CAS-Generated vs Loose-Leaf (Printed) Invoices — Legal and Practical Guide

1) Why this topic exists: invoices are regulated tax documents, not mere business paperwork

In the Philippines, sales invoices (and official receipts, where still applicable for certain transactions) are principal evidence of a taxable sale and are subject to strict rules on content, serial numbering, authorization, issuance, and recordkeeping. The Bureau of Internal Revenue (BIR) treats noncompliant invoicing as a high-risk area because it directly affects:

income tax reporting (sales recognition),
withholding tax documentation (in some cases), and
VAT compliance (output tax, input tax substantiation, invoicing requirements).

Because invoices are controlled, changes to invoice templates—especially business identity details printed on the face of an invoice—are not always as simple as “editing a layout.” This is where the practice of executing an Affidavit of Alteration developed: it is a sworn statement used to support BIR-permitted handling of previously authorized but now outdated invoice forms.

2) Core concepts and definitions

2.1 “Alteration” has two very different meanings

A. Alteration of an issued invoice (transaction details). This refers to erasures, overwriting, manual edits, or changes to amounts, buyer details, VAT, date, or description after issuance. This is generally not allowed as a corrective practice. Proper correction is typically done through:

voiding/cancelling the invoice (keeping the original), and issuing a replacement, and/or
issuing credit/debit memos (especially where VAT documentation and audit trail must be preserved), and ensuring the accounting records reflect the adjustment.

B. Alteration of unissued invoice forms (template/business details). This refers to changes in the printed face of invoices not tied to a specific sale (e.g., business name, address, VAT status line, branch code, or other registration particulars). The Affidavit of Alteration is generally about this second meaning.

This article focuses on alteration of unissued invoices and the compliance differences between CAS-generated invoices and loose-leaf printed invoices.

3) The two formats: CAS-generated vs loose-leaf printed invoices

3.1 CAS-generated sales invoices (computer-generated)

A CAS (Computerized Accounting System) or similar BIR-registered system environment is used where invoices are generated and printed by the system, typically with:

system-controlled sequential numbering,
system-embedded header/footer information,
audit trail controls (voids, cancellations, reprints, user logs),
reports that reconcile invoice sequences to sales and tax returns.

A business usually needs BIR approval/permit for the system and/or the manner of generating invoices and receipts, and the printed output must comply with mandatory invoice information.

Practical implication: “Alteration” for CAS is often a system change (template/layout/master data) rather than a change to physical pre-printed forms.

3.2 Loose-leaf (printed) sales invoices

In common business usage, “loose-leaf invoices” are pre-printed invoice forms (often continuous forms or pads) printed by a BIR-authorized/accredited printer pursuant to an Authority to Print (ATP) and issued manually or typed/printed as needed.

These are “controlled forms” because:

they carry pre-approved serial ranges,
they were printed based on your registration details at the time of printing,
they are expected to be used in sequence and safeguarded.

Practical implication: If business identity details change, you may end up holding unused stocks that no longer match your current registration information—raising the question of whether you can still use them, and under what conditions.

4) When an Affidavit of Alteration is typically used

While exact documentary requirements can vary by RDO practice and the nature of the change, an Affidavit of Alteration is commonly used when a taxpayer wants to continue using existing unused invoice stocks (or wants to document controlled handling of obsolete stocks) after changes such as:

4.1 Changes to taxpayer registration particulars

Change of registered business address (including within the same city/municipality or to a different RDO)
Change in registered business name / trade name (without changing the legal entity), or changes due to SEC/DTI updates
Change in line of business that affects invoice descriptors
Change in VAT registration status (e.g., from VAT to non-VAT or vice versa), requiring different invoice statements and VAT breakdown presentation
Change in branch/facility details where branch codes, addresses, or identifiers printed on invoices must be updated
Change in TIN format presentation (e.g., head office vs branch TIN display requirements)

4.2 Changes affecting printer and authorization details (usually for printed forms)

printer information changes, or updates to the authorization references appearing on the invoice
replacement of invoice series or adoption of a new invoice format

4.3 Migration scenarios

moving from loose-leaf printed invoices to CAS-generated invoices, or
from one CAS to another, or major system version changes that affect invoice controls, numbering, and content

In migrations, the affidavit is often paired with an inventory of unused invoices and a representation of how they will be disposed of, cancelled, stamped, or (if permitted) used with a stamping procedure.

5) What the BIR typically cares about (regardless of format)

At a compliance level, BIR’s concern is to prevent:

double use of the same serial numbers,
unaccounted invoice gaps (missing numbers that could conceal sales),
use of unauthorized documents, and
misleading identity details (wrong seller identity or tax status on the document).

This means any “alteration approach” must protect:

serial integrity (no duplicate series, no untracked reprints),
traceability (ability to prove what happened to unused stocks), and
truthfulness of face information (buyer can rely on seller identity and VAT status).

6) Key compliance differences: CAS-generated vs loose-leaf invoices

6.1 If you use CAS-generated invoices

“Alteration” is usually a controlled system update. Typical compliance expectations:

Updates are implemented in the system’s master data/template (seller name, address, VAT line, branch details).
Invoice numbering must remain system-controlled and sequential.
Voids/cancellations must be captured with a clear audit trail.
If the system approval/permit conditions require it, you may need to notify or seek approval before changing invoice layouts or critical tax content (some RDOs treat layout changes as material).

Affidavit use in CAS context: An affidavit may be used where:

the business needs to document that older invoice formats will no longer be used (cutover controls),
there are pre-printed invoice stocks previously authorized that will be cancelled because the business is moving to CAS invoices, or
the business needs to explain and commit to controls for old series, void ranges, and transition dates.

Main CAS risk: printing “old format” invoices after the effective date of changes or running parallel series without control.

6.2 If you use loose-leaf printed invoices

“Alteration” often involves physical handling of unused forms. Typical approaches the BIR may accept depending on the change:

Use up remaining stocks with a stamp reflecting updated details (commonly used for address changes or minor textual changes), supported by an affidavit and inventory; or
Cancel/withdraw remaining stocks (e.g., stamp “CANCELLED” across unused invoices, cut/deface, or surrender as required), and print new invoices under a new ATP.

Affidavit use in loose-leaf context: This is the classic scenario. The affidavit usually supports one of two positions:

Position A (continued use): “We request/represent that we will use remaining unused invoices by stamping the updated details, maintain inventory, and ensure serial integrity.”
Position B (non-use/cancellation): “We will no longer use these invoices; we will cancel them and secure new invoices reflecting updated registration.”

Main loose-leaf risk: outdated identity/VAT status on the face of invoices, and uncontrolled leftover stocks that could be used later without trace.

7) Situations where alteration is especially sensitive (higher risk)

7.1 VAT status changes (VAT ↔ non-VAT)

This is one of the most sensitive changes because the invoice must properly reflect VAT treatment. The face of the invoice typically must show:

whether the seller is VAT-registered,
the VAT breakdown where required (VATable sales, VAT amount, total),
required statements for non-VAT documents that affect the buyer’s ability to claim input tax.

Practical takeaway: continuing to use old stocks by stamping may be scrutinized more heavily, and many taxpayers choose to cancel old stocks and reprint to avoid disputes about input tax claims.

7.2 Change of legal entity (not just trade name)

If the “seller” changes (e.g., sole proprietorship to corporation, partnership restructuring, merger effects), that’s not a mere alteration; the invoices are tied to the issuing taxpayer. In these cases, old invoices generally should not be used by a different legal entity, even if the business operations appear continuous.

7.3 Change in RDO / transfer of registration

When you move to a different RDO, administrative requirements can become strict: inventory declarations, serial tracking, and disposition of unused invoices may be checked. Even if stamping is used, the documentation must clearly connect the old stocks to the taxpayer and show that the BIR can still trace the series.

8) What an Affidavit of Alteration typically contains

Although wording varies, a strong affidavit usually includes the following blocks:

Caption and parties
- “AFFIDAVIT OF ALTERATION”
- Name of affiant, citizenship, address, position (owner/proprietor, authorized representative), and authority to sign.
Taxpayer identity
- Registered business name/trade name
- TIN and branch code (if any)
- Registered address
- RDO details (where registered)
Statement of change
- What changed, and the effective date (e.g., new address effective on ___; VAT registration change effective on ___).
- Reference to the registration update filing (commonly via the registration update form and attachments).
Description of affected invoices
- Type of document: Sales Invoice
- Invoice series name (if any)
- Serial range (From No. ____ to No. ____)
- Quantity of unused invoices remaining
- Printer details and ATP reference (for printed forms), or system/permit details (for CAS).
Inventory and control measures
- A schedule/annex listing remaining serial numbers.
- Commitment that invoices will be safeguarded and issued sequentially.
- For stamping: exact text to be stamped and where it will appear.
- For cancellation: how the unused forms will be defaced/cancelled and recorded.
Non-misuse undertakings
- Undertaking not to use invoices that are obsolete/cancelled.
- Undertaking not to reprint or reproduce without authority.
- Undertaking to present the stocks upon BIR request.
Transition/cutover (especially for CAS migration)
- Effective cutover date/time.
- Treatment of voided numbers.
- Commitment that old series will not be used after cutover.
Notarization and attachments
- Jurat by a notary public.
- Annexes: inventory list, sample stamp impression, copies of old/new registration, ATP copy, printer invoice details, system permit documents as relevant.

9) Attachments and companion filings commonly paired with the affidavit

In practice, an affidavit rarely stands alone. Common companion items include:

Registration update filing reflecting the change (e.g., address, name, VAT status), with supporting documents (SEC/DTI/LGU documents, proof of address, etc.).
Inventory of unused invoices with serials.
Sample of the invoice face (old and proposed stamped/updated version) or system print samples (for CAS).
Proof of authority/permit (for printed invoices: ATP and printer details; for CAS: permit/acknowledgment documents governing system-generated invoices).
Board resolution/Secretary’s Certificate or SPA (for corporations/representatives), if the affiant is not the proprietor.

RDO practice can be highly procedural: taxpayers are often expected to show that the change has already been reflected in registration and that the remaining invoice stocks are accounted for.

10) Compliance mechanics: stamping vs cancellation (loose-leaf printed invoices)

10.1 Stamping (continued use of unused stocks)

Best suited for: minor changes that do not confuse the tax nature of the invoice (often address changes or minor business descriptors). Key controls:

Use a consistent stamp (clear, legible, durable ink).
Stamp all remaining unused invoices in the declared range, not selectively.
Keep the inventory list and note when stamping was done.
Ensure the stamped information does not obscure required printed data.

10.2 Cancellation/withdrawal (non-use of old stocks)

Best suited for: material changes (VAT status changes, entity changes, high-risk transitions). Key controls:

Mark unused invoices “CANCELLED,” deface or cross-cut, and record the serials.
Keep a log and supporting photos/scans if part of internal control.
Where required by local RDO practice, present or submit the cancelled stocks or certification of destruction/defacement.

11) CAS-specific “alteration” controls (system governance perspective)

11.1 Template and master data governance

A compliant CAS environment should ensure:

Only authorized users can change invoice header fields.
Changes are logged (who/when/what).
Old templates cannot be used after cutover (or are locked).
Reprints indicate “reprinted” or otherwise maintain traceability.

11.2 Serial and void controls

A well-controlled process includes:

clear handling of voided invoices (void reason, linkage to replacement invoice if any),
explanation for gaps (e.g., test prints should be controlled and documented),
reconciliation reports tying invoice sequence to sales journals and tax returns.

11.3 Migration from loose-leaf to CAS

Common compliance friction points:

what happens to unused ATP-printed stocks,
whether CAS invoices start a new series,
how the cutover date is documented,
whether both formats were used in parallel (and why).

An affidavit in this context often serves as a sworn control narrative for transition integrity.

12) Mistakes that commonly cause assessments or penalties

12.1 Using invoices with wrong seller identity

Invoices that show the wrong entity name, TIN, or address after official change can trigger findings such as:

“invalid invoice,”
“use of unauthorized principal invoices,” or
“failure to comply with invoicing requirements,” depending on the facts.

12.2 Mixing series or duplicating numbers

Parallel issuance from CAS and printed forms without a documented series policy can create red flags:

duplicate invoice numbers,
missing numbers with no explanation,
inability to reconcile reported sales to invoice sequences.

12.3 Treating VAT status changes as a minor stamping matter

If the invoice face no longer reflects correct VAT statements/breakdown, the buyer’s input tax claim can be denied and the seller can be cited for noncompliance.

12.4 Altering transaction details on issued invoices

Manual edits, erasures, or overwritten amounts are audit magnets. Corrections should be done through formal cancellation/replacement or credit/debit memos with clear audit trail.

13) Legal exposure and enforcement themes

While outcomes depend on facts and enforcement posture, invoicing violations can lead to:

administrative penalties and compromise penalties,
disallowance of input tax (for buyers) and related disputes,
potential closure of business in serious or repeated cases tied to failure to issue compliant invoices, and
criminal exposure in egregious scenarios (e.g., willful use of unauthorized invoices, systematic failure to issue invoices), subject to evidentiary standards and prosecutorial discretion.

Because invoices sit at the center of tax audit substantiation, the affidavit and the controls behind it are best treated as compliance evidence, not mere formality.

14) Practical compliance checklist (by scenario)

14.1 Loose-leaf printed invoices — address change

Update registration information.
Count unused invoices; prepare serial inventory.
Decide: stamp updated address vs cancel and reprint.
Execute affidavit describing: change, serial range, inventory, stamping/cancellation controls.
Keep annexes: inventory list, stamp impression, sample invoice.

14.2 Loose-leaf printed invoices — VAT status change

Update VAT registration status properly.
Prefer cancellation and reprint unless clearly allowed under local RDO practice with strict stamping and updated VAT content.
Ensure the invoice face fully complies with VAT/non-VAT statements and breakdown requirements.
Execute affidavit and preserve disposition evidence.

14.3 CAS invoices — change of address/name

Update registration.
Implement system master data/template change with audit trail.
Lock old template; document effective date.
Print controlled samples for file.
If transitioning series or retiring old series, execute affidavit or internal sworn documentation if required by your process/RDO expectations.

14.4 Migration — loose-leaf to CAS

Decide treatment of unused printed stocks (cancel vs limited continued use with strict segregation).
Document cutover date and series policy.
Ensure CAS invoice sequencing and reporting can be reconciled.
Use affidavit to document disposition of old stocks and transition controls.

15) How to think about “all there is to know” in one principle

An Affidavit of Alteration is best understood as a risk-control document used to preserve the integrity of BIR-controlled invoicing when your business registration details or invoicing platform changes.

For loose-leaf printed invoices, the affidavit typically supports whether and how unused stocks may be stamped/used or must be cancelled and replaced.
For CAS-generated invoices, the affidavit (when used) often supports system governance, transition integrity, and the retirement of old series or formats, anchored on audit trail, sequencing, and cutover controls.

The more the change affects tax characterization (especially VAT) and seller identity, the less “alteration” resembles stamping and the more it becomes a controlled retirement of old forms and issuance of compliant new ones.