Read the query: is it about the person, the records or the plan?
DOLE's concerns usually fall into three groups: the designated understudy is no longer there, the training has no verifiable record, or the plan itself is vague or shows no progress. Identify which one applies before you respond. When a request for compliance or a verbal query arrives, do not simply resubmit the same documents, because the same papers will usually get the same answer.
Write down each point raised in the notice. If it was raised verbally at the counter, the person who attended should immediately record the date, the office, the questions asked and what must be supplied by when. The deadline is whatever the notice states and the counter currently requires, so calculate it on the day you receive it and plan the work backwards from that date.
Then check what the company actually holds: who was named as understudy and whether that person is still employed; what the plan said and its milestones; and what training actually took place, with any attendance, materials, assessments or handover records. Often the problem is not that no training happened, but that it was woven into daily work and never documented in a form DOLE can review.
Sort the findings into three groups: done but not documented, planned but not done, and understudy left and not replaced. Each group needs a different response, explained below. Keeping these separate also stops the company from overstating what has been achieved, which is the fastest way to lose credibility with the reviewing officer.
Keep the notice, your written record of any verbal query and your self-check together in one file, so that whoever prepares the response works from the same facts.
The understudy left: name a real replacement, not a placeholder
Understudies resign all the time. What DOLE cares about is whether the company replaced them promptly and whether the new person is genuinely learning. Choose a Filipino employee who actually works in the relevant area and can realistically take over, not whoever happens to be available to sign a form on short notice.
A replacement designation usually needs the new understudy's details and job description, why they were chosen, how they work alongside the foreign employee and the training schedule ahead. Explain truthfully when and why the previous understudy left, with separation documents, and summarise the training they received while employed so DOLE can see how far skills transfer had progressed before the change.
If no suitable person is available yet, do not force a choice. Explain that recruitment or internal selection is under way and provide the recruitment records and timetable. Whether renewal can proceed in the meantime and how long a compliance period is allowed depends on DOLE's current practice, so it is wise for someone familiar with the process to discuss it at the counter first.
Also confirm whether the new understudy must be reported on a particular form and whether the plan document needs a revised version. Requirements can differ between offices, so ask before submitting to avoid repeated returns and lost time. Keep a note of who gave the advice and when, in case a later officer takes a different view.
Brief the new understudy and the foreign employee together before the designation is submitted, so both can describe the arrangement consistently if DOLE asks them directly about their roles and the work they share.
Training happened but was not documented: assemble honest evidence
Rebuilding records means organising what genuinely happened. Never fabricate attendance sheets or assessment results after the fact; being caught with forged records is far worse than admitting gaps.
Genuine material can include handover emails between the foreign employee and the local staff member, project records they worked on together, version histories of manuals and training materials, internal meeting minutes, the dates when the local employee began handling tasks independently, and performance reviews that mention skills development. Arranged in date order with a short explanation, these show the actual progress of skills transfer in a way an officer can follow.
Ask the foreign employee and the understudy each to write a brief statement: what was learned during the period, what the understudy can now do independently and what remains. Two statements that corroborate each other are more persuasive than a single company report. Describe concrete tasks rather than general claims such as fully mastered, which an officer cannot verify.
If training paused for a while, for example during a heavy project or the understudy's long leave, say so and explain how the gap will be made up. DOLE can usually accept a delay with a reason; what is hard to accept is records that do not match reality, or a sudden burst of perfect paperwork that obviously appeared only after the query.
Before submitting, have someone who was not involved read the evidence pack and check that every date, name and task is consistent across the documents. Inconsistencies that look minor to the company can make an officer doubt the whole submission, so it is worth removing them before filing.
The plan was vague: submit one that can be executed and checked
A good training plan states what will be learned, how, how often progress is checked and how the company will judge that the skill has been acquired. A plan that only says the company will provide comprehensive training is often exactly why it was questioned.
Break the role's core responsibilities into modules. For each, state the method, such as shadowing, coaching, internal courses or external training, how progress will be checked, such as hands-on tasks, project delivery or assessments, who is responsible and the expected stage of completion. Use stages rather than rigid calendar dates, but make sure each stage can be verified by someone outside the team.
Link the plan to the foreign employee's expected tenure: how long they are expected to stay and what level the understudy should reach in that time. DOLE's perspective is protecting local employment. A plan that shows the role is ultimately meant to be taken over by local talent answers the concern better than a description of training content alone, and it gives the company a clear internal target.
After submitting the new plan, actually follow it and keep records so the same question does not come back at the next renewal. Put the checkpoints in the HR calendar and assemble the evidence at each one rather than at the last minute. A plan that is executed quietly and documented steadily is the strongest answer to any future query.
Share the final plan with the foreign employee and the understudy and ask both to confirm in writing that it reflects what they will actually do. A plan the people involved have agreed to is far more likely to be carried out.
During the correction period: can the employee keep working?
Whether the employee can keep working while the company responds depends on whether the existing AEP is still valid and on how DOLE is treating the renewal application. Follow current DOLE and Bureau of Immigration practice and do not assume that having filed is enough.
If the current AEP is still valid, the correction process generally does not affect work within that validity, but aim to finish before expiry so the renewal is not left hanging afterwards. If the AEP is about to expire or has expired without the renewal approved, the employee's status needs separate assessment; see when a PWP expires and the 9G is still pending and types of work permits in the Philippines.
Remember that the AEP and 9G are linked. When the AEP renewal stalls, the 9G renewal usually stalls too, so watch both expiry dates together and explain the situation at the counter early if needed. Leaving the 9G side until the AEP is resolved is a common way for a manageable delay to become an overstay problem.
If the renewal is denied even after correction, decide between reconsideration and a new application based on the reasons and deadlines in the decision. If DOLE considers the company to have neglected training obligations over a long period, other foreign employees' permits may also be affected, so involve a lawyer early; see an AEP revoked after a DOLE complaint. For your specific case, consult a licensed Philippine lawyer; this article is not legal advice.
Keep the employee informed in writing about where the renewal stands and what is being done, so they are not caught off guard at work or at the airport.
Preventing a repeat, and how YIXING can help
Treat understudy management as ongoing HR work, not a last-minute paperwork exercise before renewal. Update the designation when an understudy leaves, record each training milestone as it happens, and run an internal check a few months before every renewal so that gaps surface while there is still time to close them.
Companies with several foreign employees can track every understudy, training module and checkpoint in one register alongside AEP and 9G expiry dates. HR owns the register, the foreign employee and understudy sign off at each checkpoint, and the evidence is ready whenever DOLE asks. The full chain of employer duties is described in hiring foreign nationals: AEP, 9G and localisation.
Remind foreign employees too that skills transfer is part of their job, not an extra burden. If a foreign employee is unwilling to train others, the company should address it through internal management rather than covering it up in filings, because the gap will eventually show at a renewal and the company, not the employee, will carry the consequences.
YIXING can help interpret DOLE's query, organise genuine skills transfer records, draft a workable training plan and the written response, and follow the renewal through our Visa & HR service. YIXING is a privately owned consultancy registered with the SEC (CS202009551), accredited by the Bureau of Immigration (BI Accreditation No. CA-202624381-1, valid until 2027-06-30) and by DOLE. We are not affiliated with any government office and we do not promise any approval outcome.
Reviewing the register at each quarterly HR meeting keeps understudy arrangements visible to management, so problems are raised long before a renewal deadline is close.
Frequently Asked Questions
The understudy resigned. Can the AEP still be renewed?
Can we list a local employee as understudy just on paper?
Training happened but nothing was recorded. What now?
How detailed should the training plan be?
Can the employee keep working during the correction period?
What if the renewal is still denied?
Could this affect our other foreign employees?
Let’s talk through your situation — free
Every company is different. Leave your details and a Chinese-speaking advisor will get back within 1 business day with practical, industry-specific guidance and a transparent quote.
Get help with Visa & HR → Free consultation