A seller who is registered and merely late with the display is covered. A seller whose badge is missing because no registration exists is not described anywhere in the waiver. This reading comes from the plain text of the circular and is not a statement from the BIR.
The circular also contains no penalty amount and no procedure for what applies after the BIR seal badge deadline passes. No peso figure appears in the circular, so any figure attached to the announcement comes from somewhere else. The same QR code that makes the badge scannable also turns registration into a verification layer that platforms and buyers can read at a glance.
Facebook-only sellers, marketplace sellers and creators are covered
Coverage under the BIR seal badge deadline follows the circular’s own wording. RMC 99-2026 names online sellers, online merchants, persons selling goods or services through digital or electronic platforms, and those with an online business presence. Digital platform operators are listed among the taxpayers reminded of the requirement.
A seller on Facebook or Instagram with no physical store fits that wording. So does a Shopee, Lazada or TikTok Shop seller, and the requirement is not limited to new sellers. It rests on regulations issued in 2024, and RMC 38-2026 only introduced the badge as the way to display proof.
A store with a physical shop and an online page is covered through its online presence. That is a reading of the wording, as is the reverse case. A business that sells only in person and has no online channel falls outside it.
Content creators and influencers are the contested group. A KPMG summary of RMC 38-2026 says the badge must be displayed on the seller’s, content creator’s or online influencer’s website, page or shop. RMC 99-2026 does not name creators. Whether an individual creator is covered in practice turns on a prior question, which is whether that person is registered with the BIR as a business or professional.
| Seller type | Covered | Route to the badge |
|---|---|---|
| Registered Facebook or Instagram seller | Yes | Generate through ORUS |
| Unregistered Facebook, Instagram or TikTok seller | Requirement applies, badge unavailable | Register first |
| Shopee, Lazada or TikTok Shop seller | Yes | Generate through ORUS |
| Physical store with an online page | Yes, through online presence (reading) | Generate through ORUS |
| Creator, vlogger or influencer | Named in RMC 38-2026 per KPMG summary | Depends on registration status |
| Digital platform operator | Named in RMC 99-2026 | Generate through ORUS |
| Seller with no online channel | Outside the wording (reading) | None under this circular |
Unregistered sellers cannot generate a badge
The BIR’s ORUS guide, Annex C of RMC 38-2026, sets the order for any seller approaching the BIR seal badge deadline without a registration. A taxpayer needs an ORUS account first, and anyone without one must enroll under RMC 122-2022. A new registrant then files the registration form in ORUS, Form 1901 for individuals or Form 1903 for non-individuals, and waits for Revenue District Office approval within three working days. After approval the ₱30 loose documentary stamp tax is paid inside ORUS, and only then can the certificate of registration be generated.
October 31, 2026 falls on a Saturday. Three working days of approval, followed by payment, means a registration started in the last week of October can run past the cutoff. A seller who begins that process after the BIR seal badge deadline passes carries the full display exposure with no waiver left to rely on.
Unregistered selling also becomes visible. PwC’s summary of RMC 38-2026 says government agencies, banks, financial institutions and e-commerce platforms may verify a badge by scanning its QR code. A page with no badge now shows its absence to anyone who checks.
Registration brings the filing obligations that attach to a registered business. Whether registering now carries any consequence for earlier unregistered selling is not addressed in the circular or in the ORUS guide, and none of the sources reviewed for this article confirms it either way.
Registered sellers have two routes to the badge
A registered seller with accurate records follows RMC 64-2026, issued June 18, 2026 as a supplement to RMC 38-2026. The steps are to log in to ORUS, synchronize the registration record from the profile page, open Certificates and Permits, and download the latest certificate with its QR code together with the badge. A Moore Roxas Tabamo summary of the circular lists the ₱30 documentary stamp tax as payable through BIR ePayment channels on this route. The BIR’s copy of the circular was not legible in the file reviewed, so that point rests on the law firm’s summary. For a registered seller with current records, the BIR seal badge deadline comes down to a login and a ₱30 payment.
A seller whose registration needs changes takes the second route. Annex C directs existing taxpayers to Update Information, then Correction, Change or Update of Registration, then submission, payment of the ₱30 tax, and generation of the updated certificate. The change that matters most for online sellers is the business code. A KPMG summary of RMC 38-2026 says the applicable PSIC or PSOC code must be reflected in the certificate. Reading that literally, a registration whose code does not cover online selling or digital services needs correcting before a badge can be issued.
Older certificates without a QR code do not have to be replaced. The BIR encourages updating them to secure the badge, which makes the update optional on paper and unavoidable for any seller who wants to comply.
The badge itself is free, and the BIR describes it as available to all business taxpayers. Issuance is also possible manually through a Revenue District Office. RDO counters follow working days and October 31 is a Saturday, so the practical last day for that route is Friday, October 30. That is a practical reading, not a BIR statement.
The badge goes on every official online page and only the badge goes up
RMC 38-2026, as summarized by PwC, tells sellers to post the badge and not the full certificate, which would expose the taxpayer’s TIN and address. The badge may be cropped or extracted from the certificate, but it must stay clear, readable and unaltered, and it must sit where customers can see and reach it. The BIR’s own rollout graphic places it in a website footer, an e-commerce shop header and a social media page profile.
The BIR seal badge deadline applies to each official page where goods or services are offered. RMC 99-2026 lists websites, e-commerce or e-marketplace pages, social media pages and other digital platforms, and PwC’s summary of RMC 38-2026 describes the posting locations as including but not limited to those. Read literally, a seller with a Facebook page, an Instagram account and a Shopee shop has three places to post.
The QR code is what gives the posting weight. Platforms, banks and agencies can scan it, which turns a registration into a status anyone relying on the seller can check. The badge adds a tax registration layer to what DTI online marketplace compliance rules already require of marketplace sellers.
Registration status carries everything behind the badge
The badge does not replace registration, and it does not replace the filings that follow from it. It displays a status that already exists or does not. What changes at the BIR seal badge deadline is who can see that status and how quickly.
A seller who is late with an upload needs a login and, on current guidance, ₱30. A seller whose Facebook or TikTok page has operated without registration faces the full registration process on a weekday schedule against a Saturday cutoff. Creators earning from brand deals and platform payouts without a business registration are in the same position, since RMC 38-2026 reaches their pages.
Registration is the dividing line, and the BIR seal badge deadline did not move it. Sellers with a current registration face a login and a small payment. Sellers without one face the whole process, and the waiver in RMC 99-2026 releases them from nothing except the penalty for a missing badge.
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