This is what COA allows on the Submission of Electronic Documents and Use of Electronic and Digital Signatures on Government Transactions

The Commission on Audit (COA) accepts electronic documents in lieu of paper documents provided certain conditions as stipulated in COA Circular No. 2021-006 dated September 6, 2021 are fully complied with. Moreover, government agencies have the option to submit either electronic documents or paper documents or the combination of both.

What is an Electronic Document?

Electronic Document refers to information or the representation of information, data, figures, symbols or other modes of written expression, described or however represented, by which a right is established or an obligation extinguished, or by which a fact may be proved and affirmed, which is received, recorded, transmitted, stored, processed, retrieved or produced electronically. [Rules on Electronic Evidence, Rule 2, Section 1(h)]

The Commission considers the submission of electronic documents with electronic signature/s and digital signature/s as sufficient compliance to the requirement of submission of duly signed documents as any other duly signed paper document used in government transactions.

What is an Eletronic Signature (e-signature)?

Electronic Signature refers to any distinctive mark, characteristic and/or sound in electronic form, secured and non-secured, representing the identity of a person and attached to or logically associated with the electronic data message or electronic document or any methodology or procedures employed or adopted by a person and executed or adopted by such person with the intention of authenticating or approving an electronic data message or electronic document. [Rules on Electronic Evidence, Rule 2, Section1(j)]

The Commission expanded the above definition to mean that electronic signature will not only refer to the handwritten signatures, but also the whole process adopted in approving an electronic data message or electronic document such as the following:

• scanned image of the person’s ink signature;

• a mouse squiggle on a screen or a hand-signature created on a tablet using the person’s finger or stylus;

• a signature at the bottom of the email;

• a typed name;

• a biometric hand-signature signed on a specialized signing hardware device;

• a video signature;

• a voice signature, etc.

What is a Digital Signature?

On the other hand, Digital Signature refers to a secure type of electronic signature consisting of a transformation of an electronic document or an electronic data message using an asymmetric or public cryptosystem such that a person having the initial untransformed electronic document and the signer’s public key can accurately determine whether the transformation was created using the private key that corresponds to the signer’s public key and
whether the initial electronic document had been altered after the transformation was made. [Rules on Electronic Evidence, Rule2, Section 1(e)]

Types of Documents which can be submitted to COA in Electronic Form (Electronic Documents)

The following types of documents in their electronic form may be submitted to COA:

• Procurement-related documents (more details below);

• Disbursement Vouchers (DVs);

• Requisition and Issue Slips (RIS):

• Purchase Orders (POs);

• Contracts; and

• Memoranda, among others.

Other Government Agencies that allow the Submission of Electronic Documents; hence may also be submitted to COA

Other government agencies such as the Government Procurement Policy Board (GPPB) and the Bureau of Internal Revenue (BIR) likewise allow the submission of electronic documents such as the following, among others, viz:

Procurement-related Documents which can be Submitted in Electronic Form (Electronic Documents)

• Project Procurement Management Plan (PPMP);

•Annual Procurement Plan (APP);

• Request for Quotation (RFQ);

• Request for Proposal (RFP);

• Philippine Bidding Documents;

• Invitation to Bid (ITB);

• Request for Expression of Interest;

• Supplemental/Bid Bulletin;

• Notice of Postponement of Bid Opening;

• Notice of Eligibility or Ineligibility;

• Notice of Short Listing;

• Abstract of Quotations;

• Abstract of Bids as Read;

• Abstract of Bids as Calculated;

• Bid Evaluation Report;

• Notice to Bidder with the Lowest Calculated Bid;

• Post-Qualification Report;

• Notice of Post-disqualification;

• Notice of Award (NOA);

• Approval of Higher Authority;

• Notice to Proceed (NTP);

• Reply to Motion for Reconsideration and Protest;

• Bids and Awards Committee (BAC Resolutions;

• Blacklisting Order;

• Procurement Monitoring Report (PMR);

• Agency Procurement Compliance and Performance Indicators.

The above procurement-related documents were allowed to be submitted in electronic form through GPPB Resolution No. 16-2019 approved on July 17, 2019.

BIR Forms which can be Submitted in Electronic Form (Electronic Documents)

• BIR Form 2304 — Certificate of Income Payment Not Subject to Withholding Tax (excluding Compensation Income)

• BIR Form 2306 — Certificate of Final Tax Withheld at Source

• BIR Form 2307 — Certificate of Creditable Tax Withheld at Source

• BIR Form 2316 — Certificate of Compensation Payment/Tax Withheld

The Bureau of Internal Revenue allows the submission of the above BIR Forms in electronic form through BIR Revenue Memorandum Circular No. 29-2021.

Conditions/Guidelines on the Submission of Electronic Documents to COA

If a government agency so decide to submit electronic documents to the Commission on Audit, it shall ensure the following:

• Issue internal rules in the adoption of
the same, including sanction for unauthorized and illegal use of digital certificates or electronic signatures, subject to existing laws and regulations such as the Cybercrime Prevention Act of 2012, as well as to rules of the Department of Information and Communications Technology (DICT);

• Submit a Management Representation or Policy Statement on the use of signature on electronic documents in their operations to their respective Auditors, together with the approved internal rules using prescribed template — Annex A of COA Circular No. 2021-006;

• Employees/officials authorized to sign the subject documents using digital signature shall secure/apply individual certificates with the DICT as the Government Certificate Authority (CA) through its PNPKI service or they may apply for their individual certificates from any other CA-accredited or recognized by the Department of Trade and Industry – Philippine Accreditation Bureau (DTI-PAB) to issue digital certificates to be used in government transactions, pursuant to Executive Order No. 810, s. 2009;

• Inform COA Auditors, in case of revocation or expiration (without renewal) of the digital certificate or if said digital certificate has been compromised;

• Shall maintain in its original form the digitally-signed documents which were submitted electronically to the Commission with notations that the original copy of said documents were submitted in digital format;

• The digital signature shall be in human-readable form such that the full name of the signatory and an image of the signatory’s handwritten signature appear in the electronic document; and

• Ensure that the electronic documents after they have been signed will not be altered.

Guidelines on the submission of Electronic Documents Using Electronic Signature

If the government agency decides to submit electronic documents using electronic signature, the said documents may still be accepted by the Commission on Audit provided the agency is able to establish that:

• the electronic signature is that of the person to whom it correlates;

• the electronic signature was affixed by that person with the intention of authenticating or approving the electronic document to which it is related or to indicate such person’s consent to the transaction embodied therein;

• the methods or processes utilized to affix or verify the electronic signature, if any, operated without error or fault; and

• the person whose e-signature was affixed, takes responsibility and assumed accountability that the document remained unchanged until it was submitted to the auditor.

Preferred Format of Electronic Documents to be Submitted to COA

While government agencies may use any format of electronic documents the Commission on Audit prefers the following formats: Portable Document Format (pdf), Microsoft Excel Document (xlsx) or a combination of both. The Commission emphasized however that when using any format, ensure that the electronic and or digital signatures are secured.

To learn more about the Guidelines on the use of Electronic Documents, Electronic Signatures, and Digital Signatures in Government Transactions, download COA Circular No. 2021-006 here.

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