Short answer. No. Article 32 says an applicant with a private fee-charging employment agency may not be charged any fee until he has obtained employment through the agency's efforts or has actually commenced employment. Money demanded while you are still only an applicant is collected too early.
What the law says
Any person applying with a private fee-charging employment agency for employment assistance shall not be charged any fee until he has obtained employment through its efforts or has actually commenced employment.
Labor Code, Article 32 — Fees Charged To Workers. Read the full provision →
The trigger is the job, not the effort
The article fixes a moment before which nothing may be charged: you have obtained employment through its efforts, or you have actually commenced employment. Everything the agency does before that point — interviews, endorsements, calls to employers, the hours a recruiter says he spent on your file — is work the agency performs at its own risk. The rule does not ask whether the agency was diligent or whether it incurred costs. It asks a single factual question: has this applicant got the job yet.
Renaming the fee does not move the moment
The prohibition is on charging any fee, so the label attached to the demand is not what decides it. Processing fees, training fees, reservation or slot fees, medical and documentation charges routed through the agency, and "refundable deposits" that secure a place in a batch are all money changing hands before employment. A recruiter who is confident the charge is proper should have no difficulty telling you which allowable fee it is and issuing a receipt in the agency's name. Reluctance on either point is itself the answer.
Why the timing rule exists
Charging in advance turns applicants into the agency's revenue rather than its product. An agency paid before placement earns from the queue, and has no particular reason to shorten it; an agency paid only on placement earns from the placement. That is the incentive the article is protecting, and it is why the rule bites hardest on the recruiters who most want it not to — those advertising vacancies that never quite materialise, collecting from each new batch of hopefuls while the previous batch is still waiting for a departure date.
If you have already paid
Paying early does not put you in the wrong; the prohibition is addressed to the agency, not to you. Gather what shows the sequence: the date you paid, the date you were told you had a job, and anything establishing that the first came before the second. Receipts, deposit slips, chat threads and the dated copy of any contract all do this work. Do not hand over your only copies. If the agency refuses a receipt, the refusal itself is worth recording, because it is a separate failure under the same article.