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The 2026 SIPP Just Named AI, Quantum, and Biotech as Philippine Investment Priorities
President Marcos signed Memorandum Order No. 47 on 21 May 2026, approving the 2026 Strategic Investment Priority Plan, and the order took effect roughly two weeks later once it was published. This timing matters because the plan is no longer a proposal under discussion but the operating list of what the Philippine government will grant tax incentives for, and what it will not. We have covered the broader mechanics of BOI registration and tax incentives in the Philippines separately; this piece assumes that foundation and focuses on what changed this year.
If your company is sitting on capital and weighing where to put it next, this is the kind of policy moment that should change the shortlist. The 2026 SIPP just told the market, in unusually specific terms, which frontier categories the government is actively inviting in, with the longest incentive periods it offers attached. This article walks through what actually changed in the 2026 list, why Tier III is the category most worth a serious look right now, and what it takes to structure a Philippine entity so a project is genuinely ready to be registered, not just theoretically eligible.
The 2026 SIPP Does Not Automatically Apply to You
One detail in the 2026 plan matters more than any single line item on the list. Strategic Investment Priority Plan incentives do not attach to a company. They attach to a registered project or activity, and the plan is written throughout in those terms: preferred activities, investment projects, registered business enterprises, expansion projects, export projects, with that framing serving as the entire mechanism the incentive system runs on, rather than an incidental detail.
Understanding this cuts two ways in practice. A company that has operated in the Philippines for years does not retroactively become incentive-eligible just because its sector now appears on the 2026 list. An animation studio that has been running since 2018, for instance, does not see its existing revenue become tax-advantaged simply because creative content is named in the plan. What can qualify alongside that history is a genuinely new registered project: a new export-oriented business line, a significant expansion, a new facility, or a new investment commitment that BOI can evaluate and register on its own terms.
At the same time, a company does not need to be new to the Philippines to benefit from any of this. What it needs is a part of its business, existing or planned, that can be structured and registered as a qualifying investment activity in its own right. A logistics company with ten years of warehousing history finds itself in much the same position as a brand-new foreign entrant the moment it starts planning a new fulfillment center or an automated, export-oriented operation, since the company’s age has little bearing on the outcome.
What BOI is actually evaluating is the project.
This reframes the real question, which is less about whether an industry is covered and more about what part of a business, built now or planned next, can be registered as a qualifying activity. For a foreign investor with capital to deploy, that means structuring the new Philippine entity correctly from day one. For an established Philippine business eyeing a new line, it means isolating and structuring that expansion on its own terms, separate from the operations that already exist, so BOI can see a registrable project rather than a relabeled version of business as usual.
Both situations call for the same discipline, even though they start from different positions. A foreign investor entering the Philippines for the first time and an established local business eyeing a new line of activity are, in practice, answering the same question: which part of what they are building can be isolated, capitalized, and registered as its own qualifying project.
This question becomes easiest to answer in the one tier where almost no business already has a foothold to untangle from.
Tier 3 BOI Incentives Are the Most Open Door This Year
The plan keeps the three-tier structure used in prior years. Tier I covers basic needs and enabling sectors, Tier II targets supply chain gaps and import substitution, and Tier III is reserved for frontier technology, research, and innovation, which also carries the longest available incentive periods of the three.
This absence of an existing foothold is what makes Tier III worth the closest attention. Almost nobody already has an existing Philippine operation in quantum computing that a new project would need to be carved out from, and almost nobody is sitting on an established cybersecurity solutions business that the plan would simply pass over. Most Tier III entrants are building the whole entity fresh, which means the distinction between an existing company and a new one rarely complicates the analysis here the way it does for an established logistics company or animation studio.
A few of this year’s additions are worth sitting with, since they represent real expansions of what the Philippine government is now prepared to incentivize.
- Artificial intelligence and data science, spanning machine learning, deep learning, natural language processing, computer vision, and robotics, now has its own named coverage.
- Quantum technologies appear as their own line item for the first time.
- Cybersecurity is listed with real specificity, covering real-time threat mitigation, critical infrastructure protection, encryption technology, and cyber resilience strategy.
- Modern biotechnology, defined around recombinant DNA techniques and cell fusion beyond taxonomic family, opens a door for life sciences and agricultural biotech ventures that previous plans addressed only loosely.
- Hydrogen and nuclear energy both receive dedicated coverage spanning the full lifecycle, from pre-development through decommissioning.
- Geospatial analysis rounds out the list as its own support facility category, aimed at disaster risk reduction, urban planning, and environmental management.
Taken together, these additions say something worth pausing on: the government is not simply tolerating frontier technology this year, it is actively inviting it in, with incentive periods to match. A company building in any of these categories is no longer trying to argue its way into an “innovation-adjacent” bucket. The plan now names the activity directly.
A second category deserves a brief note here as well, even though it sits in Tier I rather than Tier III. Creative and knowledge-based industries, including IT-BPM, game development, animation, and software-as-a-service, remain a named priority this year, and we have written separately about BOI incentives for creative content under the CREATE Act. The same rule applies there as everywhere else in the plan: an existing studio’s sector being listed does not touch its existing revenue, and what can qualify instead is a new export-oriented line, a new facility, or a new investment commitment, structured and registered as its own activity. The tier and the typical applicant differ, but the underlying mechanism is identical.
Being on the SIPP List Doesn’t Mean Your BOI Registration Qualifies
This is the assumption that trips up more applicants than any documentation error does. A business sees its sector named in the 2026 plan and treats that as the qualifying event, when the actual qualifying event is a registered project that BOI can evaluate on its own terms. Two companies can be doing what looks, on paper, like the identical activity, and still be treated completely differently depending on how that activity has been structured, isolated, and documented.
A foreign-backed venture entering quantum research, for example, needs more than a business plan that mentions quantum computing. It needs a Philippine entity that can demonstrate it actually owns the relevant intellectual property or research output, rather than having that IP sit with an offshore parent while the local entity merely hosts staff, and it needs capital contribution structured in a way that satisfies registration requirements rather than funding that simply happens to exist somewhere in the corporate group.
The opposite starting point looks different but lands on the same principle. A Philippine logistics company that has run conventional warehousing for a decade does not see its existing revenue touched at all by fulfillment centers and digital inventory management now sitting on the priority list. What can qualify is a new, distinct project, an automated fulfillment center or an export-oriented operation, built and capitalized separately from the existing business and structured from the outset as the registrable activity it needs to be, rather than folded quietly into operations that already exist. BOI is not being asked to bless a decade of warehousing. It is being asked to register one new, clearly bounded investment.
Both examples point to the same throughline. Being on the list is necessary but not sufficient, and what actually determines the outcome is whether the project, a new company or a new line within an old one, has been isolated, capitalized, and documented as something BOI can register: a formal project registration with defined scope, investment size, and timeline, intellectual property that visibly sits with the Philippine entity, and a capital and employment structure that points toward the registered activity rather than blurring into the rest of the business.
Much of the procedural detail behind exactly how each new Tier III category will be assessed is still being worked out, and the Board of Investments is expected to issue more detailed rules and regulations specific to the 2026 plan later this year. For now, the core registration principles described here, project isolation, IP ownership, and traceable capital, are the ones already governing how applications are reviewed.
What BOI Actually Scrutinizes in an Application
In practice, this is where applications tend to succeed or stall. Reviewers are paying particularly close attention to the nature and flow of income tied to the registered activity, and to where the capital funding it actually originates. A project whose revenue cannot be clearly traced to the registered activity itself, or whose funding cannot be clearly sourced and accounted for, invites exactly the kind of scrutiny that slows an application down or sinks it outright. The incentive is tied to the project, and BOI’s review reflects that closely: it is, in effect, tracing whether the money coming in and the income going out both genuinely belong to the activity the SIPP was written to encourage, rather than to the business more broadly.
Early legal involvement tends to be what separates the applications that move smoothly from the rest. The kind of structuring a Tier III applicant needs, clean IP ownership chains, properly documented and ring-fenced capital contribution, a project registration that maps cleanly onto how the Board of Investments actually reads applications, is not something to retrofit after incorporation or after a new facility is already running informally. It is a design decision, and for most companies it is one they only get to make correctly once. Our corporate structuring and due diligence work typically begins exactly at this stage, before a registration is filed rather than after one is questioned. More detailed implementing guidelines are expected from the Board of Investments, targeted for August 2026, but the activities, tiers, and priorities the 2026 plan already names are settled and worth structuring around now.
Procurement Is Following the Same Logic
This shift is not an isolated one. The Philippines’ approach to government procurement changed in a closely related way this year, moving away from a pure lowest-price standard toward a framework that evaluates bids on overall value, much the way the 2026 investment plan now evaluates capital on strategic alignment rather than mere presence in a sector. Two different systems are converging on the same underlying expectation: documented, demonstrable preparation now counts for more than it used to, across nearly every interaction a business has with the Philippine government.
For a company with capital ready to deploy, that convergence is the opening worth acting on. The frontier categories named in this year’s plan will not stay this uncontested for long, and the businesses that structure their entry correctly now are the ones that will be standing in front of the Board of Investments with a registrable project while others are still reading the list.
If you are evaluating a new venture in artificial intelligence, quantum technology, cybersecurity, biotechnology, or another Tier III category, the structuring decisions made before filing will shape what that venture is eligible for. AJA Law works with foreign-backed and domestic ventures on project eligibility review, IP and capital structuring, and Board of Investments registration. Contact us to discuss how the 2026 SIPP applies to what you are building.
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