BIR Authority to Print (ATP) vs system-generated invoices: who still needs printed booklets

Many businesses issue invoices from a system and keep a printed booklet in the drawer for the day the system goes down. The BIR treats the two differently. Under RR 7-2024, manual invoices need an Authority to Print, while a registered CAS needs an Acknowledgement Certificate for the invoices it generates. This guide explains the split as the rules stand in October 2026.

What an ATP is

Section 238 of the Tax Code, as amended by the EOPT Act (RA 11976), says every person engaged in business must secure an authority to print from the BIR, free of charge, before a printer can print its invoices. The BIR grants it only if the invoices are serially numbered and show the name, TIN and business address of the user. Printers must keep a logbook of the taxpayers they print for, with the number of booklets and the serial numbers.

RR 18-2012 adds the operating rules that still frame the ATP:

• Accredited printers only. Only BIR-accredited printers have the authority to print principal and supplementary invoices.
• One ATP per establishment. The head office and each branch file separately, and each keeps its own serial series showing its own address, TIN and branch code.
• The ATP travels with the booklet. A copy of the ATP is printed on the inside back cover of each booklet or pad.

RMO 12-2013 lists what goes at the foot of each printed invoice: the accredited printer's name, address, TIN and accreditation details, and the ATP number and date issued. Under RR 7-2024 Section 6(B.19), the bottom of a manual invoice shows the ATP number or OCN and date issued, the BIR permit number for loose-leaf invoices, and the approved serial numbers.

RR 7-2024 also sets out which authority goes with which kind of invoice: an ATP (or BIR printed invoices) for manual invoices, a Permit to Use for loose-leaf invoices plus an ATP for computer-aided invoices, and an Acknowledgement Certificate for a CAS or its components. Section 7 repeats that anyone who will use manual invoices secures an ATP before an accredited printer prints them.

Applying for an ATP: Form 1906 and ORUS

The ATP application form is still BIR Form 1906, revised in October 2025 and now titled "Application for Authority to Print Invoices" (RMC 97-2025). Under RMO 12-2013 it is filed with the RDO or Large Taxpayer office that has jurisdiction over your head office. The documents listed there include a sample layout of the invoice, the printer's job order and a copy of your previous ATP. Ask your RDO for its current checklist, because requirements are updated over time.

The process has moved online. RMC 153-2022 announced that ATP applications are available in the BIR's Online Registration and Update System (ORUS) in all RDOs from 16 January 2023. Since 15 January 2024, branches can apply for their own ATP through a separate ORUS branch account (RMC 10-2024). For a new business, RR 18-2012 says the ATP is secured together with the Certificate of Registration.

No more five-year expiry

RR 18-2012 made an ATP valid until the series was used up or for five years, whichever came first. RR 6-2022 removed that limit. ATP invoices and their serial numbers no longer expire, and the "valid until" date is no longer printed. RMC 123-2022 says the change took effect on 16 July 2022.

• Booklets whose old validity ran to 16 July 2022 or later can be used until fully exhausted. The printed validity date is simply disregarded.
• Booklets that had already expired on or before 15 July 2022 cannot be used, and were to be surrendered to the RDO for destruction.
• The same regulation removed the five-year validity of the Permit to Use for CRM and POS machines.

Pre-printed ATP invoice vs system-generated invoice

The choice also changes how the BIR classifies your system. Under RMO 9-2021, a CAS covers the full cycle, including system-generated invoices. If invoices are issued manually, the system is treated as a CBA. Our CAS and CBA registration guide covers that registration.

Who still needs an ATP

• Businesses that issue invoices from booklets or pads. Every printed invoice, principal or supplementary, needs an ATP.
• Computer-aided loose-leaf invoices. Invoices typed or printed onto loose-leaf forms, rather than generated by a registered CAS, need a Permit to Use for loose-leaf invoices and an ATP (RR 7-2024).
• CBA users. RMO 9-2021 says a registered system that does not generate invoices needs an ATP for them. A system that prints supplementary documents but uses manual principal invoices must declare those ATP invoices in its sworn statement.
• Back-up for a registered CAS. If your system has no redundancy or automatic switchover, RMO 9-2021 allows manual invoices during downtime. The pre-printed, pre-numbered back-up invoices set aside under an approved ATP should not exceed 1,000 sets at a time.
• Back-up for e-invoicing. RMC 98-2026 says that when system downtime, power interruption or similar events prevent an e-invoice, the taxpayer "shall issue a manual invoice duly authorized by the Bureau". It does not name the ATP, but a printed manual invoice is the kind RR 7-2024 ties to an ATP. Upon system restoration, the manual invoices are replaced with e-invoices "bearing the reference numbers of the manual invoices". E-invoicing also needs its own Permit to Issue (PTI), which RMC 98-2026 says is separate from the system's AC or PTU. See our BIR e-invoicing guide.

What the EOPT Act changed

RR 7-2024 made the invoice the proof of sale for goods and services, and the official receipt became a supplementary document. RMC 77-2024 confirms that a service business switching from ORs must apply for a new ATP for invoices, and that each type of invoice (for example a cash invoice and a charge invoice) needs its own serial series.

For unused ORs, RR 11-2024 gave two options. Use them as supplementary documents stamped "THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX", or strike out "Official Receipt", stamp "Invoice" and use them until they run out. The stamping needs no RDO approval, but unused ORs to be converted into invoices had to be reported by 31 July 2024. RR 11-2024 also tells taxpayers to obtain newly printed invoices with an ATP before the converted ORs run out. RMC 77-2024 lists back-up manual ORs converted to invoices among the documents usable until fully consumed.

Systems followed different rules. CRM and POS users could rename "Official Receipt" to "Invoice" and continue the same series. A registered CAS or CBA needed a new Acknowledgement Certificate. Any system-generated "official receipt" issued for a sale after 31 December 2024, or after the reconfiguration if that came first, is not evidence of a sale. The full field list is in our EOPT invoice requirements guide.

One more change affects printed stock. RR 6-2026 adds creditable withholding tax, if applicable, as a separate item on invoices. Its transitory rule lets unused invoices be used until consumed if "Less: Withholding Tax" is stamped conspicuously on them, and newly printed invoices must reflect the phrase before use. RMC 112-2026, issued on 22 October 2026, clarifies this. According to published summaries, the withholding line is needed only on sales subject to withholding, and no new ATP is needed solely because an existing layout lacks the field. Include the line in your next ATP layout.

Where Odoo fits

Odoo issues system-generated invoices. Registered as your CAS, it falls under the Acknowledgement Certificate route in RR 7-2024 rather than the ATP route for manual invoices. The layout is set under Settings > Companies > Configure Document Layout, where Odoo 19 lets you set the layout, logo, address, footer and the company tax ID. The BIR fields themselves need more than that:

• Odoo 20. The release notes update Philippine invoices for BIR and CAS requirements and add statutory discounts for senior citizens and persons with disabilities. Check the printed result against the RR 6-2026 withholding line before go-live.
• Odoo 19 and earlier. The layout is customised to add the "VAT Reg TIN" line, the VAT breakdown, the buyer TIN, the withholding tax line and the ACCN footer.
• Serial numbers. Odoo numbers invoices in a sequence, by default in the form INV/year/number, and logs any change to the format. Each sales journal has its own sequence, which also supports branches.
• Back-up booklets. This is a set-up suggestion, not a BIR rule. If you keep ATP booklets for downtime, TechNext can set up a separate journal for them, so each manual invoice is entered later under its own booklet number and your sales books stay complete. Confirm with your accountant how your RDO wants them recorded before we set it up.

If Odoo also runs your shop counter, the POS rules apply on top. Our POS accreditation and PTU guide explains them.

You don't need to hire your own team. A TechNext adviser reviews which of your invoices are printed and which come from a system, then our team in Taguig City sets up the Odoo invoice layout, series and back-up journal with you. You apply for the ATP and the system registration yourself. See how we set Odoo up as your CAS, or read about Odoo in the Philippines.

Sources

• RA 11976 (EOPT Act), Section 36 amending Tax Code Section 238
• RR 18-2012 (copy hosted by PhilGEPS) and RMO 12-2013 (Supreme Court E-Library)
• RR 6-2022 and RMC 123-2022 digest (BIR)
• RMC 153-2022 digest and RMC 10-2024 (BIR)
• RMO 9-2021 (copy hosted by Grant Thornton) and RMC 5-2021 Annex B: functional and technical requirements (BIR)
• RR 11-2024, RMC 77-2024 and RR 6-2026 (BIR)
• RR 7-2024 (full text, copy hosted by Offshore Management), Sections 5(C), 6(B) and 7
• RMC 97-2025 digest: revised registration forms, including Form 1906 (BIR)
• RMC 98-2026 (BIR)
• Daily Tribune: RMC 112-2026 on withholding tax in invoices (press report; BIR text not yet checked)
• Grant Thornton: invoicing requirements under RR 7-2024 and RR 11-2024
• Odoo documentation: PDF reports and document layout, invoice sequence and Odoo 20 release notes

Common questions