RMC 38‑2026: 'Blue cheque' for online retailers

For too long, the digital market in the Philippines felt like the Wild West. You could buy a custom cake, hire a freelance designer, or grab a vintage jacket for a social media comment — all without knowing whether the business was “legitimate” in the eyes of the law. Meanwhile, traditional shopkeepers were supposed to submit a draft of their Certificates of Registration (CoR) issued by the Bureau of Internal Revenue (BIR) and hang them on the wall for all to see.
Enter Revenue Memorandum Circular (RMC) No. 38-2026. Issued in April 2026, this RMC is the BIR's way of making that dusty, framed certificate of the digital age. Introducing the “BIR Registration Seal,” a digital stamp specifically designed for online marketers, freelancers, and other self-employed taxpayers.
WHAT IS A REGISTRATION MARK?
Think of the Registration Mark as a “verified” badge for taxpayers — the BIR's version of social media's “blue check.”
It is a fixed digital image with a QR code. When a customer scans that code, it connects directly to the BIR's official verification system, confirming that the seller is a registered taxpayer without splashing their private information – such as their home address or Taxpayer Identification Number (TIN) – all over the Internet.
This marks a major change in regulatory approach. In the past, if you wanted to prove you were registered online, you may have had to upload a photo of your original CoR. Not only that, but it was also a privacy nightmare.
RMC 38-2026 recognizes that the Internet is a public domain, and that vendors deserve reasonable data protection. Therefore, taxpayers are clearly required to submit only the Registration Mark and not the full CoR, thereby reducing the risk of disclosing sensitive personal information.
WHO SHOULD SEND IT?
The net is deliberately cast wide. If you receive money through digital or electronic means, RMC 38-2026 generally applies to you. The list includes:
Online Merchants: Whether you work at Shopee, Lazada, TikTok Shop, or similar e-commerce platforms.
Service Providers: Freelancers, virtual assistants, and other independent professionals who provide services online.
Digital Content Creators: Vloggers, influencers, broadcasters, and anyone who earns money through live streaming, ads, sponsorships, or affiliate links.
Platform Merchants: Any person or entity that uses a website, marketplace account, or social media page to conduct business.
The law is straightforward: if you have a digital “storefront”, you need a Registration Mark and it must be posted in a visible place. In digital marketing, this often means displaying the badge in visible sections such as “About Us,” profile headers, or “Business Information/Consent” sections of websites or social media pages.
HOW DO YOU FIND ONE?
The process is surprisingly modern. Most retailers can generate a badge through the Online Registration and Renewal (ORUS) system. If you are not a fan of doing things digitally, you can still visit your local Revenue District Office (RDO) for help.
The badge itself is free. However, there is a small catch: if you need to update your registration information to get a badge (such as changing your business structure), you will need to pay a P30 Documentary Stamp Tax (DST). It's a small price to pay for a “digital seal of approval” that assures your customers that you're a legitimate, law-abiding business.
Notably, taxpayers are not required to replace their existing CoR that does not have a QR code. However, they are encouraged to do so for the purposes of obtaining a Registration Mark. Considering that QR allows buyers to verify the seller's BIR registration, having a CoR with QR may help to better establish the seller's credibility.
IS THIS OKAY?
Whenever the BIR introduces a new rule for online sellers, the reaction is usually a collective groan. “Another requirement?” “Why us?” But if we step back and look at the bigger picture, RMC 38-2026 is actually a step toward fairness, balance, and common sense.
LEVELING THE PLAYING FIELD
For years, brick-and-mortar stores have argued that online retailers have an unfair advantage because they are “invisible.” By making registration visible through a standard badge, the BIR ensures that everyone plays by the same rules. If a physical bakery is required to display its registration, why shouldn't a Facebook-based bakery do the same? Only the speaker has changed, not the bond.
BUILDING CONSUMER TRUST
As a consumer, have you ever hesitated before sending a GCash payment to a stranger on Instagram? Many people have done so. The Registration Mark acts as a virtual bridge of trust. When a consumer sees that QR code, they know they're not dealing with a fly-by-night job. Protects legitimate sellers from scams and fake accounts.
RESPECTING THE DETAILS
One of the most critical aspects of being an online entrepreneur is that your “office” is often your living room or bedroom — places that are personal and private by nature. The BIR deserves credit for not forcing vendors to post their complete CoRs online. By adopting the QR code, they balanced the government's need for transparency with the taxpayer's right to privacy.
THE MYTH OF DIRECT THERAPY
Critics may argue that online retailers are getting “easy” treatment because they only have to post a badge instead of a full certificate. However, tax uniformity does not mean strict uniformity.
A physical store is a controlled, location-specific environment; internet does not exist. Requiring a vlogger to publicly disclose a home address (usually disclosed on CoR) would be unsafe and impractical. RMC 38-2026 proves that the tax authority can be active and flexible. It shows that they are willing to adjust the instruments of law to suit the reality of the digital world.
FINAL THOUGHTS
Taxation is rarely described as “light” or “easy,” but RMC 38-2026 sounds like limited flattery. It brings the digital economy under control without being too heavy-handed. For sellers, it's a way to gain legitimacy. For consumers, it is a tool for peace of mind. And for the BIR, it is a way to ensure that the once-“invisible” digital economy is finally visible and verifiable.
If you are an online seller, don't look at this as another obstacle. Instead, look at it as a license for your digital business – one that fits the modern way you work. It's time to pick up your badge and wear it with pride.
The views or opinions expressed in this article are solely those of the author and do not necessarily represent those of Isla Lipana & Co. The content is for general information purposes only, and should not be used as a substitute for specific advice.
Dorothy Jane Puguon is a senior manager in the Tax Services Department of Isla Lipana & Co., the Philippine member firm of the PricewaterhouseCoopers network.
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