Summary
RR No. 28-2025 implements the enhanced version of the Electronic Documentary Stamp Tax (eDST) System and requires certain industries to use it for affixing documentary stamps.
Key points
- Mandated users. Individual and non-individual taxpayers in these industries must use it: banks, quasi-banks, non-bank financial intermediaries, finance companies, and insurance, surety, fidelity, or annuity companies; shipping and airlines; pre-need companies; educational institutions for certificates taxable under Section 188; government agencies, GOCCs, and LGUs except barangays for such certificates; and notaries public. The Secretary of Finance may add other industries by revenue regulation.
- Enrollment and modules. Mandated taxpayers enroll online through www.bir.gov.ph. The system has a Deposit Module (advance deposit deducted per printing) and a Non-Deposit Module (immediate printing with monthly remittance of the total tax due). A taxpayer enrolled in one module can no longer enroll in the other.
- Exceptions. Loose documentary stamps and constructive affixture remain allowed, subject to the CIR’s determination and a separate revenue issuance. Loose stamps go only on Section 188 documents with tax due of ₱ 30.00, multiple loose stamps on documents with tax due above ₱30.00 are prohibited, and buying two or more loose stamps for future use is prohibited unless the CIR determines otherwise.
- Business closure. During examination for business closure, RDOs validate any excess eDST deposit. It is applied first to outstanding DST liability, then to other outstanding tax liabilities, and any remainder is refunded.
- Phased rollout. The CIR may implement the enhanced eDST System in phases through a separate issuance, including the procedures.
- Prohibited acts. No one may collect, sell, or offer documentary stamps for more than face value, and violations carry criminal and civil penalties. Reusing a previously affixed loose stamp is strictly prohibited, and the stamp must be cancelled per Item No. 3.c. of the guidelines under RMC No. 092-2024 before the document is released.
Who is affected
- Banks, quasi-banks, and insurance companies
- Shipping and airlines companies
- Pre-need companies
- Educational institutions and government agencies
- Notaries public
Deadlines and effectivity
- Issued: December 22, 2025
- Phased implementation set by the CIR through a separate issuance
Summary by Tax Resources PH. It is not a substitute for the full text of the issuance or professional advice.
Copies of BIR issuances are hosted here for reference. For the official version, check bir.gov.ph. Summaries by Tax Resources PH are not a substitute for the full text or professional advice.