Assessment of Additional License Fee for Late Gov't Registration

Registration to participate in government projects is required under the Revised Guidelines for Registration and Classifications and Republic Act No. 9184.
The resolution anchors its policy on the framework that government registration must remain valid to participate in government projects.
The resolution treats undertaking government projects without valid registration as conduct equivalent to undertaking construction without a valid license under the applicable fee rule.

The resolution recognizes that government registration has a three-year validity reckoned from its start.
The resolution recognizes that contractors often miss re-registration because they fail to file applications before the validity expires.
The resolution recognizes that PCAB accepts applications for re-registration three months prior to expiration.
The resolution recognizes that PCAB synchronized the expiration of government registration to coincide with the expiration of the license to assist timely re-registration.

The resolution applies to all re-registration applicants.
The resolution applies specifically when the applicant has existing projects after the expiration of the registration.
The resolution covers contractors who continue to undertake government projects even after government registration has expired.
The resolution covers situations where the contractor has not renewed the government registration after expiration.
The resolution treats the scenario as occurring notwithstanding PCAB’s acceptance of re-registration applications three months prior to expiration.

The resolution assesses an Additional License Fee for qualifying re-registration applicants.
The Additional License Fee is Php5,000 per year or a fraction thereof of non-renewal.
The resolution directs that qualifying applicants are to be assessed the Additional License Fee “similarly”—i.e., on the same basis used for undertaking construction without a valid license.
The fee is triggered by undertaking government projects after registration expiration where the registration has not been renewed.

The resolution declares that undertaking government projects without valid registration is tantamount to undertaking construction without a valid license.
The resolution imposes the consequence that such conduct is subject to the Additional License Fee of Php5,000 per year or a fraction thereof of non-renewal.
The fee consequence is tied to the period of non-renewal after expiration of registration.
The resolution operationalizes the rule by applying the assessment to re-registration applicants with existing projects after expiration.