
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

"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 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.
The first national roadmap, focused on basic readiness and catching up regionally.
Built around Market Access, DigitAlization, Logistics Integration and the battle cry "Basta e-Commerce, MADALI."
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.
These roadmaps sit on top of a legal and connectivity stack:
Legal validity of e-documents, e-signatures, e-contracts
Personal data protection, data subject rights, and IRR
Platform and marketplace accountability, E-Commerce Bureau, ITA IRR
Open access in data transmission, universal and affordable connectivity, DICT/NTC/PCC roles, IRR
This white paper argues that Philippine e-commerce policy and infrastructure must converge on four layers:
Broadband, cloud, and the open-access framework under Konektadong Pinoy
Digital payments, financial rails, fraud control, and consumer confidence
Physical infrastructure and services for an archipelagic country
Roadmaps + laws + enforcement for transactions, data, and platforms
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.

E-commerce market size: US$28B in 2024 → projected US$40.5B by 2027 (≈13% CAGR).
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
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%.
PH e-commerce has exploded from a few billion dollars pre-COVID to around US$20–28B now
But online is still only ~5% of total retail spend, versus ~32% in Indonesia and ~30% in South Korea, and nearly 47% in China
We're a fast-growing but under-penetrated market. The big story is that 95% of retail is still offline
"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:
Quality and affordability vary sharply by region
Many businesses sell via chat apps but lack integrated e-commerce stacks
Complex and costly shipping across 7,000+ islands
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.

"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
The Philippine E-Commerce Roadmap 2016–2020 (PECR 2016–2020) was the country's first comprehensive e-commerce roadmap. It:
The E-Commerce Philippines 2022 Roadmap built on 2016–2020 and introduced MADALI as both a slogan and a strategic focus:
It emphasized Speed, Security, and Structure as pillars:
Connectivity, digital payments, efficient logistics
Cybercrime response, consumer protection, data privacy
Institutional arrangements, e-government, harmonized initiatives
It had 20 strategies and 22 action agendas, including digital payments, MSME onboarding, and platform partnerships.
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:
Strengthening consumer protection, cyber resilience, and confidence in online transactions
Programs tailored for youth, women, PWDs, and seniors, and support for innovative business models
Tourism, creative industries, food & agribusiness, transportation, and logistics as focus sectors for e-commerce-driven growth
Expanding the international footprint of Philippine products and services and aligning with global digital trade rules
Catching Up
Basic readiness and regional alignment
Making E-Commerce Easy
Market access, digitalization, logistics integration
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.
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).
Broadband, data transmission (Konektadong Pinoy), IXPs, data centers, cloud services
Banking rails, QR Ph, e-wallets, KYC/AML, fraud controls, digital ID
Ports, roads, air/sea cargo, 3PLs, last-mile, returns/reverse logistics
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.

“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:
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.
On top of connectivity, three laws govern the what and how of digital commerce:
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.

"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.
The roadmaps and laws all converge on one reality: no trust, no e-commerce.
This means cybersecurity should be treated as core infrastructure at:
AI is now central to global e-commerce:
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.
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.
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.
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.
The Roadmap's global ambitions need alignment with PDP 2023–2028 and trade facilitation (customs, logistics corridors, digital trade rules).
Skills gaps in AI, data protection, and cybersecurity across government, platforms, and MSMEs could slow execution of "trust" and "inclusion" strategies.
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").
Align DICT/NTC coverage targets and QoS standards explicitly with DTI's sector and inclusivity targets in the 2028 roadmap.
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).
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).
Simplify customs/documentation for small-value e-commerce exports to align with the 2028 roadmap's cross-border ambitions.

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.
Provide storefront templates & workflows tailored to 2028 priority sectors (tourism packages, creative services, food products with cold-chain requirements, etc.).
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.
Use Konektadong Pinoy's open-access regime to:
Roll out community-level last-mile solutions in partnership with LGUs and cooperatives
Provide special SME connectivity packages aligned with 2028 roadmap sectors (e.g., tourism towns, food production hubs)
The Philippines now has:
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.

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.
Konektadong Pinoy and the Future of E-Commerce