The Bureau of Internal Revenue has issuedRevenue Memorandum Circular No. 107-2026, providing important clarifications on the implementation of theEnhanced Electronic Documentary Stamp Tax or eDST Systemunder Revenue Regulations No. 28-2025.
For businesses and professionals covered by the new system, this is more than a simple change in how Documentary Stamp Tax is processed. The Circular establishes an enrollment deadline, additional registration requirements, procedures for system issues, and consequences for failure to comply.
Here is what taxpayers need to know.
What is Documentary Stamp Tax?
Documentary Stamp Tax, commonly calledDST, is a tax imposed on certain documents, agreements, instruments, and transactions.
Depending on the transaction, DST may apply to documents involving loans, debt instruments, shares of stock, leases, transfers of property, insurance policies, and other taxable instruments.
Traditionally, compliance could involve several steps in determining, declaring, paying, and documenting the applicable tax.
The BIR’sEnhanced eDST Systemis intended to modernize this process by providing an electronic platform for documentary stamp tax administration.
According to RMC No. 107-2026, the Enhanced eDST System was developed as part of the BIR’s Digital Transformation Roadmap to address limitations of the previous system and improve the efficiency of tax compliance and revenue collection. RMC No. 107-2026
Why was RMC No. 107-2026 issued?
Revenue Regulations No. 28-2025 already institutionalized and mandated the Enhanced eDST System for taxpayers covered by the regulation.
RMC No. 107-2026 now clarifies how taxpayers are expected to implement and use it.
In practical terms, the Circular answers some of the questions businesses may have, including:
- When taxpayers must enroll
- What other registrations are required
- Whether taxpayers should continue their existing DST procedures while enrollment is pending
- What Notaries Public need to do
- What happens when an eDST is mistakenly affixed more than once
- What taxpayers should do when the BIR system encounters technical problems
- What happens if a covered taxpayer fails to enroll on time
The most important deadline: December 31, 2026
Taxpayers who are required to use the Enhanced eDST System under RR No. 28-2025 must enrollon or before December 31, 2026.
Fornewly registered taxpayerscovered by the mandate, enrollment must instead be completedwithin 90 days from the date of registration with the BIR. RMC No. 107-2026
This is important because businesses should not treat December 31 as merely the date to start preparing.
Enrollment comes with other requirements that may require coordination with the BIR.
Enrollment in eDST is not the only requirement
RMC No. 107-2026 requires covered taxpayers to comply with additional requirements alongside their eDST enrollment.
1. Enrollment in eFPS
Covered taxpayers must enroll in theElectronic Filing and Payment System or eFPSfor the filing of the Documentary Stamp Tax Declaration/Return throughBIR Form No. 2000and payment of the corresponding tax. RMC No. 107-2026
This means businesses that are not yet properly set up in eFPS may need to address this as part of their eDST compliance preparation.
2. Attendance at the BIR orientation
Taxpayers must also attend an orientation on the use of the Enhanced eDST System conducted by the BIR’sMiscellaneous Operations Monitoring Division or MOMD.
The orientation is scheduledevery second Thursday of the monthand is considered a prerequisite to using the system. RMC No. 107-2026
For affected taxpayers, waiting until the final weeks of December could therefore create unnecessary compliance pressure.
What should taxpayers do while their eDST enrollment is still pending?
Being in the process of enrolling doesnotsuspend a taxpayer’s existing DST obligations.
RMC No. 107-2026 states that taxpayers covered by RR No. 28-2025 must continue complying with their Documentary Stamp Tax obligations under existing laws, rules, and regulations while enrollment in the Enhanced eDST System is pending.
Once the prescribed enrollment period expires, covered taxpayers are expected to use the Enhanced eDST System in accordance with RR No. 28-2025. RMC No. 107-2026
In simpler terms:
Do not stop your existing DST compliance just because your Enhanced eDST enrollment has not yet been completed.
The transition does not eliminate current filing and payment responsibilities.
Notaries Public have separate responsibilities
RMC No. 107-2026 also contains an important clarification specifically forNotaries Public.
A Notary Public who works for a law firm, another office, or serves as a third party or outsourced service provider must enroll in the eDST Systemin his or her individual capacity.
The notary must maintain aseparate eDST account, regardless of the organization employing or engaging the notary or the taxpayer for whom the notarial service is being performed. RMC No. 107-2026
The Circular further requires Notaries Public to coordinate with their respective Revenue District Offices to update their taxpayer classification to“Professional”and ensure that their BIR registration records properly reflect their authority to perform notarial services. RMC No. 107-2026
This is particularly relevant to law firms, corporate legal departments, and businesses regularly relying on in house or external notarial services.
What if an eDST is applied incorrectly?
Mistakes can happen, particularly during the transition to a new electronic system.
If a taxpayer accidentally makes adouble, multiple, or erroneous affixture of documentary stampsthrough the eDST System, the Circular provides that the taxpayer must file aclaim for refund.
The claim should be filed with the concerned Large Taxpayers Division or the Revenue District Office where the taxpayer is registered, subject to existing rules governing tax refunds. RMC No. 107-2026
This makes proper review before completing an eDST transaction especially important, since an incorrect transaction may require a separate refund process to recover the amount.
What if the BIR system is down?
This is one of the most practical clarifications in the Circular.
If a taxpayer encounters issues such as:
- Slow system performance
- Delayed responses caused by internet connectivity
- System downtime or outages
- System breakdowns
- Non posting of payments in the BIR’s collection system
the taxpayer shouldimmediately report the problem to the BIR Contact Centerand request aTrouble Ticket Number or TTN.
The TTN serves as official proof that the incident was reported within the day or within the applicable deadline, particularly in cases involving non posting of payments. RMC No. 107-2026
This is an important compliance safeguard.
Simply taking a screenshot of an error message may not be enough to establish that the problem was formally reported to the BIR. Taxpayers should obtain and retain the applicable Trouble Ticket Number together with their supporting records.
What happens if a taxpayer does not enroll?
The December 31 deadline should not be ignored.
RMC No. 107-2026 expressly states that taxpayers who are required to enroll in the Enhanced eDST System but fail to do so within the prescribed period will be considerednon compliantand may be subject to the applicable penalties and sanctions under existing laws, rules, and regulations. RMC No. 107-2026
This is why affected taxpayers should assess their registration status ahead of the deadline rather than treating eDST enrollment as a year end administrative task.
Why does this matter for businesses?
The significance of RMC No. 107-2026 is not simply that another BIR platform is being introduced.
It reflects the continuing shift of Philippine tax administration towardmandatory digital compliance.
For affected businesses, the practical concern is readiness.
A company may need to determine whether it is covered, complete eDST enrollment, secure or update eFPS access, assign responsible personnel, attend the required orientation, and establish internal procedures for processing and documenting eDST transactions.
Businesses that frequently enter into transactions subject to Documentary Stamp Tax should therefore review their existing processes before the mandatory implementation period.
A simple way to think about it
Before:A business followed its existing process for complying with Documentary Stamp Tax requirements.
Now:Taxpayers covered by RR No. 28-2025 must prepare to transition to the Enhanced eDST System, together with the related eFPS and BIR requirements.
Deadline:Existing covered taxpayers must enroll byDecember 31, 2026, while newly registered covered taxpayers generally have90 days from BIR registrationto enroll. RMC No. 107-2026
What should taxpayers do now?
Businesses should not wait until December to determine whether action is necessary.
A practical first step is to review whether the company falls within the taxpayers mandated to use the Enhanced eDST System underRR No. 28-2025.
For those covered, management should begin checking the company’s eDST and eFPS registration status, identify the personnel who will handle DST transactions, arrange attendance at the required BIR orientation, and make sure internal procedures are ready before the enrollment deadline.
Notaries Public should separately review their own BIR registration and eDST enrollment requirements.
Final takeaway
RMC No. 107-2026 turns the transition to the Enhanced eDST System into a compliance matter that affected taxpayers should begin preparing for now.
The key date isDecember 31, 2026, but proper preparation may involve more than submitting an online enrollment.
Taxpayers should consider their eFPS registration, required BIR orientation, internal processes, responsible personnel, and procedures for handling system errors or incorrect transactions.
As tax administration becomes increasingly digital, early preparation can help businesses avoid last minute registration issues, processing delays, and potential non compliance.
Need assistance with your BIR compliance?
Bong Corpuz & Co., CPAscan assist businesses in assessing their tax compliance requirements and preparing for changes in BIR registration and reporting procedures.
For questions regardingRMC No. 107-2026, Documentary Stamp Tax, eDST compliance, or other BIR requirements, you may contact our team for assistance.
This article is intended for general informational purposes only and should not be considered a substitute for professional advice based on the specific facts and circumstances of a taxpayer.
