EIS-ready headcount billing for Philippine janitorial & facilities agencies
Janitorial and facilities agencies bill per deployed worker, per site, under DOLE D.O. 174 contracting rules — and under the BIR e-invoicing mandate (deadline December 31, 2026) that client invoice must become structured, BIR-reportable data. Here is what changes, and how to issue it from the same system that runs your payroll.
Key Takeaways
- Janitorial agencies are covered because they issue client invoices from a computerized system — the CAS/software group in RR 11-2025. Only a micro agency (under ₱3M) is exempt.
- Each invoice is headcount-based per site, passing through wages and statutory costs plus the service fee, with 12% VAT and 2% EWT.
- Billing should align with DOLE D.O. 174 legitimate contracting — DOLE registration, substantial capital, and solidary liability for workers' wages.
- The RA 11917 20% admin-fee floor does not apply here — that is security-only; janitorial contracting is governed mainly by D.O. 174.
Does BIR e-invoicing apply to a janitorial agency?
Yes, in almost all cases. RR 11-2025 covers taxpayers using a Computerized Accounting System or invoicing software, and a janitorial or facilities agency issues client invoices from such a system. The ₱3M micro line is an exemption, not the coverage test — an active agency invoices above it and issues from a system, so it is covered.
See the EIS compliance guide for the full coverage groups.
How do you build a headcount-based EIS invoice?
Aggregate each worker's billable time at a site from the DTR, pass through the wage and statutory cost, add the agency service fee at the contracted rate, then compute 12% VAT and the 2% expanded withholding tax the client withholds. Issue it as structured, system-numbered invoice data that can be reported to the BIR.
How does DOLE D.O. 174 fit in?
D.O. 174 governs legitimate contracting: the contractor must be DOLE-registered, carry substantial capital, and share solidary liability with the principal for workers' wages and benefits. The EIS invoice should reflect a contract rate that genuinely covers those labor-standard costs, and the billing should reconcile to the deployment and payroll records that evidence them.
| D.O. 174 requirement | What it means for billing |
|---|---|
| DOLE registration as a contractor | Legitimate-contractor status underpins the service agreement and invoice |
| Substantial capital — ₱5M paid-up (or net worth) | Signals a genuine contractor, not labor-only contracting (D.O. 174) |
| Solidary liability for wages/benefits | The billed rate must actually cover statutory labor costs |
The shared mechanics are on EIS-ready agency-to-principal billing, and if you also deploy guards, see EIS for security agency billing.
Frequently asked questions
Yes, in nearly all cases. Under RR 11-2025 the mandate covers users of a Computerized Accounting System or invoicing software. A janitorial or facilities agency issuing client invoices from a computerized system is covered. Only a micro agency — under ₱3M in annual gross sales — is exempt.
The agency issues one structured service invoice per client per period, built from the personnel deployed to that site. It passes through wages and statutory costs, adds the agency's service fee, and computes 12% VAT and the 2% expanded withholding tax the client withholds — all as structured, reportable data.
D.O. 174 governs legitimate contracting and subcontracting: the contractor must be DOLE-registered, carry substantial capital (at least ₱5 million paid-up capital, or net worth for a sole proprietorship), and the principal and contractor share solidary liability for workers' wages and benefits. The service invoice should reflect a rate that genuinely covers those labor-standard costs, and the billing should reconcile to the deployment and payroll records that prove them.
No. The 20% minimum administrative fee is specific to private security agencies under RA 11917. Janitorial and facilities contracting is governed mainly by DOLE D.O. 174, which focuses on legitimate contracting and labor-standard compliance rather than a fixed admin-fee percentage.
No. Under RR 11-2025 a paper or static PDF invoice that cannot be electronically reported does not qualify as an electronic invoice. The agency needs structured invoice data issued from a registered system; a PDF can accompany that record as a human-readable copy.
Bill facilities work EIS-ready, from the DTR.
NexusWorkforce issues headcount-based structured invoices aligned with D.O. 174 — VAT and EWT built in, registrable as a CAS — from the same system that runs cleaner payroll and deployment.
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