What Records Must Philippine Employers Keep? (DOLE Requirements)

Philippine employers are legally required to keep employment records for at least three years. Article 112 of the Labor Code mandates that every employer shall keep payroll and daily time records. DOLE Department Order No. 183-17 further specifies the records that labor inspectors verify during compliance visits. Failure to maintain these records is itself a violation — and missing records allow inspectors to presume the employee's version of events is correct.

Here are the six categories of records every Philippine employer must maintain.

1. Employee Master File (201 File)

The 201 file is the comprehensive personnel record for each employee. While the term "201 file" is not explicitly defined in a single Labor Code article, it is the standard HR practice recognized by DOLE and referenced across multiple labor regulations.

What it should contain:

• Personal information (full name, address, contact details, emergency contacts)
• Government ID numbers (SSS, PhilHealth, Pag-IBIG, TIN)
• Employment contract (signed by both parties)
• Job description and appointment letter
• Pre-employment documents (resume, NBI clearance, medical certificate)
• Compensation history (salary, allowances, adjustments with effective dates)
• Performance evaluation records
• Disciplinary records (notices, show-cause memos, decisions)
• Certificates of employment issued
• Separation documents (resignation letter, clearance, final pay computation)

Retention: Maintain for the duration of employment plus at least three years after separation. Best practice is five years, as labor cases have a four-year prescriptive period under Article 305 (formerly Art. 290) of the Labor Code.

2. Daily Time Records (DTR)

Under Article 112 of the Labor Code, every employer is required to keep daily time records of all employees. This is one of the most commonly cited violations in DOLE inspections.

Requirements:

• Must show actual time in and time out for each workday
• Must reflect overtime hours, if any
• Must be signed or acknowledged by the employee
• Electronic time records (biometrics, mobile clock-in) are accepted, provided they are accurate and accessible

Retention period: At least three (3) years from the date the records were made.

Why it matters: DTRs are the primary evidence for overtime pay, holiday pay, and night differential claims. If an employee claims unpaid overtime and the employer cannot produce DTRs, DOLE and the NLRC will generally rule in the employee's favor.

3. Payroll Records

Payroll records are the second category explicitly required under Article 112. These must document every peso paid to every employee.

What payroll records must show:

• Employee name and position
• Pay period covered
• Basic pay (daily rate x days worked, or monthly salary)
• Overtime pay, holiday pay, night differential, and other premium pay
• Allowances and other earnings
• Government contribution deductions (SSS, PhilHealth, Pag-IBIG)
• Withholding tax deductions
• Other deductions (loans, cash advances — must have written employee authorization)
• Net pay
• Employee signature or acknowledgment of receipt

Retention period: At least three (3) years.

Key detail: Under Article 113 of the Labor Code, no employer shall make any deduction from wages unless authorized by law (government contributions, withholding tax) or authorized in writing by the employee (loans, union dues). Payroll records must reflect this authorization.

4. Employment Contracts

Every employee should have a written employment contract specifying:

• Position and job description
• Compensation (salary, allowances, benefits)
• Employment status (regular, probationary, project-based, fixed-term)
• Working hours and schedule
• Probationary period terms (if applicable — must specify reasonable standards for regularization, per Art. 296)
• Termination provisions

While the Labor Code does not explicitly require all employment relationships to be in writing, DOLE labor inspectors routinely ask for employment contracts during inspections. The absence of a written contract raises red flags and makes it difficult to establish the agreed terms of employment if a dispute arises.

For probationary employees: Written notice of the standards for regularization at the time of engagement is critical. Under Article 296, failure to inform the probationary employee of the standards at the start of employment may result in automatic regularization.

5. Company Rules and Policies

DOLE inspectors verify that the employer has established and communicated company rules and policies. These include:

• Code of conduct / employee handbook — Disciplinary rules, offenses and corresponding penalties, grievance procedures
• Leave policy — Company-provided leave benefits beyond the statutory minimums (service incentive leave under Art. 95)
• Workplace safety rules — Required under RA 11058 (Occupational Safety and Health Standards Act)
• Anti-sexual harassment policy — Required under RA 7877 (Anti-Sexual Harassment Act) and RA 11313 (Safe Spaces Act)
• Drug-free workplace policy — Required under RA 9165 (Comprehensive Dangerous Drugs Act) for workplaces with 10+ employees
• Solo parent leave / maternity / paternity / VAWC leave rules — Implementing rules for statutory leave benefits

Key requirement: Policies must be disseminated to employees. Having a handbook that no one has seen does not count. Best practice is to have employees sign an acknowledgment that they have received and read the policies.

6. Occupational Safety and Health (OSH) Records

Under Republic Act No. 11058 (Occupational Safety and Health Standards Act) and its implementing rules, employers must maintain:

• Safety and health program — Written workplace safety plan appropriate to the nature of the business
• Accident/illness reports — Records of all work-related injuries, illnesses, and near-misses
• Safety training records — Documentation that employees received OSH orientation and training
• Safety officer designation — Appointment of a safety officer (required for establishments with a certain number of workers, depending on industry risk classification)
• Minutes of safety committee meetings — If a safety committee is required under the implementing rules

Retention: OSH records should be maintained for at least five years per DOLE occupational safety guidelines.

Penalty for non-compliance: RA 11058 imposes fines ranging from P40,000 to P100,000 per day of non-compliance for OSH violations. Repeated violations may result in work stoppage orders.

What DOLE Inspectors Specifically Look For

During a routine labor inspection under DOLE Department Order No. 183-17 (Rules on Labor Laws Compliance System), inspectors will verify compliance with labor standards by requesting:

Record	What They Check
Payroll records	Minimum wage compliance, correct overtime/holiday pay, 13th month pay
DTRs	Actual hours worked vs. hours paid, overtime documentation
Employment contracts	Employment status, agreed compensation
SSS/PhilHealth/Pag-IBIG registration	Proof of registration and remittance
Company policies	Code of conduct, anti-sexual harassment policy, OSH program
201 files	Completeness, government ID registration

Inspectors may arrive unannounced. Under DO 183-17, they are authorized to enter any establishment during working hours and request records. Refusing access or failing to produce records is itself a violation.

How to Organize Your Records

Physical Records

• Maintain individual 201 file folders per employee, organized alphabetically or by employee number
• Store in a secure, fire-resistant cabinet with restricted access
• Separate active and separated employees (but retain separated employee files for the required period)

Digital Records

• Use an HRIS or document management system with role-based access controls
• Maintain an audit trail for all record changes (who changed what, when)
• Back up data regularly (daily for payroll, weekly for documents)
• Ensure records can be exported or printed on demand for DOLE inspections

Retention Schedule Summary

Record Type	Minimum Retention	Recommended
Payroll records	3 years (Art. 112)	5 years
Daily time records	3 years (Art. 112)	5 years
201 files	3 years after separation	5 years after separation
Employment contracts	3 years after separation	5 years after separation
OSH records	5 years (RA 11058)	5 years
Company policies	Duration of applicability	Indefinite

Related Guides

• DOLE Labor Inspection Guide for Philippine Employers — What to expect during a DOLE visit and how to prepare
• What Is the 201 File? What Philippine HR Needs to Know — Detailed 201 file checklist
• Attendance and Timekeeping Rules in the Philippines — DTR requirements and best practices
• Philippine Payroll Compliance Guide 2026 — Payroll record requirements in the broader compliance context

Legal References

• Labor Code of the Philippines (PD 442, as amended)
  • Article 112 — Keeping of Payroll and Daily Time Records (3-year retention)
  • Article 113 — Wage Deduction (written authorization required)
  • Article 95 — Service Incentive Leave
  • Article 296 — Probationary Employment
  • Article 305 — Prescriptive Period for money claims (4 years)
• DOLE Department Order No. 183-17 — Rules on Labor Laws Compliance System (labor inspection procedures and record verification)
• Republic Act No. 11058 — Occupational Safety and Health Standards Act (OSH record-keeping, penalties)
• Republic Act No. 7877 — Anti-Sexual Harassment Act (policy requirement)
• Republic Act No. 11313 — Safe Spaces Act (expanded anti-harassment requirements)
• Republic Act No. 9165 — Comprehensive Dangerous Drugs Act (drug-free workplace policy for 10+ employees)

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This guide is for informational purposes only and does not constitute legal, tax, or financial advice. While we strive for accuracy by citing official Philippine laws and government circulars, regulations change. Consult a qualified professional or the relevant government agency for advice specific to your situation.