Employer of Record sounds simple until a client asks: "Can you hire this one foreign employee for us?"

The answer depends entirely on one question most people forget to ask first: will they actually be physically working in the Philippines?

Here's why that question matters more than almost anything else in the conversation.

If they're working remotely, never setting foot here: none of what follows applies. No Alien Employment Permit, no work visa, no Bureau of Immigration filing. Philippine immigration law regulates work performed within Philippine territory — not who employs someone, or what passport they hold. A foreign hire working from their own country, under a Philippine company, is typically structured as an independent contractor, paid directly, with no local immigration process at all.

The moment they're physically here doing the work, everything changes. That's when an Alien Employment Permit (AEP) becomes mandatory — and as of June 2026, AEP processing has centralized to DOLE's Bureau of Local Employment Central Office under Administrative Order No. 199. Providers still quoting pre-2026 timelines are working from outdated information.

What actually has to happen, in order, once someone is working on Philippine soil:

→ A Labor Market Test — proving no qualified Filipino can fill the role, with local publication requirements

 → AEP filing and DOLE evaluation

 → A 9(g) Pre-Arranged Employment Visa, paired with the AEP, via the Bureau of Immigration

 → BIR TIN registration for the foreign hire

 → SSS, PhilHealth, and Pag-IBIG enrollment — mandatory the moment they're locally employed, same as any Filipino staff member

Miss that distinction, and you're not looking at a delay — you're looking at a foreign employee who legally cannot start work on the date you promised your client, or one who's been filed for unnecessarily.

This is where global EOR platforms show their limits. They're built for volume, not for navigating one country's immigration bureaucracy update by update. Knowing exactly when the rules apply — and when they don't — is the difference between a smooth hire and a stalled one.

We've processed AEP cases since 2016 and track every regulatory change, including this year's centralization, because our clients' hires don't get to wait for us to catch up.

If someone quotes you AEP pricing before asking where your hire will physically work — ask more questions.

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