An Act Appropriating Funds for the Operation of the Bangsamoro Government from January One to December Thirty-One, Two Thousand and Twenty-Two and for Other Purposes

This is the region's budget for 2022 — ₱79,862,015,000.00 — and the first one to say out loud that part of it is money the government already had and did not spend.

Section 1 draws on the annual block grant, other subsidies from the National Government, the region's share of national taxes collected inside its territory, projected collections on its own taxes and fees, and “unused/unutilized appropriations from the Bangsamoro Treasury”. That last phrase is new, and every budget after this one keeps a version of it.

The government has grown. There are now 11 other executive offices funded alongside the 17 ministries, up from 6 the year before — the Sports Commission, the Pilgrimage Authority, the Commission for the Preservation of Cultural Heritage, the Cooperatives and Social Enterprise Authority and the Development Academy of the Bangsamoro all appear for the first time. So do two special purpose funds that matter to anyone outside the bureaucracy: a Special Development Fund of ₱5,000,000,000 for conflict-affected communities, and a Local Government Support Fund of ₱1,394,016,000.

The Bangsamoro Transition Authority receives ₱3,558,163,162, about 4.5% of the total.

The last 19 pages carry 71 sections of general provisions. Personnel Services across government may not exceed 45% of total revenue. At least 5% of every ministry's budget must go to a Gender and Development Plan. Deductions may never reduce an employee's monthly net take-home pay below ₱5,000. Rainwater collection systems are required in public markets, schools and government buildings — and may never be built on private lots. Infrastructure contracts, winning bidders and final costs must be published within 30 days, and officials who miss their quarterly reports have their salaries suspended automatically.

One provision is entirely new. Section 27 directs every ministry and office to work toward “the full integration and mainstreaming of Islamic or Shari'ah compliant finance within their services and activities”, and tells the Chief Minister to issue guidelines and stand up a body to check that products and services actually comply. It has appeared in every Bangsamoro budget since.

The Bangsamoro Government needs an annual appropriations act to function. This was the last budget of the first Bangsamoro Transition Authority, whose term the National Government had extended to 2025, and it was passed and signed on the same day — 28 December 2021 — 3 days before it took effect.

The phrase to notice in Section 1 is “unused/unutilized appropriations from the Bangsamoro Treasury”. Until this act, the region's budgets were funded from money it expected to receive. From here on they are funded partly from money it already received and did not manage to spend. The wording broadens again in FY 2023 to “unutilized prior years' appropriations”, and again in FY 2024 to add “unutilized prior year's allotments reverted to the Bangsamoro Treasury”. Read alongside the extension acts — BAA 14, BAA 24, BAA 33, BAA 52, each of which pushed an expiring budget's validity out by a year — and alongside the supplemental acts of 2024, 2025 and 2026, which re-appropriate ₱36.57 billion of previously unspent money between them, the pattern is consistent: the Bangsamoro Government has been appropriating faster than it can disburse for its entire existence, and its budget laws have gradually been rewritten to make that legal rather than exceptional.

Section 48 shows the same thing in miniature. Everything in this act expires on 31 December 2022 — except the constituent LGUs' share of income taxes, which gets until 31 December 2023. It is the first time a Bangsamoro budget carves out a class of money that outlives the rest, and the carve-out grows each year afterward until, in FY 2025, the LGU share stops lapsing altogether.

Section 49 is worth reading twice. It is headed “Retention or Deduction of Funds” and consists of a single sentence saying that fund releases shall be transmitted to the ministry concerned. The FY 2020 and FY 2021 acts headed the same section “Prohibition Against Retention or Deduction of Funds”, with the same single sentence and no actual prohibition; here even the word “Prohibition” is dropped. A sentence forbidding retention or deduction as reserves or overhead does not appear in any Bangsamoro budget until FY 2025.

The Contingent Fund keeps its familiar contents — ₱2.4 billion earmarked for a Transitional Development Impact Fund, money for COVID-19 vaccines and protective gear, and once again a “provision for cost of acquisition of Al-Amanah Islamic Bank and other related costs”, the third consecutive budget to make room for that purchase. Section 27, mainstreaming Islamic finance across the whole government, arrives in the same act. The two sit oddly together: an ambitious policy direction in the general provisions, and a line in a contingency fund for a bank the government has been trying to buy since 2020.