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COMELEC Resolution No. 11060: Public Funds Disbursement Restrictions

Resolution No. 11060 restricts specified public spending during election periods, not all government payments. The 2026 BARMM election has revised dates and limited coverage.
From TheFinanceBase Team4 min to read
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COMELEC Resolution No. 11060 is an election-specific restriction on certain public spending—not a permanent ban on every government payment. Its original dates applied to the May 12, 2025 national and local elections and BARMM parliamentary elections. For the September 14, 2026 BARMM parliamentary election, Resolution No. 11221 applies the rules with revised dates and a limited geographic scope.

What Resolution No. 11060 restricts

Resolution No. 11060 implements Sections 261(v) and 261(w) of the Omnibus Election Code. Section 261(v) addresses public officials and employees—including barangay officials and personnel of government-owned or controlled corporations and their subsidiaries—releasing, disbursing, or spending public funds for specified social welfare and housing-related projects during the statutory pre-election period, subject to exceptions. Section 261(w) concerns issuing, using, or availing treasury warrants and similar devices that promise future delivery of money, goods, or other value chargeable against public funds. Read Resolution No. 11060.

The resolution describes social welfare and services as government aid, support, or assistance for disadvantaged, distressed, or vulnerable people or sectors. Housing-related projects are defined by reference to activities of the Department of Human Settlements and Urban Development or offices performing similar functions. Whether a particular program or transaction falls within those categories depends on its facts and the applicable issuance.

Which dates apply: 2025 or 2026?

The dates differ by election and resolution. The original version concerns the 2025 elections; Resolution No. 11221 adopts Resolution No. 11060, as amended by Resolution No. 11118, for the September 14, 2026 BARMM parliamentary election. Do not apply one election’s calendar or geographic scope to the other.

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Election context Main covered spending and treasury-warrant period Separate assistance-distribution period Geographic scope
2025 national and local elections and BARMM parliamentary elections, under Resolution No. 11060 March 28 through May 11, 2025 AICS distribution restriction: May 2 through May 12, 2025, subject to stated exceptions As set out for the 2025 election context in Resolution No. 11060
September 14, 2026 BARMM parliamentary election, under Resolution No. 11221 adopting the amended rules July 31 through September 13, 2026 A separate period applies to Ayuda, TUPAD, AKAP, AICS, and 4Ps distribution; the resolution provides limited medical and burial assistance exceptions Specified municipalities and cities in Basilan (except Isabela City), Lanao del Sur, Maguindanao del Norte, Maguindanao del Sur, Tawi-Tawi, and the Special Geographic Areas

The 2026 dates and scope come from COMELEC Resolution No. 11221. For a specific 2026 distribution, check that resolution’s exact assistance-period dates, exceptions, and any subsequent election-specific issuance; they are not interchangeable with the 2025 AICS dates.

Can an LGU release social welfare funds during the restriction?

An LGU is not automatically barred from every public expenditure, but covered social welfare or housing-related spending may be restricted during the applicable period. The answer depends on the election, geography, type of assistance or project, the provision that applies, and whether an exception or a COMELEC exemption is available. A 2025 date range should not be used to decide a transaction tied to the 2026 BARMM election.

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Calamity and disaster relief

Under the original resolution, relief or other goods distributed to people affected by calamities or disasters do not require a COMELEC exemption. The concerned agency, office, or LGU must immediately report the type of assistance, distribution date and location, amount of public funds, and a certified copy of the relevant executive order or local legislative declaration of calamity.

Routine operating expenses and salaries

The original resolution states that Routine Maintenance and Other Operating Expenses (MOOE) and government personnel salaries, including benefits mandated by law, are outside the restrictions.

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Other publicly funded programs and activities

Projects, programs, and activities outside the covered social welfare and housing-related categories may proceed under the original resolution’s conditions. These include prior establishment and reporting, compliant public information activity, and safeguards against promoting a candidate or conditioning benefits on support for a candidate.

When is a COMELEC exemption needed?

Where a project requires an exemption, Resolution No. 11060 provides a request process and filing requirements. An exemption is not automatic. The applicable election issuance controls the deadline and documentation, so applicants should verify the current rules before scheduling a release or distribution. The 2026 BARMM adaptation has its own election context; do not assume a deadline from the 2025 version carries over.

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What to check before approving or receiving a payment

  1. Identify the election and issuance. Determine whether the transaction relates to the 2025 election rules or the 2026 BARMM election rules, and check for later amendments or election-specific issuances.
  2. Confirm the date and location. Match the planned release, distribution, or instrument use to the relevant restriction period and, for the 2026 BARMM election, the listed municipalities and cities.
  3. Classify the transaction. Establish whether it is covered social welfare assistance, a housing-related project, a treasury warrant or similar device, or an expenditure outside those categories.
  4. Document any exception or exemption. For disaster relief, prepare the required immediate report and supporting calamity declaration. For a project requiring exemption, follow the applicable request procedure and deadline.
  5. Check public communications and conditions. Ensure any permitted program meets applicable reporting and public-information conditions and does not promote a candidate or condition benefits on candidate support.

The resolutions set the governing framework, but they do not determine how every individual transaction is classified. For a disputed or high-stakes payment, verify the signed applicable resolution and obtain advice from the responsible agency or qualified Philippine election-law counsel.

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