1) Executive takeaways

If an “Acknowledgment Receipt” (AR) is used only to acknowledge money received for a non-sale purpose (e.g., deposits, advances held in trust, reimbursements, loan proceeds), it is generally treated as a supplementary document and does not, by itself, require BIR “approval” (i.e., an Authority to Print or permit/registration as a principal receipt/invoice).
If an AR is used in place of the required BIR-recognized principal document for a taxable transaction—meaning it functions as your Official Receipt (OR) or Sales Invoice (SI)—then it effectively becomes an unregistered principal receipt. In that scenario, you are exposed to penalties for failure to issue the proper OR/SI and/or use of unregistered receipts.
Being Non-VAT does not remove the obligation to issue receipts/invoices. Non-VAT taxpayers still must issue the appropriate OR/SI (non-VAT format) for sales of goods/services, and those principal documents are the ones that require BIR registration/authority.

2) What “BIR approval” usually means in practice

When people say “BIR approval” for receipts, they typically mean one (or more) of these compliance requirements:

Authority to Print (ATP) for printed principal receipts/invoices (booklets/pads) issued by an accredited printer;
Permit to Use (PTU) (or equivalent authorization) for computerized/accounting system/CRM/POS that generates receipts/invoices;
Registration of the range/series and required “printer’s imprint” details (TIN, business style, address, ATP number, etc.);
BIR-required content and formatting (serial numbering, required disclosures like “NON-VAT REGISTERED,” etc.).

Key point: The “approval” requirement attaches primarily to principal receipts/invoices—the official documents the tax rules expect you to issue for business sales/collections—not to every piece of paper that acknowledges money.

3) AR vs OR vs Sales Invoice: the concepts you must separate

A) Principal documents (the “official” tax documents)

These are the documents the tax rules expect you to issue and your customer can ordinarily rely on for recording the transaction (and, for VAT taxpayers, for input tax support):

Sales Invoice (SI) – typically used for sale of goods/merchandise (and, in many settings, for sale of property).
Official Receipt (OR) – traditionally used for sale of services (and/or evidence of payment/collection, depending on the structure of the transaction and prevailing invoicing rules).
Other BIR-recognized principal invoices/receipts depending on industry and system.

These are the documents that generally require ATP/PTU and BIR registration/authorization.

B) Supplementary documents (supporting papers)

These documents support operations or document flows but are not meant to replace the principal receipt/invoice, such as:

Acknowledgment receipt (AR)
Collection receipt (CR) (often used internally to acknowledge collection but not as the BIR principal OR)
Delivery receipt (DR)
Order slip, billing statement, statement of account
Provisional/temporary receipt, deposit slip, etc.

Supplementary documents are generally allowed so long as they do not pretend to be the principal OR/SI and do not become the “only” document issued when an OR/SI is required.

4) The legal question: “Do Non-VAT ARs require BIR approval?”

The practical legal test

Ask: Is the AR being used to document a transaction that requires a BIR principal receipt/invoice?

Scenario 1: AR is for non-sale money (generally no BIR “approval” needed)

Examples:

Security deposit (e.g., lease deposit, refundable deposit)
Customer deposit/downpayment held pending future sale (especially if no sale is yet completed)
Reimbursement (employee liquidations, customer reimbursements where you’re merely recovering a cost as agent)
Loan proceeds received, shareholder advances, capital infusions
Return/refund acknowledgment
Trust money received as agent (subject to careful structuring and documentation)

In these cases, an AR is usually treated as a supplementary acknowledgment, not as a principal receipt. You typically do not need an ATP just to issue an AR—provided you still issue the required principal document later if/when the transaction becomes a sale or a taxable collection that requires OR/SI.

Scenario 2: AR is used instead of the required OR/SI (BIR authorization effectively required—AR becomes a problem)

Examples:

You provide a service, get paid, and only issue an “Acknowledgment Receipt” (no BIR-registered OR).
You sell goods and only issue an AR (no BIR-registered Sales Invoice).
You issue ARs as your standard customer-facing proof of sale/collection.

Here, the AR is functioning as the principal receipt. If it is not BIR-authorized/registered as such, it can be treated as:

failure to issue the required OR/SI, and/or
issuance/use of unregistered receipts/invoices, and/or
noncompliant content/format, and/or
records/invoicing deficiencies that can cascade into assessment disputes (income recognition, expense substantiation, withholding documentation, etc.).

Bottom line: A non-VAT AR does not automatically require BIR approval—but it becomes risky and potentially penalizable when it substitutes for the required principal OR/SI.

5) Non-VAT status: what changes (and what does not)

What does not change

Even if you are Non-VAT:

You are still generally required to register your business and issue the appropriate principal receipts/invoices for sales transactions.
Your principal OR/SI still generally must be BIR-authorized (ATP/PTU) and compliant with required information.

What does change

Non-VAT taxpayers typically must ensure their principal receipts/invoices reflect non-VAT status, commonly through statements like:

“NON-VAT REGISTERED”
“THIS DOCUMENT IS NOT VALID FOR CLAIM OF INPUT TAX” (commonly seen on non-VAT receipts/invoices)

Also, pricing and tax presentation differ (no VAT breakdown as output VAT), but you may still have other tax considerations (income tax, withholding tax obligations depending on payor/payee classification, percentage tax if applicable, etc.).

6) When should you issue an AR, and when must you issue an OR/SI?

A) Common transaction mapping (practical guide)

1) Security deposit (refundable)

At receipt of deposit: AR is appropriate (supplementary).
If applied later as payment: issue the proper OR/SI at the point it becomes consideration for a sale/service (timing depends on the nature of transaction and invoicing rules you follow).

2) Downpayment for goods

If the sale is not yet completed/delivered, businesses often issue AR for deposit.
Upon sale/delivery (or point recognized under your invoicing rules): issue Sales Invoice (principal), reflecting deposit application.

3) Service fee collected

You generally must issue the principal OR (or the principal invoice document required for services under your setup) upon collection/recognition—an AR alone is not enough as your external tax document.

4) Reimbursement

If you’re truly being reimbursed as an agent and not earning income on it, an AR plus supporting documents may be used.
If it’s actually part of your service fee or you mark it up, it may be treated as part of gross receipts—then the principal OR/SI may be required.

5) Loan proceeds / capital contribution

AR or other documentary acknowledgment is fine; these are not sales.
No OR/SI should be issued because it’s not income from sale (though ensure accounting and documentation are clear).

B) A simple rule of thumb

If the money is for a sale of goods/services (or will be applied to it), you need a compliant principal OR/SI at the proper time.
If the money is not consideration for a sale (deposit, trust, loan, capital), an AR is typically fine.

7) If you choose to use ARs, how to reduce risk

A) Make it unmistakably “supplementary”

On the AR face, consider adding language such as:

“ACKNOWLEDGMENT RECEIPT (SUPPLEMENTARY ONLY)”
“NOT VALID AS AN OFFICIAL RECEIPT/SALES INVOICE”
“FOR DEPOSIT/REIMBURSEMENT/SECURITY DEPOSIT ONLY (specify purpose)”
“SUBJECT TO ISSUANCE OF OFFICIAL RECEIPT/SALES INVOICE WHEN APPLICABLE”

B) Avoid features that make it look like a principal receipt

Be careful about:

Using the title “Official Receipt” or “Sales Invoice” anywhere
Using OR/SI-like numbering that mirrors your registered series (can confuse audits)
Omitting purpose and treating it as proof of sale
Issuing ARs as the only document customers receive for paid services/sales

C) Keep a controlled internal series and log

Even if ARs are supplementary, it’s good practice to:

use a unique series (e.g., “AR-2026-000123”),
maintain a logbook (date, payor, amount, purpose, linked OR/SI later), and
cross-reference the eventual OR/SI (if applicable).

8) What happens if you rely on ARs instead of BIR-registered receipts?

Potential exposure typically includes:

Penalties for failure to issue receipts/invoices when required
Penalties for use/possession/printing of unregistered receipts (depending on facts)
Assessment issues: the BIR may estimate sales based on collections, bank deposits, third-party info, or gaps in invoice/receipt sequences
Customer disputes: business customers often require valid OR/SI for their own substantiation and withholding documentation

In practice, invoicing/receipting deficiencies often create bigger problems than the paper itself—because they affect audit trail integrity.

9) “Should we just get ARs BIR-approved to be safe?”

It depends on what you mean by “safe”:

If ARs are truly supplementary, the safer move is usually not to convert them into quasi-official receipts, but to use them correctly and issue the proper OR/SI when required.
If your business model genuinely needs a customer-facing document for collections, consider whether what you actually need is:
- a properly authorized principal OR/SI, and/or
- an authorized system (POS/CRM) that produces compliant documents, and/or
- a clearly labeled collection acknowledgment that never replaces the principal document.

If you try to “BIR-approve” ARs but then use them like OR/SI, you may simply be rebranding the principal document—at which point you should just issue the proper principal document in the first place.

10) Practical compliance checklist (Non-VAT)

Confirm your correct principal document (SI for goods / OR or principal invoice for services under your registration and invoicing setup).
Ensure your principal documents are authorized (ATP for printed; PTU/authorization for system-generated).
Ensure required statements for Non-VAT appear on principal documents.
If you will use ARs:
- label them supplementary,
- specify purpose (deposit/reimbursement/etc.),
- state not valid as OR/SI, and
- maintain cross-references to the eventual OR/SI when applicable.

11) FAQs

“We are Non-VAT and small. Can we issue ARs only?”

If the AR is for sales/fees, issuing ARs only is risky. Non-VAT status does not excuse the requirement to issue proper principal receipts/invoices for business transactions.

“Is a deposit already a sale?”

Not always. A refundable security deposit is generally not a sale. A customer deposit/downpayment may become part of the sale later. The documentation should reflect the true nature and timing.

“Can we print AR booklets ourselves?”

You can create internal AR forms, but if they start functioning like principal receipts (or look like them), you increase audit risk. Use clear “supplementary only” labeling and never let ARs replace the required OR/SI.

12) Bottom line answer

Non-VAT Acknowledgment Receipts do not inherently require BIR approval—as long as they are truly supplementary and are not used as substitutes for the BIR-required principal receipt/invoice for sales of goods or services. The moment an AR is used as the customer’s “official” proof of a taxable sale/collection, it can be treated as an unregistered/noncompliant principal receipt, triggering penalty and audit exposure.

General information only; for application to your specific facts (especially deposits vs sales timing, reimbursements as agent vs income, and document sequence controls), consult a Philippine tax professional or counsel.