SOCE Guide: Which Expenses Count for Campaign vs. Election Period in the Philippines

Executive Summary

In the Philippines, what you must disclose in your Statement of Contributions and Expenditures (SOCE) and what counts toward spending limits hinges on when and why the money was spent. In brief:

SOCE + spending limits = “campaign expenditures.” These are amounts spent to promote a candidacy during the official campaign period (and obligations incurred then, even if paid after).
The “election period” (typically much longer) governs security and conduct rules (e.g., gun ban, appointments ban), not campaign finance accounting.
Pre-campaign (before campaign period): activities are not “campaigning” for purposes of spending limits; expenses here generally don’t count toward the cap, but beware coordination, advance payments, and proper labeling in your books.
Silence period/election day: no campaigning is allowed, but payments made on or after election day still count in the SOCE if the obligation arose during the campaign period.
In-kind help and coordinated third-party spending are contributions and must be reported; independent (non-coordinated) spending is not a contribution to the candidate but is still regulated separately.

The rest of this article explains the legal framework, timing rules, classification tests, edge cases, documentation standards, and filing mechanics in detail.

Legal Framework at a Glance

Philippine campaign finance is primarily governed by:

The Omnibus Election Code (OEC)
RA 7166 (Synchronized Elections Act) – spending limits and SOCE filing
RA 9006 (Fair Elections Act) and implementing COMELEC resolutions – campaign period mechanics and propaganda rules
COMELEC resolutions issued for each electoral cycle (they refine forms, due dates, and granular rules)

Practical takeaway: Spending limits and SOCE are tied to the campaign period declared by COMELEC for that specific election, while the election period triggers separate conduct restrictions (e.g., gun ban) and does not expand what you must include in the SOCE.

Key Definitions

Candidate, Party, Party-List

Candidate: A person who is lawfully running for office.
Political party/party-list: Must also file SOCEs through their designated treasurer.

Election Period vs. Campaign Period

Election period: A fixed window (traditionally, 90 days before election day to 30 days after) that activates special election-related restrictions (e.g., firearms, transfers, appointments).
Campaign period: The shorter, COMELEC-set window when candidates are allowed to campaign (typical baselines: 90 days for national posts; 45 days for most local posts; barangay/SK periods are separately set per cycle).
- Campaign silence applies immediately before and including election day.

Contribution

Cash or in-kind support given for the purpose of influencing the election, including donated goods, services, discounts, and use of property.
Volunteer services provided without compensation are generally not contributions; however, out-of-pocket costs paid by volunteers for campaign’s benefit count as in-kind contributions if coordinated or received by the campaign.

Campaign Expenditure

Any payment, liability, or thing of value used to promote or oppose a candidate during the campaign period, including obligations incurred in that period (even if paid later). These count toward the spending limit and must be included in the SOCE.

Timing Rule: The Heart of the SOCE

What Counts (and toward the cap)

Obligations incurred during the campaign period for campaign purposes (ads ordered, tarpaulins printed, staff hired, headquarters leased, rallies mounted).
Payments after election day for those obligations still count (they were incurred during the campaign period).
In-kind contributions received/used during the campaign period (e.g., free venue for a rally, donated fuel, billboard space) count at their fair market value.

What Generally Does Not Count Toward the Cap

Pre-campaign spending: materials, tours, ads, or events before the campaign period typically do not count toward spending limits.
- Caveats:
  - If you prepay for goods/services to be used during the campaign period, those uses are campaign expenditures.
  - If materials are carried over and used during the campaign period (e.g., re-posting the same content, re-running ads, re-displaying tarps), allocate the pro-rata fair value used within the period.
Election-period-only compliance costs (e.g., firearm ban compliance) that are not for promoting a candidacy are not campaign expenditures.
Truly independent expenditures (by citizens/organizations without coordination): not contributions and not the candidate’s expenditures—though still subject to separate transparency/propaganda rules for the spender.

Classification Tests & Practical Examples

A. Media and Digital Advertising

TV/Radio/Print ad aired during campaign period → Campaign expenditure (book full cost for airings within the period).
Digital ads (FB/Google/TikTok) served during campaign period → Campaign expenditure (use platform invoices with date-stamped delivery).
Boosted pre-campaign posts that continue into campaign period → Pro-rate the impressions/flight during campaign period to the campaign expenditure.
Organic content created by volunteers with no coordination and no payment → Not a contribution, not an expenditure.
Agency retainers signed pre-campaign but work performed during campaign → Billable work performed/used during campaign is a campaign expenditure.

B. Ground Operations

HQ rent and utilities during the campaign period → Campaign expenditure.
Field staff stipends, per diems, transport, fuel during the campaign period → Campaign expenditure.
Volunteer meals paid by a supporter and coordinated by the campaign → In-kind contribution; record fair value → Campaign expenditure.
Volunteer-brought food without coordination/solicitation → Generally not a reportable contribution.

C. Collaterals & Merchandise

Tarpaulins printed and posted during the campaign → Campaign expenditure.
Tarps printed pre-campaign but posted during campaign → Value attributable to the campaign-period display counts.
Giveaways (shirts, caps, umbrellas) distributed during campaign → Campaign expenditure (watch barangay/local propaganda size/content rules).
Sample ballots prepared for election day (ordered during campaign) → Campaign expenditure.

D. Events, Rallies, and Concerts

Venue, staging, sound system, artists’ fees for a rally during campaign → Campaign expenditure.
Religious/charitable events: Beware vote-buying and prohibited donations rules; if for promotion during campaign, treat as campaign expenditure (even if framed as “community assistance”).

E. Election Day & Silence Period

Campaigning is prohibited, but payments made on or after election day count if they settle campaign-period obligations (e.g., unpaid print invoices, last-mile logistics).
Watchers’ allowances for poll watching on election day: commonly treated as campaign expenditure if obligation was set during campaign period or they perform campaign-related functions (coordination, voter assistance consistent with law).
Transportation for voters may cross into vote-buying/undue influence issues—do not treat illegal spending as legitimized by the SOCE; legality comes first.

Contributions: Cash vs. In-Kind

Cash

Disclose source, amount, date received.
Deposit to the campaign bank account where feasible; keep bank proofs.

In-Kind

Record description, donor, fair market value, date received/used.
Examples: free venue, fuel, vehicles, office equipment, ad space, printing, professional services.
Discounts deeper than ordinary commercial terms: treat the discounted value provided because of candidacy as an in-kind contribution.

Third-Party Spending & Coordination

If the campaign requests, directs, or has material involvement (creative approval, targeting parameters, scheduling), treat the spending as coordinated → candidate’s contribution/expenditure.
If truly independent (no coordination), it’s not the candidate’s contribution/expenditure. Keep evidence of non-coordination to rebut challenges.

Spending Limits (Baseline, Remember Cycle-Specific Rules Apply)

President/Vice-President: typically ₱10.00 per registered voter in the constituency.
Other candidates: typically ₱3.00 per registered voter if supported by a party; ₱5.00 if independent (no party).
Political parties/party-lists: historically ₱5.00 per voter in support of their slate.

Always verify the COMELEC resolution for your election cycle—proposals to update limits circulate from time to time.

How to compute: Use the number of registered voters in the territorial jurisdiction as of the official COMELEC list for that election. Track a running ledger to avoid overshoot.

Documentation & Valuation

Obligations: Keep contracts, job orders, purchase orders, invoices, delivery receipts, acceptance reports, and proof of posting/airing (e.g., ad affidavits, screenshots, broadcast logs).
Payments: ORs, checks/bank slips, electronic payment confirmations.
In-Kind: Written donation letter/Deed of Donation, valuation basis (published rates, three comparable quotations, prior invoices), proof of use.
Digital: Platform invoices, ad manager spend reports, date-stamped performance logs.
Allocation: If an item spans pre-campaign and campaign periods (e.g., a two-month billboard), pro-rate by days or delivered units (impressions, spots) and document the method.
Books: Maintain a dedicated cash receipts and cash disbursements journal; index supporting documents to SOCE line items.

What to Put in the SOCE

Contributions received (cash and in-kind), donor details, dates, amounts/values.
Expenditures (by category), payees, dates, amounts/values, and whether incurred vs. paid.
Unpaid obligations incurred during the campaign period (list them; you may pay them after, but they still count).
No-spend campaigns must still file a “no contributions/no expenditures” SOCE.

Filing Mechanics (General)

Who files: Every candidate (including those who withdrew or were substituted), and every party/party-list through its treasurer.
When due: Generally within 30 days after election day (COMELEC may set a specific calendar date and cut-off hour).
Where: As directed by COMELEC (e.g., local field offices for local candidates; a designated office for national bets).
Form & signatures: Use the COMELEC-prescribed forms; candidate and treasurer sign; notarization typically required.
Amendments: Limited window for corrective filings may be provided by resolution (amend, don’t conceal).

Penalties & Compliance Risks

Failure to file: Administrative fines and bar from assuming office until submission; repeated non-filing can lead to stiffer sanctions, including disqualification under prevailing rules.
Material misstatements/omissions: Possible election offense exposure; may affect candidacy.
Over-spending: Separate election offense with penal and administrative consequences.
Shadow spending via “independents” or affiliates**:** If found coordinated, COMELEC can re-characterize as the candidate’s expenditure.

Common Edge Cases & How to Handle Them

Pre-campaign “advocacy” ads that look like campaign ads
- If they continue into the campaign period or are repurposed for campaign messaging, allocate the campaign-period portion to the SOCE.
Corporate donations
- Be mindful of prohibited donors (e.g., public utilities, natural resources concessionaires, government contractors). If a prohibited source gives in-kind help, refuse and document refusal; do not book it.
Crypto or novel in-kind assets
- Convert to peso value at a defensible market rate on date received; keep exchange records; disclose as in-kind.
Cross-candidate joint events
- Split costs pro-rata (by stage time, audience share, or agreed formula) and disclose each candidate’s share.
Surplus funds
- Treat per COMELEC guidance for the cycle (e.g., return to donors, donate to party/charity, or keep subject to tax rules if allowed); always document disposition.

Practical Checklist

Before campaign period
- Open campaign bank account; appoint a treasurer and compliance officer; set a document retention plan.
- Establish coordination protocols so third-party efforts don’t inadvertently become coordinated spending.
During campaign period
- Log every obligation and in-kind receipt as they happen.
- Reconcile ledgers weekly to track the spending limit.
- Keep a calendar of ad flights and inventory of posted materials with dates.
After election day
- Pay remaining obligations (where lawful); finalize valuation for in-kind; prepare the SOCE with supporting schedules; file on time.
- Retain records for the period required by law/COMELEC resolution.

Bottom Line

For SOCE purposes in the Philippines, the decisive boundary is the campaign period, not the broader election period. Count, disclose, and cap everything incurred for campaign purposes during that window, including in-kind support and obligations paid after. Treat pre-campaign and election-period-only costs carefully, allocate fairly where there’s overlap, and document everything. When in doubt, err on the side of disclosure and maintain a defensible paper trail.