Accountability by design: How digital tools can close the procurement gap

The Philippines does not lack procurement laws. That much is certain. Republic Act 9184, enacted in 2003, established competitive public bidding, created the Government Procurement Policy Board (GPPB) and put in place the Philippine Government Electronic Procurement System (PhilGEPS) as the national procurement registry. It also carried criminal penalties for procurement violations, giving the framework real teeth against those who chose to abuse it.

On July 20, 2024, Republic Act 12009 updated that framework in several meaningful ways. It replaced the old lowest-bid-wins evaluation standard with a Most Economically Advantageous and Responsive Bid (MEARB) approach, giving procuring entities room to weigh quality and lifecycle costs, not just price. It introduced mandatory beneficial ownership disclosure, requiring all bidders to identify the natural persons who ultimately own or control them, a direct response to the shell company and affiliated-bidding arrangements that RA 9184 could not consistently catch.

However, 12009 also removed the criminal penal clauses that RA 9184 carried. While administrative and civil liabilities remain, criminal penalties for procurement-related violations are no longer provided under the law. In response, a House Bill filed in early 2026 seeks to restore these exact provisions. While the revised framework introduces significant modernization measures, its effectiveness in strengthening accountability remains a subject of debate.

Despite these reforms, the 2025 investigations into flood control infrastructure highlighted ongoing challenges in procurement oversight. These findings prompted further review by the Independent Commission for Infrastructure, established through Executive Order 94, to examine the circumstances surrounding these projects.

This highlighted a broader concern: not only the reported irregularities themselves, but also the limitations of existing oversight mechanisms in detecting them.

The problem has a name: Fragmentation

Five institutional systems govern public procurement in the Philippines. PhilGEPS holds bid advertisements and award notices. The COA holds its annual findings. The BIR holds tax clearance validity and remittance records. PCAB holds contractor license categories. The GPPB maintains the consolidated blacklist. Five systems, five agencies, five sets of records, and not one common identifier linking them together in real time.

This is the structural gap that allows irregularities to remain undetected across fragmented systems. However, the good news is that this is a solvable problem.

The CADENA Bill

Senate Bill 1506, the Citizen Access and Disclosure of Expenditures for National Accountability (CADENA) Act, passed the Philippine Senate in December 2025 with a 17-0 vote. Its counterpart House measures are still working through the legislative process, but the direction is clear.

What makes the CADENA Bill consequential is its mandate for citizen-accessible storage of procurement and budget records through a  timely, accurate, tamper-resistant, interoperable and traceable public portal. It requires government agencies to upload and regularly update budget-related documents, including contracts, project costs, bills of materials and procurement records, on a centralized digital platform.

Three tools that change what is possible

Append-only cryptographic ledgers, rule-based and AI-augmented risk analytics and integrated public transparency platforms are not cutting-edge experiments. They are proven tools already being used in government settings and are directly applicable to the structural gaps identified in recent procurement investigations.

Start with the ledger. An append-only, cryptographically chained architecture records every procurement event as a timestamped entry linked to the one before it. Any attempt to alter a past record becomes immediately detectable, making retroactive changes to milestones, awards or supporting documents significantly more difficult. The audit trail is not a separate report generated alongside the system. It is the system itself, and it is mathematically protected.

For Philippine procurement, this addresses a longstanding vulnerability. While COA can identify inconsistencies during audits, this often happens after transactions have already been completed. An append-only ledger shifts the focus from detecting alterations after the transaction has been completed to preventing them from occurring undetected in the first place.

This capability is already being demonstrated in the Philippines through the Department of Public Works and Highways Integrity Chain pilot, launched in September 2025 through a memorandum of agreement between the Blockchain Council of the Philippines and the DPWH. The platform records selected infrastructure project data on an immutable ledger accessible to the public.

The second tool is risk analytics. Rule-based and AI-augmented monitoring can significantly reduce the delay between the occurrence of an irregularity and its detection.

Artificial intelligence further enhances oversight by identifying patterns that may not trigger predefined rules. Rather than replacing auditors, AI expands their ability to detect anomalies, prioritize investigations and focus attention on higher-risk transactions.

One more thing on AI tools specifically. There is a well-documented adoption problem with risk systems in government: officials distrust outputs whose reasoning they cannot follow. The solution to this is natural-language explanation, and it is already available.

The third tool is integration. Connecting procurement, audit, tax compliance, contractor licensing and blacklisting data through a common identifier enables real-time verification across agencies.

At the citizen level, greater transparency also strengthens accountability. When contracts, project milestones, payments and other procurement records are publicly accessible through a unified platform, monitoring is no longer limited to government institutions alone.

The remaining gap is governance, not technology

This is the part that technology cannot fix on its own.

While an append-only ledger protects the integrity of what is recorded, it cannot protect against the deliberate non-recording of events that should have been entered. If a contract award is never entered into the system, the ledger has nothing to verify. In cases of collusion or intentional omission, the integrity of the ledger alone cannot prevent the gap.

Closing it requires two things. The first is data-sharing architecture among several government agencies, built around common identifiers and real-time status query protocols. None of these agencies need to surrender control of their own data. They need a formal agreement on sharing a bounded set of status indicators through a common platform. The CADENA Bill’s contemplated National Budget Transparency and Accountability Council, with DICT as technical lead, is the right vehicle for that coordination.

The second is recording accountability at the individual level. Agency-specific implementing rules, upon CADENA enactment, must establish which officer records which event, at which stage, under which personal accountability framework, with which consequences for failure.

None of this is beyond reach. The technology exists. The legal framework is taking shape. What the next phase requires is not new technology, but effective implementation, coordinated governance and accountability.

Jessie Hilario is a lawyer, the Head of the Government Bidding Group and a senior lead consultant under the Technology Consulting Group of R.G. Manabat & Co. (KPMG in the Philippines), a Philippine partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.