Quick Read
- The DTI Trustmark vs BIR seal contest has ended in two pulled-back mandates, as DTI made the Trustmark voluntary on October 15, 2025, and the BIR suspended mandatory display of its seal on October 26, 2026 until further notice.
- RMC 113-2026 suspends mandatory display and the October 31 deadline, bars penalties solely for non-display, and the Commissioner said the BIR will work with the National Privacy Commission.
- The BIR seal was introduced as an alternative to an existing posting duty while DTI’s order created a new paid badge requirement, yet the BIR retreated within two days of the senators’ appeal, citing data privacy, technical issues and scope rather than cost.
- Sellers pay ₱130 to ₱1,130 for a Trustmark that remains available, while the free BIR seal is paused with no end date.
- The Trustmark application already requires the BIR Certificate of Registration, which makes BIR registration the common gate for both badges.

The DTI Trustmark and the BIR registration seal look alike on a seller’s storefront, but they were built on different footing, and both mandates have now been pulled back. DTI made its Trustmark voluntary on October 15, 2025, weeks after its order. The BIR suspended mandatory display of its seal on October 26, 2026 through RMC 113-2026, two days after Sen. Bam Aquino asked for a pause and Sen. Pia Cayetano raised privacy concerns. This Trustmark vs BIR seal comparison sets the two side by side on what each proves, its legal basis, who pays, how each was rolled out and where each is vulnerable.
DTI Trustmark vs BIR Seal Starts With What Each Badge Proves
The two badges answer different questions for a buyer. The Trustmark says a business follows e-commerce rules, and the BIR seal says a business is registered with the tax bureau.
| Dimension | DTI Trustmark | BIR registration seal |
|---|---|---|
| Legal basis | RA 11967 section 11, DAO 25-12 | RR 7-2024 section 5(H), RR 15-2024 section 7, RMC 38-2026 |
| Status today | Voluntary through December 31, 2026, with a DTI review after | Mandatory display suspended until further notice under RMC 113-2026 |
| Who is covered | Online merchants, e-retailers, e-marketplaces and digital platforms | Online sellers, service providers, professionals, bloggers, vloggers, live streamers, creators and influencers earning online |
| What it proves | Compliance with minimum legal and regulatory standards, not quality | Registration with the BIR |
| What it requires | Business registration, BIR Certificate of Registration, ID, platform list, written complaints process | Registered business with the right PSIC or PSOC code on the Certificate of Registration |
| Cost | ₱130, ₱630 or ₱1,130 by enterprise size | Free badge, ₱30 documentary stamp tax when secured online |
| Verification | QR code to the DTI Trustmark portal | QR code to the BIR verification site |
| Sanction | Suspension or revocation of the Trustmark | No penalty solely for non-display during the suspension |
Coverage differs at the edges. The Internet Transactions Act excludes online media content and consumer-to-consumer transactions from its scope, while the BIR circular names bloggers, vloggers, live streamers, content creators and influencers earning from online views, ads, affiliate commissions or sponsorships.
The Legal Chain Is Where the Two Rollouts Split
DTI’s Statute Only Encourages a Trustmark
The Internet Transactions Act says DTI “shall encourage the development” of a Trustmark that an industry-led private body may run. The same law says the e-commerce bureau’s powers must not be exercised in a way that creates barriers to entry or impedes the ease of doing business. Aquino argued in early October 2025 that DAO 25-12 conflicted with that Act and with the Ease of Doing Business Act. DTI’s own FAQ page says all online merchants must be Trustmark-registered, then says applying is voluntary. DTI can point to a real registration hook, since the Act tells the bureau to exert efforts to enforce the registration of digital platforms and online merchants with the bureau, but the Act’s list of administrative fines contains none for lacking a Trustmark.
The BIR Seal Rests on a Duty That Predates It
RMC 38-2026 cites two existing provisions, section 5(H) of RR 7-2024 and section 7 of RR 15-2024, as requiring sellers to post proof of registration online. The Commissioner’s statement describes the badge as an alternative to posting the full Certificate of Registration. The circular text contains no penalty language of its own. Neither RMC 113-2026 nor the Commissioner’s statement says whether the duty to post the full certificate returns during the suspension.
Each Type of Seller Pays a Different Price
| Actor | DTI Trustmark | BIR registration seal |
|---|---|---|
| Micro sellers, assets up to ₱3 million | ₱130 in total fees, plus documents and a written complaints process | Free badge, ₱30 documentary stamp tax when secured online |
| Small sellers, ₱3 million to ₱15 million | ₱630 in total fees, plus the same documents | Same as above |
| Medium and larger sellers | ₱1,130 in total fees, plus the same documents | Same as above |
| Freelancers, creators and influencers | Outside the Act for online media content and consumer-to-consumer sales | Named in scope, and the Certificate of Registration needs the right code |
| Unregistered sellers | Cannot apply without a BIR Certificate of Registration | Still exposed under existing registration rules, since RMC 113-2026 suspends only badge display |
| Platforms and e-marketplaces | Covered as Trustmark registrants themselves | Named among parties that may scan the badge’s QR code, and not mentioned in the suspension documents |
In Trustmark vs BIR seal terms, registered micro and small sellers pay the least under the BIR seal and carry the most paperwork under the Trustmark. Unregistered sellers are the clearest losers, since they are locked out of the Trustmark and still exposed under the BIR’s registration rules. Platforms and registered businesses gain, because a scannable badge lowers the cost of telling legitimate sellers from the rest.
The Rollout Mechanics Show Two Different Playbooks
| Dimension | DTI Trustmark | BIR registration seal |
|---|---|---|
| Type of obligation | New paid badge, after DAO 25-12 made a voluntary Trustmark mandatory | Alternative to posting the full Certificate of Registration online |
| Runway | Deadline of September 30, 2025, moved to December 31 within weeks, then dropped | Circular issued April 29, 2026, with a display deadline later extended to October 31 under RMC 99-2026 |
| Consultation | Pushback came after issuance, with Aquino’s call in early October and a town hall on October 15 | No public consultation turned up in the reporting reviewed |
| Operating readiness | Fee guidance still being finalized as of mid-October | User guide annexed to the circular |
| Public framing | Compliance indicator that the FAQ says does not certify quality | Alternative to posting the full certificate online |
| Timing of concession | After backlash, with the mandate dropped October 15 | Twice, with the deadline extended to October 31, then display suspended on October 26 |
| Main objection | Cost, duplication and conflict with the Acts | Data privacy, technical issues and scope, in the Commissioner’s own words |
| State today | 18,405 applications as of December 22, 2025, with a review after December 31, 2026 | More than 52,700 badges reported on October 19, 2026, display suspended, and issued badges may still be shown |
The Trustmark vs BIR seal record shows the BIR conceded twice, and the second concession was the mandate itself, granted within two days of the senators’ appeal. DTI conceded once and late, but its program stayed open, with applications still accepted and a review set for after December 31, 2026. RMC 113-2026 suspends display only and says nothing on issuing badges.
Each Agency Has a Different Weak Point
| Weak point | DTI Trustmark | BIR registration seal |
|---|---|---|
| Legal footing | The statute encourages, the order mandated, and the FAQ page says both | The duty is cited from existing regulations, but the circular text has no penalty language |
| Messaging | A compliance indicator that the FAQ says is not a quality certification | Introduced as an alternative to posting the certificate, then suspended on data privacy grounds |
| Scope clarity | Duplicates documents sellers already file, though the Act tells DTI to reuse existing databases | Scope was among the concerns the Commissioner cited |
| Enforcement path | No fine for lacking a Trustmark in the Act’s list of administrative fines | Relies on parties such as platforms and banks scanning the QR code |
| Data question | Portal publishes store name, registration information and platforms used | Cayetano said sellers worry the QR code could expose full legal names, which was not verified, and the BIR said it will work with the National Privacy Commission |
The difference is timing and what survived. DTI’s weak points surfaced within weeks of the order and left a live program, while the BIR’s surfaced at the display deadline and left a paused one.
The Likely Endgame Runs Through Registration
The Act tells DTI to use existing business databases and coordinate with other agencies. The Trustmark application already requires the BIR Certificate of Registration, and the BIR seal comes from that same registration. Aquino’s own proposal was to fold the Trustmark into business registration or renewal and make it free. DTI’s review after December 31, 2026 is where that route could be taken, though nothing announced commits DTI to it.
The Trustmark vs BIR seal question ends in registration data. The Trustmark kept its program and lost its mandate. The BIR seal kept its issuance and lost its display requirement, with no end date. Sellers now hold a badge nobody must post, and DTI holds a program nobody must join. What moves next is the data behind both, meaning the registration record the Trustmark already depends on, and the QR page the BIR has said it will address with the National Privacy Commission and affected taxpayers.
FAQs
Is the DTI Trustmark mandatory right now?
Registration is voluntary. DTI said in December 2025 that it would keep it voluntary through 2026 and review the policy after December 31, 2026. DTI’s FAQ page still says online merchants must be Trustmark-registered under the Act, and also says applying is voluntary.
Does the BIR seal replace the Certificate of Registration?
The seal was introduced as an alternative to posting the full certificate online, not to holding one. The circular lists the industry codes that must appear on the certificate, so a seller still needs a valid registration behind the badge.
Does a seller have to display the BIR seal right now?
No. RMC 113-2026 suspends the mandatory display until further notice, and no penalty is imposed solely for non-display during the suspension. Sellers who already hold a badge may keep displaying it at their option.
Which badge comes first in the Trustmark vs BIR seal sequence?
BIR registration comes first, because DTI’s Trustmark application requires the BIR Certificate of Registration.
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