I. Purpose and Scope

A newly registered establishment in the Philippines enters a regulated employment environment the moment it engages a worker—whether probationary, regular, project-based, fixed-term, seasonal, part-time, or through a legitimate contractor. “DOLE compliance” is not a single filing; it is an ongoing system of (a) reportorial submissions to the Department of Labor and Employment and (b) workplace records that must be created, updated, and made available for inspection.

This article consolidates the core mandatory reports and records typically expected of establishments under Philippine labor standards, occupational safety and health (OSH), and related DOLE issuances, with emphasis on what a new establishment should set up immediately.

II. Compliance Architecture: What DOLE Commonly Looks For

DOLE compliance, as enforced through labor inspection and OSH enforcement, generally clusters into five “buckets”:

Employment documentation (contracts, policies, employee data, proof of lawful pay and benefits)
Timekeeping and payroll systems (wage compliance, statutory benefits, proof of payment)
Statutory labor standards records (leaves, holidays, 13th month, disciplinary and separation documentation)
OSH programs, committees, training, and incident reporting (RA 11058 and its IRR framework; DOLE OSH rules)
Contracting/subcontracting and special workforce arrangements (compliance when engaging contractors; special permits; foreign nationals)

A sound checklist must therefore be both paperwork-complete and system-ready (i.e., can produce documents on demand and demonstrate implementation).

III. One-Time or “Foundational” DOLE-Facing Actions for New Establishments

A. Establishment Registration/Profiling (Regional Office/Online Systems)

Many DOLE regional processes begin with an establishment profile/registration (often via an online establishment registration facility used for inspection coverage and official transactions). Practical takeaway: treat establishment profiling as a foundational step, and keep a copy of the registration confirmation/number, plus the details you submitted (address, nature of business, workforce size, working hours, contact person).

Maintain on file:

Proof of business registration (SEC/DTI/CDA, mayor’s permit, BIR registration)
Establishment profile printout/confirmation and any updates
Organizational chart and contact persons for HR/payroll and OSH

B. If Hiring Foreign Nationals: Alien Employment Permit (AEP) Track

If you will employ foreign nationals in the Philippines (outside exempt categories), the establishment typically must secure an AEP (processed through DOLE). This becomes a report-and-record obligation: retain AEP applications, approvals, exemptions (if applicable), employment contracts, and position justifications.

Maintain on file:

AEP application, proof of publication/posting (where required), and approval
Employment contract and position description
Visa/work authorization documentation and compliance correspondence

IV. Mandatory DOLE Reports (Reportorial Requirements)

Below are the most common reports that must be submitted to DOLE or its offices depending on your circumstances. Not all apply to every business; a new establishment should identify which apply and diarize deadlines.

A. Work Accident/Illness Reporting (Core OSH Reporting)

Under the OSH framework, establishments must report work-related accidents, dangerous occurrences, and occupational illnesses, especially those resulting in death, serious injury, disabling injury, or hospitalization, within prescribed periods and using DOLE/BWC/Regional Office reporting channels/forms.

Minimum compliance system:

A written internal protocol for incident reporting and investigation
A designated responsible officer (often the Safety Officer/HR)
Incident logs and investigation reports
Timely notification to DOLE when thresholds are met

Records tied to the report (must be kept):

Incident report, investigation findings, witness statements
Medical findings/fit-to-work notes (privacy-compliant handling)
Corrective action documentation and committee minutes approving measures

B. OSH Program-Related Submissions (When Required by Industry/Size/Risk)

Some workplaces—particularly those in higher risk classifications or with larger headcount—are expected to have a formal OSH program and specific OSH staffing/training. While the OSH program is primarily a kept-on-site document, particular industries (notably construction) require submission/approval of a safety and health program before work starts.

Construction note: For construction projects, a Construction Safety and Health Program (CSHP) is commonly required for submission in accordance with construction OSH rules.

C. Notifications for Certain Work Arrangements (When Implemented)

Certain non-standard work arrangements may require DOLE notification or at least documentation ready for inspection—examples include compressed workweek schemes and other alternative arrangements that affect normal working hours, rest days, and premium computations.

Keep ready:

Company policy/board resolution implementing the scheme
Employee acknowledgments/consents where appropriate
Computation templates proving no wage diminution and correct premiums

D. Contracting/Subcontracting-Related Filings (If You Are a Contractor; If You Engage Contractors, Keep Records)

Department Order-based rules on contracting (commonly associated with “labor-only contracting” prohibitions) create two compliance tracks:

If you are a contractor/subcontractor: you may need to register as such with DOLE and meet capitalization, compliance, and reporting requirements.
If you are a principal engaging contractors: your obligation is strong recordkeeping and due diligence—you must keep proof that the contractor is legitimate and that deployed workers receive lawful wages and benefits.

Principal’s must-keep file for each contractor:

Contracting agreement with clear scope and consideration
Proof of contractor’s legitimacy (registration/certificate where applicable)
Contractor payroll summaries and proof of wage payment for deployed workers (or equivalent compliance proofs)
Proof of remittance of statutory contributions for deployed workers (as contractually required)
List of workers assigned, work schedules, and supervision boundaries (to avoid “labor-only” indicators)

V. Mandatory Workplace Records (What You Must Have Ready On-Site)

Even when no periodic report is due, DOLE inspection frequently turns on whether your records exist, are accurate, and show implementation. For new establishments, the goal is to set up a complete “records spine.”

A. Employment Records (Per Employee)

1) Hiring and status documents

Application and pre-employment requirements
Employment contract (with position, wages, work schedule, work location, probation terms if any)
Job description and reporting line
Proof of age/identity (to ensure lawful employment; special rules apply to minors)
Confidentiality, code of conduct, and company policy acknowledgments
Apprenticeship/learnership agreements if applicable (special DOLE rules apply)

2) Personnel movement

Regularization notices (or end-of-probation outcomes)
Promotions, transfers, salary adjustments (with effective dates and basis)
Disciplinary records (due process documentation)
Separation/termination records (resignation letters, notices, quitclaims—handled carefully)

3) Required policy acknowledgments Maintain signed acknowledgments for:

Working hours, rest day rules, overtime policy
Leave policies and conversion rules
Anti-sexual harassment and safe spaces policy orientation (committee/process)
Anti-violence/harassment policies
Data privacy notices for employee information

B. Timekeeping and Payroll Records (Labor Standards Core)

1) Time records

Daily time records (DTR) / bundy logs / biometric logs
Work schedules and shift rosters
Overtime approvals and actual rendered OT
Night shift records (if applicable)
Work-from-home/hybrid time proof (if applicable)

2) Payroll records A payroll register that clearly shows:

Basic pay rate and pay period
Hours/days worked and premium computations (OT, rest day, holiday, night differential)
Allowances and their treatment (integrated vs. non-integrated, if applicable)
Deductions (authorized and lawful)
Net pay and proof of payment (bank advice, payslip acknowledgments)

3) Statutory monetary benefits documentation

13th month pay computations and proof of release
Service incentive leave (SIL) credits and usage, or proof of exemption if legitimately exempt
Holiday pay and premium pay computations
Wage order compliance (current minimum wage and correct application of regional wage orders)

Record retention practice (practical rule): Keep payroll/time records in an organized, retrievable format for several years. When in doubt, retain longer—especially if you are in industries with frequent claims exposure.

C. Required Posted Notices / On-Site Disclosures

While the exact poster set varies by industry and local practice, establishments should be ready to show:

Company rules and regulations (where applicable), code of discipline
Workplace policies on harassment and reporting mechanisms
Emergency numbers, evacuation plan, and first-aid arrangements
OSH commitments and key OSH personnel (Safety Officer/First Aiders/Fire Brigade lists)
Wage-related notices where required or prudent (payday schedule, wage rates, pay slips availability)

D. Occupational Safety and Health (OSH) Records and Systems

A compliant OSH “binder” (physical or digital) typically contains:

1) OSH program and governance

Written OSH program appropriate to the workplace
Safety and Health Committee constitution, member list, and meeting minutes
OSH budget and procurement records (PPE, training, controls)

2) Risk management

Hazard identification and risk assessment (HIRA) documents
Control measures implementation records
Job safety instructions and toolbox meeting records (as applicable)

3) Training and competency

Safety Officer appointment and proof of required training
First-aider training certificates and roster
Orientation records for all employees (and contractors on-site)
Specialized training records (chemical handling, electrical safety, work at height, etc., if applicable)

4) Health surveillance and medical

Pre-employment and periodic medical exam records where applicable (privacy-protected)
Clinic/first-aid logbook and medicines inventory (as applicable)
Health programs (e.g., communicable disease protocols when relevant)

5) Incident logs and reporting

Accident/incident logbook
Near-miss reports and investigations
Corrective actions tracking and closure evidence
DOLE notification submissions and acknowledgments (when incidents trigger reporting)

6) Equipment, facilities, and inspections

Preventive maintenance logs
Certifications/inspections for covered equipment (e.g., pressure vessels/elevators/hoists) where applicable
Fire safety inspection documentation and drill records (coordinate with fire code compliance separately, but keep OSH copies)

7) Chemical safety (if chemicals are used/stored)

Chemical inventory
Safety Data Sheets (SDS)
Labels and storage compatibility plans
Exposure monitoring results (if conducted) and controls

VI. Special Situations: Extra Reports/Records New Establishments Often Miss

A. Multi-Employer or Contractor-Heavy Sites

If multiple contractors work on-site, maintain:

A contractor control program (orientation, permits-to-work, incident reporting, PPE rules)
Contractor attendance and toolbox meeting logs
Clear delineation of supervision (principal supervises results, not the manner/method, to avoid “labor-only” indicators)

B. Project Employment and Fixed-Term Arrangements

For project-based engagements:

Project employment contracts with specific project and duration
Assignment orders, project completion records
Clear payroll segregation for project workers
OSH orientation and site-specific hazard briefings

C. Apprenticeship/Learnership/Internship

These arrangements have specialized requirements and are frequently scrutinized. Maintain:

Approved programs and agreements
Proof of school coordination for internships (where applicable)
Allowance/pay compliance and hours limitations
Training plans and evaluation records

D. Establishments with Night Work or Extended Hours

Maintain:

Night differential computations and proof
Policies on fatigue management and safe transport measures where applicable
OSH risk assessment addressing night work hazards

VII. Building the “DOLE Inspection-Ready” Compliance File (Practical Checklist)

A. Corporate/Establishment Profile Folder

Business registrations and permits
Establishment profile/registration confirmation (and updates)
Organizational chart; HR/payroll/OSH focal persons
Company policies manual; code of conduct

B. Employment & Personnel Folder (Per Employee + Masterlist)

Contracts, IDs, status documents
Master employee list with hire dates, positions, rates, schedules
Disciplinary and movement records
Separation records (when applicable)

C. Payroll & Timekeeping Folder (By Pay Period)

DTR/biometric exports and approved schedules
Payroll register, payslips, proof of payment
Premium computations templates (OT/holiday/rest day/night diff)
13th month computation and proof of release
Leave ledgers (SIL and other leaves)

D. OSH Folder (Living System)

OSH program; committee documents; meeting minutes
HIRA; safety policies; emergency response plan
Training matrix; certificates; orientations
Incident logs, investigations, corrective actions
Equipment inspections, maintenance logs, SDS/chemical inventory (if applicable)
DOLE-reportable incident submissions and acknowledgments (if any)

E. Contracting Folder (Per Contractor)

Contract and scope
Proof of legitimacy/compliance documents
Lists of assigned workers and their compliance proofs
Site orientation logs and OSH coordination

VIII. Compliance Calendar for a New Establishment (Suggested Operating Rhythm)

Every pay period

Update time records and payroll register
Archive payslips/proof of payment
Update leave ledgers and premium pay computations

Monthly

Reconcile attendance vs. payroll vs. schedules
OSH committee check-ins (or as required by your OSH structure)
Update training tracker and PPE issuance logs

Quarterly

Conduct safety inspections and document corrective actions
Review wage compliance against current wage orders and job classifications
Audit contractor compliance files (if applicable)

Annually

Refresh OSH program and training plan
Conduct emergency drills and document after-action reports
Review 13th month pay computation controls
Conduct an internal labor standards audit (records completeness and consistency)

Immediately upon trigger

Report and investigate qualifying workplace accidents/illnesses
Document and implement corrective actions
Update DOLE establishment details when material changes occur (address, ownership structure, workforce scale—based on applicable registration processes)

IX. Consequences of Non-Compliance (Why Records Matter)

Non-compliance is often found not because an employer intentionally violates the law, but because it cannot prove compliance. In practice:

Missing or unreliable time records can lead to findings of underpayment of wages, OT, holiday pay, and night differential.
Incomplete OSH documentation can lead to OSH violations, work stoppage orders in severe cases, and administrative/criminal exposure under the OSH law framework when willful non-compliance results in serious harm.
Weak contracting documentation can reclassify a relationship into prohibited arrangements, exposing the principal to employer liabilities.

The best defense is a compliance system that produces consistent, contemporaneous, and verifiable records.

X. Quick-Reference Checklist: “Minimum Viable DOLE Compliance” for Day 1

Labor Standards

Employment contracts + employee masterlist
Timekeeping system + schedules + OT approvals
Payroll register + payslips + proof of payment
Leave ledger (SIL and other company leaves)
13th month pay computation file (ready even if paid later)
Posted workplace rules and key employee policies

OSH

Written OSH program
Safety and Health Committee + minutes
HIRA / hazard log + controls
Training records (orientation, Safety Officer, first aiders)
Incident logbook + investigation templates
Emergency plan + drill records (as conducted)
PPE issuance logs

Contracting (if applicable)

Contractor due diligence file + worker list + compliance proofs
On-site OSH coordination and orientations

Other statutory (related but not DOLE)

SSS registration and remittances
PhilHealth registration and remittances
Pag-IBIG Fund registration and remittances

These are not “nice to have.” They form the documentary backbone that labor inspectors and adjudicators rely on when resolving compliance issues and money claims.