Quick Read
- The Oct 31 compliance deadline for BIR registration badge is suspended along with it, and no penalty applies solely for not posting the badge.
- Sellers who never secured a badge gain, while sellers who applied early spent effort on a requirement now suspended.
- Buyers and e-commerce platforms lose the one uniform way to verify a seller by scanning a QR code.
- The circular cites registration verification initiatives, while the Commissioner’s statement cites privacy, technical issues, and scope.
- No document says what the full Certificate of Registration posting rule requires in the meantime.
The Bureau of Internal Revenue suspended the mandatory display of the registration badge on Oct 26, five days before online sellers were due to comply. RMC 113-2026 lifts the penalty for not posting it, and the Commissioner’s statement drops the Oct 31 deadline with it. The circular does not address the rule behind the badge. The BIR Registration Seal Badge was introduced as an alternative to posting the full Certificate of Registration online, and no document says what that original rule demands while the alternative is suspended.
BIR Suspends the Registration Badge but the Penalty Relief Is Narrow
RMC 113-2026, dated Oct 26 and signed by Commissioner Charlito Martin R. Mendoza, suspends the mandatory display of the BIR Registration Seal Badge prescribed under RMC 38-2026, as supplemented by RMC 64-2026 and 99-2026, until further notice. Taxpayers who already hold the badge may keep posting it at their option. The circular is addressed to all internal revenue officials, employees, and others concerned, and directs them to give it wide publicity.
The penalty relief is worded for the registration badge only. The circular says no penalties apply “solely on account of non-display” of the badge during the suspension. It says nothing about the registration obligation itself or the penalties tied to it. The Oct 31 deadline appears in the Commissioner’s statement, which says he directed its suspension together with the mandatory online posting.
Neither Document Touches the Rule the Badge Replaced
RMC 38-2026, issued on Apr 29, implements the requirement to post proof of registration online under Section 5(H) of Revenue Regulations No. 7-2024 and Section 7 of Revenue Regulations No. 15-2024, according to tax advisories on the circular. The Commissioner’s statement describes the badge as an alternative to posting the full Certificate of Registration online, as those regulations require.
RMC 113-2026 suspends the alternative. Neither it nor the statement amends, suspends, or restates either regulation. Whether the posting requirement can be enforced against online sellers while the registration badge is optional is a question for a tax practitioner, and the documents do not answer it.
The statement says protecting personal information online is a harder problem than showing a COR at a physical shop, which is the concern the badge was meant to address.
Early Adopters and Platforms Carry the Cost While Unbadged Sellers Gain
Sellers, freelancers, and creators who are registered but never secured a registration badge gain. They skip securing it through the Online Registration and Update System or a Revenue District Office, and they skip the public posting.
Securing the badge is free, but it carried a ₱30 Loose Documentary Stamp Tax, according to a tax advisory. Sellers who paid it and posted early spent that money and effort on a display requirement that is now suspended.
BIR said more than 52,700 registration seal badges had been secured by online sellers, service providers, and content creators as of Oct 14. No total of covered taxpayers accompanies that count, so it cannot be turned into a compliance rate.
Buyers and e-commerce platforms lose a practical check. RMC 38-2026 lets banks, government agencies, e-commerce platforms, and other relying parties verify a seller by scanning the badge’s QR code. With the registration badge optional, that check works only on sellers who choose to post it.
The Circular and the Statement Give Different Reasons
The circular gives its reason as the orderly implementation of the Bureau’s “registration verification initiatives” and does not describe them. The Commissioner’s statement cites data privacy, technical issues, and the scope of the requirement. It says BIR will work with the National Privacy Commission and consult affected taxpayers, and it gives no date for either.
The statement also ties the planned consultation to the intent of the Ease of Paying Taxes Act to simplify compliance, the law under which both regulations were issued. The two documents point to different problems, one about how BIR checks registration and one about how sellers’ personal data is shown. Neither document describes how registration will be verified while the registration badge is optional.
The Display Rule Has Been Adjusted Three Times Since April
Four circulars have shaped the badge since April.
| Issuance | Date | What it did |
|---|---|---|
| RMC 38-2026 | Apr 29, 2026 | Introduced the badge as an alternative to posting the full COR online |
| RMC 64-2026 | Jun 18, 2026 | Added guidelines for generating the badge online for taxpayers with no COR updates |
| RMC 99-2026 | Sept 24, 2026 | Moved the display deadline to Oct 31, according to published reports |
| RMC 113-2026 | Oct 26, 2026 | Suspended mandatory display until further notice |
RMC 99-2026’s date and content come from published reports, and RMC 113-2026 confirms it exists. A seller who planned around the Oct 31 deadline saw that date set and then suspended within five weeks.
BIR Holds the Next Move
Sellers who posted early hold the public proof of registration, while sellers who did not hold penalty relief written for the badge alone. Platforms and buyers lose a uniform check, and the registration badge stays optional until BIR says otherwise. The Bureau has set no date for its consultation with the National Privacy Commission.
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