Are Government Agencies Required to Change their Official Receipt to Invoice?

Just recently, the Bureau of Internal Revenue (BIR) issued a Revenue Regulation requiring entities concerned to change their Official Receipt to Invoice as mandated under the Ease of Paying Taxes (EOPT) or Republic Act No. 11976.

According to BIR Revenue Regulation No. 7-2024:

Issuance of “Official Receipt for the sale of goods or services after June 30, 2024 will not be considered as evidence of sales of goods or services and shall be tantamount to failure to issue or non-issuance of Invoice required under Section 6(A) hereof subject to penalty of not less than One Thousand Pesos (Php 1,000.00) but not more than Fifty Thousand Pesos (Php 50,000.00) and suffer imprisonment of not less than two (2) years but not more than four (4) years pursuant to Section 264(a) of the Tax Code.

However, the BIR clarified in the same Memorandum that:

All unused or unissued Official Receipts may still be used as supplementary document until they are fully consumed, provided that the phrase “THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX” is stamped on the face of the document upon effectivity date of these Regulations.

The Official Receipt, along with other equivalent documents such as Collection Receipt, Acknowledgement Receipt and Payment Receipt are all the same, serve as proof of payment that cash has been received or that payment has been collected/made for goods and/or services.

The question is, are government agencies affected by this Revenue Regulation and are they required to issue Invoice instead of Official Receipt?

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