Compliance Checklist for Australian Financial Services Companies Hiring in the Philippines
Author: Martin English
Published: May 27, 2026
Hiring finance, accounting or support staff in the Philippines requires more than finding the right candidate. Australian companies should consider worker classification, employment contracts, payroll, statutory contributions, privacy, data security, outsourcing oversight and ongoing supervision.
An Employer of Record can manage the local employment process, but it does not remove the Australian company’s responsibility for its own regulatory, operational, privacy or governance obligations.
This guide provides general information only. It is not legal, tax or regulatory advice. Australian companies should obtain professional advice for their specific arrangement.
Quick answer
Before hiring staff in the Philippines, Australian financial services companies should:
- Confirm whether the role should be structured as employment or contracting.
- Verify the EOR provider’s Philippine legal entity and employment processes.
- Use a written employment contract that complies with applicable Philippine requirements.
- Confirm payroll, SSS, PhilHealth, Pag-IBIG and BIR processes.
- Review Australian privacy and cross-border data obligations.
- Assess whether the work supports a material business function or critical operation.
- Define access, supervision, reporting and audit controls.
- Document the EOR’s responsibilities and the company’s responsibilities.
- Prepare an orderly offboarding and transition process.
Companies that want to hire in the Philippines without setting up a local entity can read our guide to hiring employees in the Philippines without a company.
SOS EOR pricing and support
Smart Outsourcing Solution charges one EOR management fee:
US$190 per employee per month
This is the only SOS EOR rate. It is not a starting price, estimate or price range.
Recruitment and candidate selection are included in the fee. There is no separate recruitment fee.
Salary, employer statutory contributions, 13th-month pay, benefits, allowances, equipment and other employee-specific costs are separate where applicable.
Under the standard EOR structure, there are:
- No hidden SOS provider costs
- No FX markup
- No onboarding fee
- No SOS provider termination or exit fee
A real person remains involved throughout recruitment, onboarding, payroll, HR support, compliance and offboarding.
See Philippines EOR pricing for a detailed explanation of the management fee and separate employment costs.
1. Confirm the worker’s classification
The first step is to assess whether the person should be engaged as an employee or an independent contractor.
A role may have characteristics of employment where the company:
- Sets regular working hours
- Directs how the work is performed
- Provides ongoing supervision
- Integrates the worker into internal teams
- Provides or requires the use of company systems
- Assigns recurring operational duties
- Expects a long-term or exclusive relationship
The written agreement is only one part of the assessment. The actual working relationship, level of control and day-to-day arrangement should also be considered.
An EOR can support the formal employment structure, but it does not replace a case-specific classification review.
2. Verify the EOR provider
Before appointing an EOR, confirm:
- The provider’s Philippine legal entity
- Corporate registration details
- Employment contract process
- Payroll process
- SSS, PhilHealth and Pag-IBIG remittance process
- BIR withholding and reporting process
- Employee recordkeeping procedures
- Benefits administration
- Onboarding and offboarding procedures
- HR support and escalation process
- Data security controls
- Confidentiality procedures
- Audit and reporting capability
- Treatment of employee-specific costs
- Responsibilities when employment ends
Ask the provider to explain which services are included in the management fee and which costs are charged separately.
For a more structured provider review, use the Philippines EOR quote comparison and fee normaliser.
3. Review the employment contract
The Philippine employee should receive a written employment contract that clearly explains the employment terms.
The contract should address, where applicable:
- Position title
- Duties and responsibilities
- Salary and pay schedule
- Working hours
- Work location
- Probationary period
- Leave entitlements
- Benefits and allowances
- Confidentiality
- Data privacy
- Intellectual property
- Company systems and access
- Notice and termination provisions
- Statutory contributions
- 13th-month pay
- Employee policies
- Dispute and escalation procedures
For finance and accounting roles, confidentiality, system access and client-information handling should be addressed clearly.
4. Confirm payroll and statutory administration
The EOR should explain how it manages:
- Salary payments
- Payroll cut-off dates
- Payslips
- SSS contributions
- PhilHealth contributions
- Pag-IBIG contributions
- BIR withholding
- Employee tax documentation
- 13th-month pay
- Leave records
- Benefits enrolment
- Final pay
Employer statutory contributions are employee-related costs and are separate from the US$190 SOS EOR management fee.
Under the standard SOS EOR structure, employee wages and mandatory government contributions are passed through at cost. 13th-month pay is an employee-related cost and may be invoiced monthly at 1/12 of the employee’s monthly base wage.
Contribution rates and payroll requirements can change. Use current official Philippine sources when preparing calculations or approving a quote.
5. Review privacy and data obligations
Finance and accounting staff may access personal, financial or commercially sensitive information.
Before providing access, review:
- What information the employee will handle
- Where the information will be stored
- Which systems the employee can access
- Whether information will be transferred outside Australia
- Who can approve and remove access
- How security incidents will be reported
- How information will be returned or deleted
- Whether a Data Processing Agreement is required
- Whether confidentiality and security obligations are documented
Australian Privacy Principle 8 may be relevant when personal information is disclosed to an overseas recipient. The specific obligations depend on the information, parties and arrangement involved.
A Data Processing Agreement is generally recommended and may be required depending on the data and privacy obligations that apply.
6. Assess ASIC, AFSL and operational-risk requirements
Australian financial services companies should assess whether the Philippines-based role supports a material business function, critical operation or regulated activity.
Consider:
- The nature of the work
- The systems and information the employee can access
- The effect of provider failure
- Business continuity requirements
- Concentration risk
- Supervision and quality controls
- Audit rights
- Incident reporting
- Service monitoring
- Exit and transition planning
AFSL holders should determine whether the arrangement needs to be recorded in an outsourcing, risk or governance register. The applicable requirements should be confirmed with the company’s legal, risk or compliance advisers.
APRA-regulated organisations should also review the CPS 230 and offshore teams guide before finalising a material offshore arrangement.
7. Set up access and security controls
Before the employee starts, define:
- Which systems the employee can access
- The minimum access required for the role
- Approval requirements
- Multi-factor authentication
- Password and device controls
- Logging and monitoring
- Restrictions on downloading information
- Restrictions on personal-device use
- Incident-reporting procedures
- Access-review frequency
- Offboarding and access-removal procedures
Access should be based on the employee’s duties. Finance, client-service and compliance roles should not automatically receive broad access to all company systems.
8. Prepare audit-ready records
Keep evidence of:
- Worker-classification assessment
- EOR due diligence
- Provider registration checks
- Signed employment contract
- Employee identity and employment documents
- Statutory registrations
- Payroll records
- Remittance confirmations
- 13th-month pay calculations
- Benefits records
- Data Processing Agreement, where applicable
- Confidentiality agreement
- Access approvals
- Security training
- Incident reports
- Governance reviews
- Performance and supervision records
- Offboarding confirmation
The exact records required will depend on the company’s structure, industry, systems and regulatory obligations.
9. Define responsibilities between the company and EOR
| Area | Australian company | SOS EOR |
| Daily work and priorities | Manages | Supports the employment relationship |
| Performance expectations | Sets and manages | Provides HR support where required |
| Employment contract | Provides role and package requirements | Administers local employment documentation |
| Salary and benefits | Approves the package | Processes according to agreed terms |
| Payroll | Reviews and funds payroll | Administers payroll |
| Statutory contributions | Funds applicable costs | Administers and remits applicable contributions |
| Recruitment | Approves role and candidate requirements | Recruitment and candidate selection included |
| HR support | Manages business-related matters | Provides employment and HR support |
| Privacy and access | Controls business access and data use | Supports agreed employment processes |
| Offboarding | Confirms business decision and handover | Manages employment administration and final-pay process |
These responsibilities should be reflected in the EOR agreement, service schedule and employee-specific terms.
10. Understand the total employment cost
The US$190 SOS EOR management fee is separate from:
- Employee salary
- Employer statutory contributions
- 13th-month pay
- HMO or other benefits
- Allowances
- Equipment and software
- Other approved employee-specific costs
- Legally required final pay or employment obligations
Recruitment and candidate selection are included in the SOS EOR management fee and are not charged separately.
Use the Philippines employee cost calculator to model salary, statutory costs, 13th-month pay, benefits and the EOR management fee.
11. Plan the hiring timeline
Existing employees can generally be onboarded as early as five business days once the following are complete:
- Signed agreement
- Complete employee information
- Required employment documents
- Agreed salary and benefits
- Required approvals
- Payroll funding
For new candidates, recruitment is included in the EOR fee. The hiring timeline may vary depending on:
- Role requirements
- Candidate availability
- Seniority
- Interviews
- Assessments
- Reference checks
- Offer acceptance
- Notice period
- Required documentation
The five-business-day timeline applies to eligible existing-employee onboarding once the required information, documents and funding are complete. It should not be presented as a guaranteed timeline for every new hire.
12. Plan for offboarding
The company and EOR should agree how the arrangement will end before employment begins.
Review:
- Notice requirements
- Final-pay calculations
- Accrued leave
- Statutory obligations
- Benefits termination
- Return of equipment
- Data return or deletion
- System-access removal
- Client communication
- Employee records
- Handover responsibilities
- Transition to another provider or direct employment
There is no SOS provider termination or exit fee under the standard EOR structure. Legally required final pay, severance, accrued benefits or other employee-related obligations may still apply.
Companies moving an existing contractor into employment can read the contractor-to-EOR conversion guide.
Frequently Asked Questions
Is an EOR automatically compliant for an Australian financial services company?
No. An EOR can support Philippine employment and payroll administration, but the Australian company must still assess its privacy, regulatory, operational-risk, outsourcing and governance responsibilities.
Is recruitment included in the SOS EOR fee?
Yes. Recruitment and candidate selection are included in the US$190 SOS EOR management fee. There is no separate recruitment fee.
What is the SOS EOR fee?
The SOS EOR management fee is US$190 per employee per month. This is the only SOS EOR rate.
Are salary and statutory contributions included?
No. Salary, employer statutory contributions, 13th-month pay, benefits, allowances, equipment and other employee-specific costs are separate where applicable.
Are there hidden SOS provider fees?
No. The standard SOS EOR structure has no hidden provider costs, FX markups, onboarding fees or provider termination or exit fees.
Can an existing employee be onboarded quickly?
Existing employees can generally be onboarded as early as five business days once the agreement, employee information, required documents and funding are complete.
Does the EOR take responsibility for the Australian company’s compliance?
No. SOS manages the local employment relationship and related employment administration. The Australian company remains responsible for its business operations, supervision, system access, data handling and applicable Australian obligations.
Final checklist
Before onboarding a Philippines-based finance or accounting employee, confirm that you have:
- Completed a worker-classification review
- Verified the EOR provider
- Reviewed the employment contract
- Confirmed salary and employee-specific costs
- Confirmed the US$190 monthly EOR fee
- Confirmed that recruitment is included
- Reviewed statutory contribution processes
- Reviewed privacy and data-transfer requirements
- Assessed ASIC, AFSL or APRA obligations where applicable
- Defined system-access controls
- Agreed reporting and audit procedures
- Prepared an offboarding process
- Documented the arrangement in writing
Speak with a Philippines EOR specialist
Smart Outsourcing Solution can help you review:
- Philippines employment requirements
- EOR suitability
- Finance and accounting role structures
- Recruitment and candidate selection
- Salary and employment-cost planning
- Payroll and statutory administration
- Privacy and data-handling considerations
- Contractor-to-employee transitions
- Existing-employee onboarding
- Offboarding and employee transfers
The SOS EOR management fee is US$190 per employee per month, with recruitment included and employee-specific costs shown separately.
