A compliance checklist for Australian financial services firms hiring offshore staff in the Philippines
This article is a submission by Smart Outsourcing Solution, a Philippines-based Employer of Record (EOR) and remote staffing provider helping global businesses hire and manage compliant offshore teams without setting up a local entity.
- Australian financial services firms commonly hire paraplanners, mortgage processing assistants, SMSF administrators, and compliance support staff in the Philippines, but the decision involves more than cost.
- An Employer of Record lets an Australian company hire a dedicated Philippine employee without setting up a local entity, while the client retains day-to-day control over the work.
- Philippine-side compliance is only half the picture. Australian privacy obligations continue to apply once client data crosses the border, under Australian Privacy Principle 8 of the Privacy Act 1988. (OAIC)
- Financial services firms should verify local employment structure, Philippine payroll and statutory compliance, Australian cross-border data obligations, documentation and audit visibility, and how much day-to-day control they retain.
- Smart Outsourcing Solution supports Australian companies hiring dedicated Philippine employees for finance, admin, and client-facing roles through this kind of compliance-first process.
Cost is not the first question for a regulated business
Australian financial services companies have been hiring in the Philippines for years, for:
- Client services
- Paraplanning
- Mortgage processing
- SMSF administration
- Compliance support
- Back-office operations
The talent pool is deep, English proficiency is strong, and the cost advantage is real.
But a financial services firm is not evaluating an offshore hire the same way a general SME would. Client data, regulatory obligations, and audit trails are already part of daily operating life.
Offshoring a role does not pause those obligations. It extends them across a border.
This means the usual offshoring question, “how do we find someone good and keep the cost down,” needs a second layer underneath it: what do we need to verify to stay compliant once the work, and the data behind it, is being handled in the Philippines?
Common roles Australian financial services firms hire in the Philippines
- Client services officers
- Paraplanning assistants
- Financial planning admin staff
- Mortgage processing assistants
- Loan processing support
- Accounting and bookkeeping staff
- SMSF administration support
- Compliance administration support
- Operations coordinators
- Customer support staff
Most of these roles are ongoing, supervised closely, and embedded in the firm’s daily workflow and systems.
The combination of regular hours, direct reporting, and access to client data tends to make an Employer of Record a more suitable structure than an independent contractor arrangement, since the EOR provides formal local employment while the Australian company continues to direct the work.
Pro Tip: Before comparing providers, map out exactly what client data the role will touch: names, financial details, identification documents, SMSF records. This determines how carefully you need to treat the cross-border data question below, independent of which offshore role you’re hiring for.
1. Local employment structure in the Philippines
Start with the same foundation any offshore hire needs.
Ask:
- Does the provider directly employ staff in the Philippines, or subcontract employment elsewhere?
- Who signs the employment contract, and can you review a sample?
- Who manages the employee’s HR record, leave balances, and documentation?
- What is the process for resignation, termination, and final pay?
2. Philippine payroll and statutory compliance
Formal employment in the Philippines includes recurring statutory obligations. The Social Security System sets a combined 15 percent contribution rate on Monthly Salary Credit, split 10 percent employer and 5 percent employee, alongside a separate Employees’ Compensation Program contribution.
PhilHealth requires employers to remit both the employee premium and the employer’s counterpart share accurately and on time, at a 5 percent premium rate for 2024 to 2025 within the applicable salary bounds.
Rank-and-file employees who have worked at least one month are also entitled to 13th-month pay, equivalent to one-twelfth of their total basic salary earned in the calendar year, under Presidential Decree No. 851.
Ask the provider to confirm, specifically, how SSS, PhilHealth, Pag-IBIG, withholding tax, and 13th-month pay are calculated and remitted, and whether you will receive payslips and contribution records you can file for your own governance purposes.
3. What happens to client data once it crosses the border
This is the step general offshoring guides tend to skip, and it is the one that matters most for a regulated business.
Under Australian Privacy Principle 8 of the Privacy Act 1988, an Australian entity becomes accountable for any mishandled personal information disclosed to an overseas recipient, such as an offshore employee or contractor, subject to limited exceptions.
In practice, that means granting a Philippine-based employee access to your CRM, client files, or portfolio systems is generally treated as a cross-border disclosure, not something that falls outside your privacy obligations simply because the work is being done through an EOR.
The Australian Privacy Principles generally excludes organisations with less than AUD 3 million in annual turnover, though certain activities, including handling of tax file numbers and some financial services functions, can bring smaller businesses into scope regardless of size.
Questions worth raising with any EOR or offshore provider before granting system access to a Philippine-based employee:
- What confidentiality obligations are written into the employee’s contract regarding client data?
- Does the provider support device, access, and credential controls that align with your own security policy, or is that entirely on your company to manage?
- What is the process, and the notification timeline, if a data-handling incident occurs on the employee’s end?
- Can you maintain your own audit trail of who accessed what, independent of the provider’s internal systems?
None of this is a reason to avoid offshoring. It is a reason to document how you are meeting your own obligations before, not after, granting access.
4. Documentation and audit visibility
Australian financial services firms typically need clean records for internal governance and, where relevant, regulatory review. A provider should be able to give you ongoing access to:
- Employment contracts
- Payroll reports and payslips
- Statutory contribution records
- Leave records
- Onboarding and offboarding documentation
If a provider treats this as an occasional favor rather than a standard part of the service, that is worth factoring into the decision.
5. How much day-to-day control you actually keep
Many financial services firms want a dedicated employee who works inside their own systems and follows their own processes, not a shared resource inside someone else’s delivery model. Under an EOR structure, the client company should retain control over:
- Task assignment and daily priorities
- Training and process documentation
- KPIs and performance feedback
- Tools, systems, and quality standards
The EOR administers the employment relationship. It should not be making decisions about how the work itself gets done.
EOR versus BPO, for this specific use case
| Factor | Employer of Record | BPO |
|---|---|---|
| Legal employer | EOR provider | BPO provider |
| Day-to-day control | Usually retained by the client | Often managed by the provider |
| Best for | A dedicated employee embedded in your systems | An outsourced process or function |
| Data access pattern | Direct, ongoing access to your systems | Often mediated through the provider’s own workflows |
| Recruitment | Depends on provider | Usually included |
For firms wanting a dedicated paraplanner or mortgage processing assistant who works inside their own CRM and follows their own compliance procedures, EOR is generally the closer fit. BPO suits firms that want to hand off an entire function, such as a full processing queue, to a provider’s team.
Where Smart Outsourcing Solution fits
Smart Outsourcing Solution (SOS) is a Philippines-based Employer of Record and remote staffing provider that helps international companies, including Australian financial services firms, hire dedicated employees in the Philippines without setting up a local entity.
Its model supports finance, admin, and client-facing roles with documented local employment, payroll and statutory administration, and HR support, while the client retains direct control over daily work, training, and performance. Firms working through the checklist above are welcome to put the same questions to SOS directly.
FAQs
Does hiring through a Philippine EOR remove our Australian privacy obligations?
No. Australian Privacy Principle 8 continues to apply when personal information is disclosed to an overseas recipient, and the Australian entity remains accountable for how that information is handled, subject to limited exceptions.
An EOR handles Philippine-side employment and payroll; it does not replace your own privacy compliance obligations.
What roles are most commonly hired by Australian financial services firms in the Philippines?
Client services officers, paraplanning assistants, mortgage and loan processing support, SMSF administration, bookkeeping, and compliance administration are among the most common.
Should we choose EOR or BPO for a dedicated paraplanner?
EOR is generally the better fit when you want the person working inside your own systems under your direct supervision. BPO suits firms outsourcing an entire process rather than embedding one dedicated employee.
What should we ask about data security before granting system access?
Ask what confidentiality terms exist in the employment contract, whether the provider supports your own access and device controls, and what the incident notification process looks like. Final responsibility for your own privacy obligations sits with your business, not the offshore provider.
Key takeaways
- Cost is not the first filter for a regulated business offshoring client-facing or data-sensitive roles. Compliance structure comes first.
- Philippine-side due diligence covers legal employment, payroll, and statutory administration. Australian-side due diligence covers what happens to client data once it crosses the border.
- Australian Privacy Principle 8 keeps accountability with the Australian business even after personal information is disclosed to an overseas recipient. (OAIC)
- EOR is generally the better structure for a dedicated employee working inside your own systems; BPO suits handing off an entire process.
- Smart Outsourcing Solution supports Australian financial services firms through this compliance-first hiring process for dedicated Philippine employees.
Independent
