Konektadong Pinoy and the Future of E-Commerce
Aligning Connectivity, Policy, AI, and Platforms with the Philippine E-Commerce 2028 Roadmap
Author: Mack Comandante, Venture Builder – Leadership, AI Strategy & Digital Transformation for Enterprise Value; Founder - Exoasia Innovation Hub; Founding BOT - Cyber Security Council of the Philippines; Executive Director - Global AI Council Philippines
Event Context: Meet Magento Philippines 2025 – E-Commerce Infrastructure & Policy Panel
Executive Summary
"This is not just a discussion paper; it is a blueprint for execution. It successfully argues that for the digital economy to actually lift the "remaining 95%" of offline retail (MSME) in the Philippines, the government must stop celebrating the passage of laws and start obsessing over their deployment at the community level."
— Noel Africa, ICT Transformation Leader
"The Konektadong Pinoy Law marks a defining moment—a true convergence of technology, legislation, and entrepreneurial spirit for the Philippines. Drawing from my experience leading transformative digital initiatives in the Philippines, I see this not just as progress, but as a rare alignment of opportunity and readiness. With e-commerce now a US$28 billion force and connectivity reaching new heights, our collective challenge is to empower every Filipino and MSME with the tools, skills, and trust to thrive online. Real transformation will be measured not only by innovation, but by community impact and inclusive growth.
Now is the time to turn policy into daily practice, ensuring that this convergence delivers a digital future where no one is left behind—and where Filipino ingenuity shines on the global stage."
— Azhar Shaikh - SVP, Transformation, QBE Insurance
The Digital Inflection Point
The Philippines is at a digital inflection point. As of early 2024, there are around 86.98 million internet users (about 73.6% penetration), and e-commerce has grown into a US$28 billion market in 2024, projected to reach US$40.5 billion by 2027.
Digital payments now account for over half of retail transactions by volume (around 57% in 2024).
Yet, the country still faces a pronounced digital divide, fragmented logistics, and a persistent policy-implementation gap, especially for MSMEs outside Metro Manila.
Roadmap Evolution: Three Strategic Phases
01
Philippine E-Commerce Roadmap 2016–2020
The first national roadmap, focused on basic readiness and catching up regionally.
02
E-Commerce Philippines 2022 Roadmap ("MADALI")
Built around Market Access, DigitAlization, Logistics Integration and the battle cry "Basta e-Commerce, MADALI."
03
E-Commerce Philippines 2024–2028 / "Philippine E-Commerce 2028 Roadmap"
The new roadmap with 13 strategies and 28 deliverables, focused on trust, inclusivity, innovation, and cross-border expansion in priority sectors like tourism, creative industries, food & agribusiness, transportation, and logistics.
Legal and Connectivity Foundation
These roadmaps sit on top of a legal and connectivity stack:
E-Commerce Act – RA 8792
Legal validity of e-documents, e-signatures, e-contracts
Data Privacy Act – RA 10173
Personal data protection, data subject rights, and IRR
Internet Transactions Act – RA 11967
Platform and marketplace accountability, E-Commerce Bureau, ITA IRR
Konektadong Pinoy Act – RA 12234
Open access in data transmission, universal and affordable connectivity, DICT/NTC/PCC roles, IRR
Four Layers of E-Commerce Infrastructure
This white paper argues that Philippine e-commerce policy and infrastructure must converge on four layers:
Connectivity & Cloud
Broadband, cloud, and the open-access framework under Konektadong Pinoy
Payments & Trust
Digital payments, financial rails, fraud control, and consumer confidence
Logistics & Fulfillment
Physical infrastructure and services for an archipelagic country
Legal, Data & Platform Governance
Roadmaps + laws + enforcement for transactions, data, and platforms
Cross-Cutting Enablers and Risks
Across all four layers, cybersecurity and AI are emerging as cross-cutting enablers and risks, which the 2028 Roadmap implicitly leans on to build a more trusted, inclusive, and globally competitive e-commerce ecosystem.
The paper closes with concrete recommendations aligned with the 2016–2020, 2022, and 2024–2028/2028 roadmaps, focusing on turning policy into playbooks, toolkits, and technical architectures—not just more PDFs.
The Philippine E-Commerce Moment
Market and Adoption Snapshot
Market Size
E-commerce market size: US$28B in 2024 → projected US$40.5B by 2027 (≈13% CAGR).
Digital Landscape
  • 86.98M internet users (73.6% penetration)
  • 86.75M social media users (73.4% of population)
  • Digital payments: 57%+ of retail transactions in 2024
This confirms strong demand-side readiness: Filipinos are mobile-first, socially connected, and increasingly comfortable transacting online.
Despite a surge in internet adoption (over 73% penetration) and digital payments now reaching 57.4% of all retail transactions in 2024, e-commerce still only accounts for about 5–7% of total retail spend—highlighting a persistent gap between digital readiness and true online commerce. This emphasizes the need for policymakers and leaders to focus not only on digital infrastructure, but also on MSME onboarding, affordable logistics, and trust-building across regions.
— Azhar Shaikh, SVP, Transformation - QBE Insurance
E-Commerce Growth Timeline
Regional Comparison: E-Commerce Penetration
How the Philippines compares with other Asian markets (penetration snapshot):
Despite fast growth, we're still in early-penetration territory, closer to India than to Indonesia, China, or Korea. The world average is already about 4x higher than the Philippines' ~5%.
The Big Picture: Volume vs. Penetration
Volume
PH e-commerce has exploded from a few billion dollars pre-COVID to around US$20–28B now
Penetration
But online is still only ~5% of total retail spend, versus ~32% in Indonesia and ~30% in South Korea, and nearly 47% in China
Opportunity
We're a fast-growing but under-penetrated market. The big story is that 95% of retail is still offline

Key Insight: "The big story is not that Shopee/Lazada are big already, but that 95% of retail is still offline — so how do we use infrastructure, payments, cybersecurity, and logistics policy to convert that remaining 95% safely and inclusively?"
Persistent Structural Gaps
"True e-commerce transformation in the Philippines will not come from technology alone, but from our ability as leaders to forge meaningful connections between infrastructure, policy, and trust. We must harness digital platforms not simply for scale, but for real inclusion—empowering every MSME and Filipino entrepreneur to participate securely and confidently in the new economy.
The gap between rapid digital adoption and low e-commerce penetration in the Philippines highlights a critical ‘last-mile’ challenge: True transformation will depend not just on platform growth, but on tackling operational realities—integrating payment systems, logistics, and digital trust at the grassroot level. As our regional peers have shown, bridging this gap is where policy, private sector innovation, and community engagement must converge to unlock inclusive digital prosperity."
- Azhar Shaikh - SVP, Transformation, QBE Insurance
Despite the momentum, analyses from DTI, PCC, and others highlight:
1
Uneven Connectivity
Quality and affordability vary sharply by region
2
Shallow MSME Digitalization
Many businesses sell via chat apps but lack integrated e-commerce stacks
3
Logistics Fragmentation
Complex and costly shipping across 7,000+ islands
4
Low Policy Awareness
MSMEs struggle to interpret and implement RA 8792, DPA, ITA, and now Konektadong Pinoy
The roadmap trilogy (2016–2020, 2022, 2024–2028) is the government's evolving answer to these gaps.
Roadmap Evolution: From MADALI to "Exciting Commerce"
"E-commerce platforms thrive on trust, and a huge part of that trust is earned through security. Cybersecurity should be built into every stage of the development process and should never be treated as a last-minute patch. When security is part of the design, businesses protect their customers, their reputation, and their future."
— Cjay Billones, COO, Secuna
2016–2020 Roadmap: Catching Up
The Philippine E-Commerce Roadmap 2016–2020 (PECR 2016–2020) was the country's first comprehensive e-commerce roadmap. It:
  • Highlighted the role of e-commerce in economic development
  • Framed actions around APEC's "Digital Prosperity Checklist" (infrastructure, innovation, investments, information flow, intellectual capital, integration, implementation & monitoring)
  • Emphasized that the Philippines was missing out on regional opportunities and needed to catch up
2022 Roadmap: "Basta e-Commerce, MADALI"
The E-Commerce Philippines 2022 Roadmap built on 2016–2020 and introduced MADALI as both a slogan and a strategic focus:
Market Access
Digitalization
Logistics Integration
It emphasized Speed, Security, and Structure as pillars:
Speed
Connectivity, digital payments, efficient logistics
Security
Cybercrime response, consumer protection, data privacy
Structure
Institutional arrangements, e-government, harmonized initiatives
It had 20 strategies and 22 action agendas, including digital payments, MSME onboarding, and platform partnerships.
2024–2028 / 2028 Roadmap: Trust, Inclusivity, and Global Expansion
In 2024, DTI and the E-Commerce Promotion Council began crafting and then launched the E-Commerce Philippines 2024–2028 Roadmap, often branded publicly as the Philippine E-Commerce 2028 Roadmap.
Key points:
  • 13 strategies and 28 deliverables over a 4-year period (to 2028)
  • Described by DTI as a move from "easy commerce" to "exciting commerce," building on MADALI's gains
2028 Roadmap: Core Emphasis Areas
Trust and Safety
Strengthening consumer protection, cyber resilience, and confidence in online transactions
Inclusivity and Innovation
Programs tailored for youth, women, PWDs, and seniors, and support for innovative business models
Priority Sectors
Tourism, creative industries, food & agribusiness, transportation, and logistics as focus sectors for e-commerce-driven growth
Cross-Border and Global Presence
Expanding the international footprint of Philippine products and services and aligning with global digital trade rules
The Evolution: Catching Up to Exciting Commerce
1
2016–2020
Catching Up
Basic readiness and regional alignment
2
2022 MADALI
Making E-Commerce Easy
Market access, digitalization, logistics integration
3
2024–2028
Exciting Commerce
Trusted, inclusive, and globally competitive
In other words, if 2016–2020 was about catching up, and 2022 MADALI made e-commerce "easy", the 2028 Roadmap is about making Philippine e-commerce trusted, inclusive, and globally competitive.
A Four-Layer Framework for E-Commerce Infrastructure
Aligning the roadmap trilogy with the legal and connectivity stack, we can organize the ecosystem into four layers (useful for platforms like Magento and policy conversations).
Connectivity & Cloud
Broadband, data transmission (Konektadong Pinoy), IXPs, data centers, cloud services
Payments & Trust
Banking rails, QR Ph, e-wallets, KYC/AML, fraud controls, digital ID
Logistics & Fulfillment
Ports, roads, air/sea cargo, 3PLs, last-mile, returns/reverse logistics
Legal, Data & Platform Governance
Roadmaps, laws (RA 8792, RA 10173, RA 11967, RA 12234), regulators, and enforcement
The 2028 Roadmap mostly plays across Layers 2–4 (trust, inclusivity, sector programs, cross-border), while Konektadong Pinoy targets Layer 1, and the e-commerce laws formalize Layer 4.
Konektadong Pinoy Act (RA 12234): Transforming Connectivity
“The Konektadong Pinoy initiative reflects a direction that deeply resonates with the transformation blueprint I have long advocated: integrating the discipline of 4IR process evolution, the responsibility of ethical AI, and the clarity of purpose-driven digitalization. By expanding digital access and strengthening the country’s foundational infrastructure, Konektadong Pinoy moves beyond technology deployment—it enables a more inclusive, more empowered participation in the digital economy. Its vision aligns well with the idea that transformation must begin with systems that work, technologies that elevate human capability, and policies that ensure no Filipino is left behind. In many ways, it is a practical expression of how national digital strategies can serve both progress and people.
When every Filipino is digitally connected, AI can serve — and purpose can empower.”
- Engr. Gerald G. Divinagracia, MBPM (Former Undersecretary of ARTA)
The Konektadong Pinoy Act (RA 12234), formerly the Open Access in Data Transmission bill, is a landmark law that:
  • Establishes a comprehensive and inclusive data transmission and connectivity framework
  • Segments networks into international gateways, backbone, middle-mile, and last-mile, and applies open access and fair, reasonable, non-discriminatory (FRAND) access principles
  • Removes the congressional franchise requirement for Data Transmission Industry Participants (DTIPs) and replaces it with a registration/licensing regime under NTC/DICT
  • Strengthens roles of DICT (policy), NTC (regulation & spectrum), and PCC (competition), plus a Joint Congressional Oversight Committee
  • Emphasizes expansion to unserved and underserved areas, using innovative last-mile and satellite-based solutions
For e-commerce, it acts as the connectivity backbone for the 2016–2020, 2022, and 2028 roadmaps, ensuring that "exciting commerce" is not confined to NCR and a few major cities.
Legal, Data & Platform Governance: The Three Core E-Commerce Laws
On top of connectivity, three laws govern the what and how of digital commerce:
RA 8792 – Electronic Commerce Act (2000)
  • Grants legal recognition to electronic documents, messages, and signatures
  • Makes e-contracts (e.g., Magento checkout + email confirmation) legally binding
  • Enables e-government transactions
RA 10173 – Data Privacy Act (2012)
  • Protects personal data in government and private systems
  • Requires organizational, physical, and technical safeguards; establishes NPC and mandates IRR
  • Gives data subjects rights (to be informed, access, correct, object, etc.)
RA 11967 – Internet Transactions Act (ITA, 2023)
  • Applies to B2B and B2C internet transactions where one party is in the Philippines or where a platform targets the PH market
  • Creates/strengthens the E-Commerce Bureau (DTI)
  • Imposes duties on online merchants, e-marketplaces, digital platforms, and intermediaries
  • IRR via Joint Administrative Order 24-03 (2024) operationalizes these duties
The Full-Stack Policy Architecture
Together with Konektadong Pinoy (RA 12234), these laws provide a full-stack policy architecture that the 2028 Roadmap now tries to operationalize for specific sectors and inclusion goals.
Cybersecurity and AI: Cross-Cutting Enablers and Risks
"From a financial services viewpoint (both Bank and Non-Bank), there is a clear regulatory expectation in the Philippines, led by the Bangko Sentral ng Pilipinas (BSP), that all digital financial services platforms, including those facilitating e-commerce, must establish cybersecurity as a first principle:
  • The BSP's evolving IT risk and cybersecurity guidelines (Circular No. 808, and Circular No. 982) explicitly require BSP-supervised institutions to implement strong, real-time fraud management, end-to-end controls, and rapid incident response, even mandating features like multi-factor authentication and behavioral analytics as baseline, not optional add-ons.
  • Failure to prioritize security can result in financial liability for consumer loss (based on existing consumer protection regulations) and regulatory penalties.
  • Strong authentication, 24/7 fraud detection, and proactive cyber posture are no longer differentiators, they are minimum legal and reputational requirements for services to maintain digital consumer trust and to be allowed to operate.
A key point regarding the Anti-Financial Account Scamming Act (AFASA), or RA 12010, is that it adds a crucial legal requirement for both e-commerce platforms and financial service providers to proactively prevent, detect, and report online fraud and account-related scams.
AFASA supports the cyber security-by-design stance by legally obligating platforms and banks/non-banks to integrate robust fraud controls, real-time monitoring, and mandatory reporting mechanisms directly into their systems, rather than relying solely on user vigilance or reactive measures."
— Tops Laguatan, ITRMS Head, Bank of Makati Inc.
Cybersecurity as Core Infrastructure
The roadmaps and laws all converge on one reality: no trust, no e-commerce.
The 2022 MADALI roadmap names Security and trust as a core pillar
The 2028 Roadmap explicitly aims for a "safer PH e-commerce landscape" and to build trust between online customers and sellers
RA 8792, RA 10173, RA 11967, and RA 12234 all carry expectations around system security, data protection, and incident reporting
This means cybersecurity should be treated as core infrastructure at:
  • Network level – DTIPs complying with security and incident-reporting standards under Konektadong Pinoy
  • Platform level – marketplaces, PSPs, and logistics platforms embedding secure-by-design patterns
  • Merchant level – SMEs following basic cyber hygiene and using secure, updated tools
AI as Accelerator and Risk
AI is now central to global e-commerce:
Positive Side
  • Fraud/scam detection and risk scoring
  • KYC/KYB automation that supports ITA's due diligence requirements
  • Personalization, recommendation, and customer support
Risk Side
  • More convincing phishing and social engineering (multi-language, localized)
  • Potential privacy breaches if merchants plug raw customer data into unvetted AI tools, contrary to DPA/IRR
  • Bias in AI-driven scoring and access, undermining inclusivity goals in the 2028 roadmap
The 2028 Roadmap's focus on trust, inclusivity, and innovation implies that AI governance will be a key practical frontier—even if not yet spelled out in detail.
Key Gaps and Challenges (Viewed Through the 2028 Lens)
1
Digital Divide & Affordability
Konektadong Pinoy and other DICT programs have been helpful, but many communities remain unserved/underserved. Without closing this, the 2028 Roadmap's inclusivity goals risk becoming Metro-centric.
2
Sector-Specific Logistics and Compliance Hurdles
Tourism, creatives, food & agribusiness, transport, logistics all have sector-specific regulatory and fulfillment challenges (e.g., cold chain, IP, safety standards) that MSMEs struggle to navigate.
3
MSME-Friendly Implementation
The combined weight of RA 8792 + DPA + ITA + Konektadong Pinoy is heavy. Without simplification into checklists, templates, and plug-ins, the 13 strategies / 28 deliverables won't land at barangay level.
4
Cross-Border Readiness
The Roadmap's global ambitions need alignment with PDP 2023–2028 and trade facilitation (customs, logistics corridors, digital trade rules).
5
AI & Cyber Capacity
Skills gaps in AI, data protection, and cybersecurity across government, platforms, and MSMEs could slow execution of "trust" and "inclusion" strategies.
Recommendations Aligned with the 2028 Roadmap
For Government and Regulators (DTI, DICT, NTC, NPC, PCC)
01
Publish a 1–2 page "Roadmap Stack" for MSMEs
Visualize the three roadmaps + four laws + Konektadong Pinoy in one simple diagram (stack of layers). Attach MSME checklists mapped to the 13 strategies / 28 deliverables (e.g., "If you're a food MSME exporting via e-commerce, here are your top 10 tasks across connectivity, payments, logistics, data, platforms").
02
Integrate Konektadong Pinoy targets into the 2028 e-commerce agenda
Align DICT/NTC coverage targets and QoS standards explicitly with DTI's sector and inclusivity targets in the 2028 roadmap.
03
Sector playbooks for priority industries
For tourism, creatives, food & agribiz, transport, logistics, co-create sector-specific e-commerce & AI playbooks with industry groups: Typical use cases, compliance requirements, and recommended tech stacks. Sample process flows (e.g., farm-to-foreign-customer via platforms).
Government Recommendations (Continued)
01
Cyber + AI guidance
NPC and DTI should issue joint advisories on: Acceptable AI use for profiling, marketing, credit scoring under the DPA. Minimum cyber controls for SMEs and platforms (aligned with NCSP 2023–2028).
02
Cross-border facilitation
Simplify customs/documentation for small-value e-commerce exports to align with the 2028 roadmap's cross-border ambitions.
Recommendations for Platforms & Developers
Magento Ecosystem, Marketplaces, PSPs
Compliance-by-Design Modules
Build and promote PH-localized modules that implement: DPA-compliant consent, privacy notices, and data retention. ITA-aligned seller onboarding, disclosures, and complaint-handling flows.
Sector-Specific Templates
Provide storefront templates & workflows tailored to 2028 priority sectors (tourism packages, creative services, food products with cold-chain requirements, etc.).
AI & Cyber Features for SMEs
Offer AI-driven fraud detection and anomaly alerts as plug-ins. Simple security dashboards for SMEs that show patch status, 2FA usage, admin logins, etc., in plain Filipino/English.
Recommendations for Telcos, DTIPs, and Infra Providers
Use Konektadong Pinoy's open-access regime to:
Community-Level Solutions
Roll out community-level last-mile solutions in partnership with LGUs and cooperatives
Special SME Packages
Provide special SME connectivity packages aligned with 2028 roadmap sectors (e.g., tourism towns, food production hubs)
Recommendations for MSMEs and Merchant Communities
Treat connectivity, cybersecurity, and compliance as business enablers, not just cost
Join platform-led programs that interpret roadmaps into practical trainings (e.g., Magento/marketplace academies)
Use official roadmaps and laws as a language for negotiation with providers (e.g., asking ISPs about QoS standards or platforms about ITA compliance)
From Roadmaps to Playbooks
The Philippines now has:
  • Three generations of e-commerce roadmaps (2016–2020, 2022 MADALI, 2024–2028 / 2028) that evolve from catching up to making e-commerce easy to making it exciting, inclusive, and globally competitive
  • A strong legal spine – RA 8792, RA 10173, RA 11967 – setting rules for digital transactions, data, and platforms
  • A transformative connectivity framework – Konektadong Pinoy (RA 12234) – to unlock universal, affordable, high-quality internet
The Strategic Question
The strategic question is no longer "What should we do?"
but "How do we translate this stack into concrete architectures, modules, and playbooks—fast enough and simple enough—for MSMEs and citizens?"
If government, platforms, telcos, and MSMEs can align around the four-layer framework and the 2016–2020 → 2022 → 2028 roadmap arc, then e-commerce in the Philippines can evolve from being a promising niche into simply how normal commerce works—trusted, inclusive, and competitive on the global stage.
About the Author
Mack Comandante
Mack Comandante is an award-winning executive with over 20 years of cross-sector leadership experience spanning supply chain, strategy, and innovation. Renowned as a 1st Prize Exponential Organizations consultant and ambassador, he has consistently championed leading enterprise and startup transformations.
An expert in integrating data analytics, agile and sustainable value chain models, and technology, that drives robust business performance and ensures regulatory compliance. He has been recognized for excellence in consulting and implementation through measurable and sustainable business transformations.
Comandante is the Founder of Exoasia Innovation Hub. He also serves as the Executive Director for the Global AI Council Philippines and is a Founding Board of Trustee for the Cyber Security Council of the Philippines. He is an active advocate for leveraging emerging technologies and is the proponent of Founders Arena, an international competition recognizing startup initiatives in Blockchain, AI, and Cybersecurity during the Philippine Blockchain Week 2025.
He is currently enhancing his expertise in the Chief AI and Digital Officer Program at the Asian Institute of Management and holds a graduate degree from the Strategic Business Economics Program with a Certificate in Business Economics from the University of Asia and the Pacific.
Key References & Download Links
Roadmaps
  • Philippine E-Commerce Roadmap 2016–2020 (PECR 2016–2020) – DTI
    Download PDF
  • E-Commerce Philippines 2022 Roadmap ("MADALI") – DTI
    Download PDF
  • E-Commerce Philippines 2024–2028 / Philippine E-Commerce 2028 Roadmap – DTI news & context
  • DTI news: "Pascual leads e-Commerce Philippines 2024–2028 Roadmap: Pioneering a new era of trust and expansion in digital trade" Read more
    Read More
  • PIA explainer on the 4-year roadmap, 13 strategies & 28 deliverables. Read More
    R
  • WomenBizPH event note (Philippine E-Commerce 2028 Roadmap, inclusivity & sectors): Read More
Key References: Laws & IRRs
Konektadong Pinoy Act – RA 12234
Electronic Commerce Act – RA 8792
Data Privacy Act – RA 10173 & IRR
Internet Transactions Act – RA 11967 & IRR