Overview

In the Philippines, employer registration with SSS, PhilHealth, and Pag-IBIG Fund (HDMF) is generally tied to having covered workers—meaning employees (and, in many cases, compensated corporate officers) for whom the corporation must deduct and remit contributions.

So, a corporation with truly no employees is generally not required to register as an employer with these agencies yet. The key caveat is that “no employees” is often misunderstood: corporate officers who receive compensation are commonly treated as employees for social insurance purposes, which can trigger registration and remittance duties even if the corporation has no rank-and-file staff.

This article explains the rules, gray areas, and practical realities.

Core Concept: Employer Registration Follows the Obligation to Remit

Employer registration exists to enable a business to:

Report workers,
Deduct contributions, and
Remit employer + employee shares, and
File periodic reports.

If there is no one to report and no contributions to remit, the basic policy logic is: no employer account is needed yet.

But the determining question is not “Do we have employees on paper?”—it is:

Does the corporation have any person who is treated as an “employee” for SSS/PhilHealth/HDMF and receives compensable remuneration that triggers contributions?

The Most Common Trap: “No employees” but Paid Officers

Many corporations operate with:

No payroll staff, but
A president/treasurer/manager receiving a salary, allowance, honorarium, per diem, or other regular compensation.

In many compliance settings, compensated corporate officers are treated like employees (or at least treated as covered persons whose contributions must be remitted by the corporation acting as employer). This can create a duty to register and remit even if the corporation has no other workers.

Practical rule of thumb

Unpaid officers + no staff → usually no employer registration yet
Any paid officer or worker → typically register and remit

SSS: When a No-Employee Corporation Must Register

Legal framework (high level)

SSS coverage is governed by the Social Security Act (currently under RA 11199, building on earlier laws). Coverage is mandatory for:

Employees (compulsory coverage),
Employers (to register and remit), and
Separate tracks exist for self-employed and voluntary members.

General rule

A corporation generally registers as an SSS employer when it employs at least one covered employee.

The officer issue

If the corporation pays compensation to corporate officers (e.g., president, treasurer, general manager), those officers are commonly treated as employees for coverage/remittance purposes. If you pay them regular compensation, the corporation is usually expected to:

Register as employer,
Register the officer(s) as employee(s),
Deduct and remit contributions,
Submit required reports.

If the corporation has no employees and no paid officers

Typically:

No SSS employer registration is necessary yet.
However, individuals (owners/officers) may still need personal coverage as self-employed or voluntary members depending on their situation (especially if they have other income sources).

PhilHealth: Employer Registration vs. Individual Coverage

Legal framework (high level)

PhilHealth operates under RA 7875 as amended, and the Universal Health Care framework under RA 11223 expanded population coverage concepts. In practice, contribution collection still distinguishes between:

Employed members (with employer counterpart and payroll remittance), and
Self-paying members (self-employed/professionals, etc.), and
Other classifications.

General rule

A corporation registers as a PhilHealth employer when it has employees for whom it must remit employed-member contributions.

If there are no employees

If the corporation has no staff and no compensated officers treated as employed members:

It typically does not need to register as a PhilHealth employer yet.

If officers are compensated

If an officer is treated as an employed person and compensated through payroll-like arrangements:

Employer registration and remittance are typically expected.

Important practical note

Even if a corporation has no employees, the individuals involved may still need to be properly classified in PhilHealth (e.g., self-paying) depending on their income and status. Employer registration is a separate question from personal membership.

Pag-IBIG (HDMF): When Employer Registration Is Triggered

Legal framework (high level)

Pag-IBIG Fund is governed by RA 9679 (Home Development Mutual Fund Law of 2009) and implementing rules/issuances. Obligations typically arise for:

Employers (to register and remit),
Employees (mandatory contributions in covered employment),
Optional/voluntary coverage mechanisms for others in certain cases.

General rule

A corporation generally registers as an HDMF employer when it has covered employees.

If there are no employees and no paid officers treated as employees

Usually:

No employer registration is required yet.

If there are compensated officers or workers

If the corporation has a person treated as an employee for coverage purposes:

Employer registration and remittance are usually expected.

One Person Corporation (OPC) and “Single-Owner” Setups

A common modern setup is an OPC with:

One stockholder (who is also president and sole director),
No other staff.

Whether registration is required depends on whether the OPC pays compensation in a manner that creates an employer–employee style relationship for social insurance remittances. If the OPC pays its president a regular salary (and treats it as compensation), agencies may expect employer registration and remittance.

If the OPC has no payroll and no paid officer compensation, it is often treated as having no trigger for employer registration—though the individual may still need personal coverage through other classification routes.

“But We Need It for Permits / Banking / Bidding”: The Practical Reality

Even when not strictly required by statute at the moment, some third parties (and sometimes local processes) request:

Employer numbers,
Certificates of compliance,
Proof of registration.

This can happen for:

Business permit renewals,
Government procurement,
PEZA/BOI or other registrations,
Bank account opening / credit due diligence,
Corporate vendor accreditation.

How no-employee corporations typically handle this

Common approaches include:

Requesting/maintaining a “No Employees” status/annotation with the relevant agency (where available in practice), or
Securing a certification/letter indicating no remittance obligation due to no employees, or
Registering only once there is a covered person—while documenting corporate status to explain to third parties.

Be careful: registering as an employer “just to have a number” can create reporting expectations. If the system expects periodic filings/remittances and you submit nothing, you could trigger notices, penalties, or compliance flags unless the account is properly tagged as no-employee/inactive (if the agency allows that treatment).

What Counts as “Compensation” That Can Trigger Coverage?

To evaluate whether you actually have a covered person, examine whether the corporation pays any natural person:

Salary/wages
Allowances treated as compensation
Regular honoraria
Fixed monthly “management fee” paid to an individual
Taxable benefits given as part of work/service

Also watch for:

Individuals paid via “consultancy” arrangements that function like employment (control, fixed hours, integral role, exclusivity). Even if called “consultant,” agencies may treat it differently depending on facts.

Penalties and Risk Exposure

If a corporation should have registered/remitted but did not, potential consequences can include:

Assessment of unremitted contributions,
Penalties/surcharges/interest (structure varies by agency rules),
Administrative enforcement actions,
Issues obtaining clearance/certifications later,
Complications when an officer/worker later claims benefits and records are missing.

Conversely, registering too early without proper “no employee” tagging can create:

Compliance notices for missing reports,
System-generated delinquencies,
Administrative hassle to correct status.

Best-Practice Compliance Strategy for No-Employee Corporations

1) Confirm you truly have “no covered persons”

Create an internal checklist:

No rank-and-file employees
No paid officers receiving compensation from the corporation
No individuals paid in a way that resembles employment

2) Document officer compensation status clearly

If officers are unpaid:

Board resolution stating officers receive no compensation (or only reimbursements supported by receipts)
Keep reimbursements clearly documented as expense reimbursements, not allowances

3) Decide the trigger point for registration

Hire your first employee, or
Start paying compensation to an officer in a covered way

4) If third parties demand proof

Prepare a standard packet:

Sworn statement or corporate certification: “No employees”
Latest GIS/SEC documents showing officers
Board resolution on non-compensation (if true)
Explanatory letter for why employer registration is not yet applicable

Frequently Asked Questions

Q: We pay directors per meeting. Does that count?

It can, depending on how it is structured and frequency. If it resembles compensation for services, it may raise coverage questions. Meeting per diems and honoraria should be evaluated carefully.

Q: We only pay dividends.

Dividends are generally returns on investment, not salary. Pure dividend payment without employment-type compensation typically does not create employer remittance duties.

Q: We pay a bookkeeping firm, not an individual.

If the payee is a legitimate separate business entity (not a disguised employee relationship), that usually does not create an employer–employee relationship with the corporation. But if the arrangement is effectively an individual working under company control, risk increases.

Q: Can we register later when we hire?

Yes—many corporations register upon hiring their first employee. The key is not to miss the point when coverage becomes mandatory.

Practical Bottom Line

A corporation with no employees usually does not need to register as an employer with SSS, PhilHealth, and Pag-IBIG yet. However, if the corporation has any compensated officer or worker treated as covered employment, registration and remittance obligations can be triggered—even without rank-and-file staff.

Quick Decision Guide

You likely do NOT need employer registration yet if:

No employees
Officers are unpaid
No one receives salary/allowances/honoraria as compensation

You likely DO need employer registration if:

You hire even one employee, or
You pay a corporate officer regular compensation, or
You have a worker relationship that looks like employment even if labeled “consultant”

This article is for general informational purposes and does not constitute legal advice. For a definitive compliance position (especially for officer compensation structures, OPC setups, or mixed consultancy arrangements), consult a Philippine labor/employment or corporate compliance practitioner familiar with SSS/PhilHealth/HDMF assessments.