Philippines SEC MC 16
SEC Memorandum Circular No. 16, s. 2025 — Adoption of PFRS Sustainability Disclosures (PFRS S1 and S2)
Topic : ESG disclosure · Level : National
Today
MC 16 issued 22 Dec 2025, in force 8 Jan 2026. Tier 1 PLCs (cap >PHP50bn) apply PFRS S1/S2 from FY2026, reporting in 2027.
Summary
The Philippine SEC adopted PFRS S1 and S2 (IFRS S1/S2) through MC 16 s.2025, in force since 8 Jan 2026. Listed firms with market cap above PHP50bn start in FY2026, those above PHP3bn in FY2027, others and large non-listed firms in FY2028. Scope 1-2 assurance follows after two years.
Who is concerned
- Turnover
- Large non-listed: revenue >PHP15bn
- Employees
- non précisé
- Listed company
- cotées et non cotées
- Sectors
- All sectors
- Triggering activities
- PSE listing (tier by cap at 31 Dec 2025)
- Non-listed with revenue >PHP15bn
- Extraterritorial reach
- No
non précisé
- Examples
- PSE conglomerate with cap >PHP50bn
- Philippine utility buying Chinese equipment
- Large unlisted retailer >PHP15bn revenue
What the law requires
- Prepare a sustainability report under PFRS S1 and S2 per tier
- Disclose Scope 1-2 GHG emissions; Scope 3 optional during 2-year relief
- Obtain limited assurance on Scope 1-2 two years after first application (ISSA 5000)
- Follow MC 4 s.2019 until the year before the tier starts
Penalties
PLC (as incomplete Annual Report): warning, then PHP30,000 + PHP500/day, then PHP60,000 + PHP1,000/day. LNL fines in later rules.
What this changes for a supplier in China
Limited direct effect. Chinese equipment and material suppliers to large Philippine groups may get climate data requests once Scope 3 reporting starts.
Expected evidence
- Scope 1-2 GHG data
- Product carbon footprint
- Energy mix data
Tiers : Tier 1