Sourcing offshore accounting candidates usually starts at a job description and ends at an interview. The step that decides how much of that effort is wasted sits in front of both, and it is a question about the other side of the table. Who was lawfully allowed to go and find this person, in the country where that person actually sits? Four routes lead a name to your inbox, and each one puts the finding, the screening and the paperwork in different hands. Sort out which route you are on and you know which document to ask for, before anyone books a call.
How to Source Offshore Accounting Candidates: The Four Routes
A candidate reaches you along one of four routes, and the route is usually visible in the first email.
| Route | Who finds the candidate | Who screens first | What you can ask to see |
|---|---|---|---|
| The provider's existing bench | The provider, before your seat existed | The provider, against its own standard | The employment record for that named person |
| An in-country recruitment agency | The agency, against your spec | The agency, to a statutory minimum | The local recruitment license and the office that issued it |
| Your own posting, an employer of record behind it | You | You | Not a recruitment license. The entity that is the legal employer, and the registration it employs under |
| Your own overseas entity | You | You | Your own entity's registrations |
The Provider's Existing Bench
Nobody recruited this person for you. They were hired for the provider's own bench, trained on the provider's account, and moved onto your seat when you signed. Nobody ran a search against your spec, so a recruitment license is not the document that describes this route, and asking for one produces a confused answer that reads like evasion.
What is in play is the employment relationship behind the person. Ask whether the accountant is the provider's own permanent employee or labour supplied into somebody else's establishment, because those two answers point at different paperwork, and the Indian version of that split is set out in the employer of record India guide. The screening on this route has already happened, scored against the provider's own rubric rather than yours, so a bench candidate still gets your own work sample the way accounting candidate assessment describes, and what the provider's write-up of that screening is actually worth is worked through in how to interview offshore accountants.
An In-Country Recruitment Agency
This is the only route where a third party goes out and finds a specific human being for your specific seat. On this route the recruitment license is the document that describes what actually happened, which makes it the easiest of the four to verify.
The agency's job here is narrow, and worth naming. It advertises, collects applicants, runs a first pass, and hands you a shortlist. It does not employ the person on your behalf unless you have separately arranged that, so the license answers who may recruit, not who pays the salary.
Your Own Posting, With an Employer of Record Behind It
You write the ad, you run the search, you interview, and an employer of record, the local company that becomes the legal employer while the person works to your direction, signs the employment contract at the end. Sourcing on this route is yours by default, and the employer of record split between who employs and who stays responsible has its own guide.
The trap is quiet. If the provider offers to "help with the search" and starts sending you profiles, it has stopped being only your employer of record and started doing recruitment, which in some countries is a licensed activity in its own right. Ask, in writing, which entity ran the sourcing and under which registration, and get the answer before profiles start arriving rather than after.
Your Own Overseas Entity
With your own company in-country there is no third party to license, because you are recruiting your own staff for your own payroll. The questions move inward, to your entity's registrations and to the local employment law it now sits under, and that is a conversation for local counsel before the first offer letter rather than after the first dispute. The rest of what changes when the seat crosses the border is covered in the offshore hiring guide.
What Counts as Recruitment, and Who Needs a License to Do It
In the Philippines the definition is wider than the word suggests, and it is written into the Labor Code itself. Recruitment and placement refers to any act of canvassing, enlisting, contracting, transporting, utilizing, hiring or procuring workers, and it includes referrals, contract services, promising or advertising for employment, locally or abroad, whether for profit or not, with a proviso that anyone who in any manner offers or promises employment for a fee to two or more persons is deemed engaged in it, under Article 13(b) of the Labor Code of the Philippines. Read that list again. A referral is in it.
The rules that govern doing this inside the country are the revised rules on recruitment and placement for local employment, Department Order 141-14. Under its definitions, a private employment agency is any person, partnership or corporation engaged in the recruitment and placement of workers for local employment, and a license is the document issued by the Secretary of Labor and Employment through the Regional Director authorizing that operation. An authority to recruit is a separate document, issued to a named person to conduct recruitment activities on the agency's behalf.
Three details from those rules turn the license into something you can actually check. It runs for three years from issuance unless revoked or cancelled sooner, under Section 12. The original has to be displayed conspicuously and permanently inside the agency's office, under Section 14, so a video call pointed at the wall is a fair request. And an authority to recruit is valid nationwide, under Section 19, so an agency working outside its own region is not by itself a red flag (Department Order 141-14).
The consequence of having no license is not a paperwork problem. Illegal recruitment means any act of canvassing, enlisting, contracting, utilizing, hiring or procuring workers, including referrals and contract services, promising or advertising for local employment, whether for profit or not, when it is undertaken by a non-licensee or non-holder of authority, under Section 42 of the same rules. If the shortlist reached you through someone with no document, the exposure sits with them, and the disruption sits with you.
Licenses That Do Not Stack
Here is the part that catches out buyers who assume one good vendor can do everything. Sole proprietors, partnerships or corporations licensed to engage in private recruitment and placement for local employment are prohibited from engaging in job contracting or subcontracting activities, under Section 5 of Department Order 141-14. The recruitment license and the delivery-pod business are on opposite sides of a line the rules draw deliberately.
So a Philippine company that recruits to your spec and a Philippine company that supplies you a managed accounting team are answering to different regimes, and the second one is where the contracting analysis lives, including the labor-only test set out in employer of record versus independent contractor. A vendor claiming to be both should be asked to name the document behind each activity. The answer may be that a group holds two companies, one for each, which is a fine answer. You will only see it if you ask.
There is a second stacking error, and the rules close it in one line. An agency duly licensed to recruit and place workers for overseas employment, and intending to engage in local recruitment and placement, must apply for a separate license (Department Order 141-14). An overseas deployment license, waved on a sales call, is not evidence of the thing you are buying.
The Overseas Rules Are Probably Not Your Rules
A Filipino accountant working from Manila for your firm has not left the country, and the Labor Code's own definition turns on exactly that. Overseas employment means employment of a worker outside the Philippines, under Article 13(h) of the Labor Code.
That definition carries the point through to the rule buyers are most often warned about. No employer may hire a Filipino worker for overseas employment except through the Boards and entities authorized by the Secretary of Labor, under Article 18 of the Labor Code, which is the ban on direct hiring. The same article exempts direct hiring by members of the diplomatic corps, international organizations and such other employers as the Secretary of Labor may allow, so the ban is not absolute even on its own terms.
On the Labor Code's own definitions the ban is about deployment abroad, so it does not describe a person who stays at a desk in Cebu, and the license that matters for your seat is the local one. Put your intended structure in front of Philippine counsel before you rely on that reading, because how the seat is papered can move the analysis.
What the License Proves, and What It Plainly Does Not
A license tells you the agency may lawfully recruit. It does not tell you the agency can judge an accountant, and the rules make the gap visible rather than hiding it.
The screening a licensed agency must run is a documents-and-interview floor. It requires a bio data or comprehensive resume, a birth certificate, an original medical certificate and an original barangay clearance from the applicant, the barangay being the smallest unit of local government where that applicant lives, then an interview after evaluating those documents to explain the recruitment contract and determine whether the applicant is fit, capable and willing to work, under Section 40 of Department Order 141-14. Identity, health, willingness. Nothing in that list is a fixed-asset rollforward or a Schedule C.
The rest of that section is paperwork filed with government offices rather than screening, and one line of it is something else you can ask to see. Before recruiting in a given place, the agency has to present a copy of its valid license, its authority to recruit and a notarized job order to the Public Employment Service Office and the Barangay Office covering that place, under the same Section 40 of the revised rules.
One more line from these rules doubles as a character test on the agency. No fees whatsoever shall be collected, neither deducted from the salaries or wages of the workers, and the only two charges an agency may make are a service fee agreed with the employer and the cost of moving the worker from home to the place of work, both billed to the employer and in no case deducted from the worker's salary (Department Order 141-14, Section 35). The agency swears to that before it holds a license at all, because its application must carry an affidavit of undertaking that it will not collect any fees whatsoever from the job applicants, under Section 6 (Department Order 141-14).
So a transportation line on the invoice to you is a lawful charge, and money collected from the candidate is not. Ask a shortlisted candidate, privately, whether they paid anything to reach the interview. The answer tells you more about the agency than its brochure will.
India Asks a Different Question
India does not put a general recruitment license in front of the same transaction. The document that can exist there is the contract labour license, it applies only at or above a headcount threshold, and on the statutory definitions behind it the chain of who is liable to whom runs between two Indian parties rather than reaching your firm. That analysis, with the sections behind it, is already laid out in the employer of record India guide, so the question to carry into an Indian conversation is the one it ends on: are these people your own employees, or contract labour supplied into an establishment.
Confirm the Person Before the Vendor Summary Arrives
Every route above ends with a name on a profile written by someone who wants you to say yes. The Philippines and India each publish a register that lets you get underneath that, and the two work differently enough that the difference is worth planning around.
The Philippine one is open. The Professional Regulation Commission runs an online verification service that confirms the identities of registered professionals, and it offers verification of a license by name, with the profession and the first and last name, as well as by license number with a birthdate. Its own disclaimer is worth reading with it: the Commission believes the information to be reliable, but human or mechanical error remains possible, as does delay in posting or updating. Treat a hit as confirmation and a miss as a question, not as proof of fraud.
The Indian one runs on a number, not a name. The Institute of Chartered Accountants of India publishes a members database as at a stated date, searchable by membership number. That order of operations matters when you plan the check, because you cannot start from a shortlist of names. Ask each candidate for their membership number in the same message that asks for their CV, and the verification takes a minute instead of a week.
Neither register tells you what the credential permits, which is a separate question with its own traps, and hiring offshore CPAs works through what those letters can and cannot mean on an offshore resume.
When This Is the Wrong Thing to Be Checking
If what your firm actually needs is reviewed output rather than a named person in a seat, most of the above is diligence pointed at the wrong risk. Buying a delivery team means the licensing question narrows to the contracting side, and the thing that protects your signature is the review chain, not the recruiter. The sourcing questions earn their keep when an individual joins your workflow, carries your logins, and appears on your capacity plan, which is the situation how to build an offshore accounting team is written for.
The same is true when you are early. If you have not decided which seat you are filling, no register will tell you, and a shortlist arriving before that decision is a distraction dressed as progress.
Ask Who Found Them, Then Ask for the Document
Sourcing offshore accounting candidates well is mostly a matter of sequence. Establish the route first, because it names the party you are relying on. Ask that party for the document its route actually requires.
From an agency it is a recruitment license. From an employer of record it is the name of the entity that will legally employ the person and the registration it employs under. From a provider filling your seat off its own bench it is the employment record for that named person. Then check the person yourself in the register at source, before the summary arrives and starts doing your thinking for you.
If capacity is what is driving the search, the fastest way to learn whether any of this will hold is to test the work rather than the paperwork. Accountably places trained offshore accountants and tax preparers inside US CPA and EA firms from our own offices in India, ramped on your software and SOPs in about 3 to 4 weeks, with a layered review chain standing in front of your signature. Since 2022 that has meant 20+ US firms and 30+ placements. Don't trust us. Test us. Run a Free 40-Hour Proof Pilot on a fixed block of your own representative work, graded by your own reviewer, and if a placement is not the right fit in the first 30 days we replace them free.