Frameworks

SEC Sustainability Reporting in the Philippines

From 2026, sustainability reporting is mandatory for publicly-listed companies and qualifying large non-listed entities in the Philippines. The Securities and Exchange Commission (SEC) issued Memorandum Circular No. 16, Series of 2025, on December 22, 2025, formally adopting the Philippine Financial Reporting Standards on Sustainability Disclosures (PFRS S1 and S2) — aligned with global ISSB standards. This guide covers who must report, what is required, and how ESG reporting software like Presgo can simplify compliance.

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What is the SEC of the Philippines?

The Securities and Exchange Commission (SEC) of the Philippines is the government regulator responsible for supervising and regulating the country’s capital markets and corporate reporting framework. Among its functions is the development and enforcement of sustainability reporting guide for corporations, particularly publicly listed companies, to improve transparency on environmental, social, and governance (ESG) matters and align company disclosures with investor and stakeholder expectations.

The SEC first institutionalised sustainability reporting for Philippine-listed firms through Memorandum Circular No. 4, Series of 2019, also called the Sustainability Reporting Guidelines for Publicly-Listed Companies. In December 2025, it superseded that circular entirely with Memorandum Circular No. 16, Series of 2025, marking the shift from a voluntary “comply or explain” approach to mandatory, ISSB-aligned reporting.

What are the SEC sustainability reporting guidelines?

The SEC Sustainability Reporting Guide is a set of regulatory instructions that require covered companies to prepare and file sustainability reports that disclose non-financial performance across economic, environmental, social, and governance categories. The framework has evolved in two distinct phases:

The original guidelines issued in 2019 follow a “comply or explain” approach, allowing organisations to disclose available data and explain gaps. Currently, the SEC is revising these guidelines to adopt a more structured and standardised reporting format, including a sustainability narrative and a formal reporting template (SuRe Form) that considers global frameworks such as the IFRS S1 and IFRS S2.

MC No. 4, Series of 2019

The 2019 guidelines introduced sustainability reporting for PLCs on a comply-or-explain basis. Key features included:

•       Comply or explain approach: Companies were required to disclose available ESG data or explain why certain information was not provided, giving flexibility during early adoption.
•       Non-financial ESG disclosure: Reports covered economic, environmental, social, and governance topics relevant to the company’s operations and stakeholders.
•       Materiality-based: Companies were guided to focus on ESG issues material to their business model, risks, and long-term performance.
•       Framework alignment: Companies were encouraged to align with globally recognised standards such as GRI, SASB, and the UN SDGs.
•       SuRe Form template: A prescribed Sustainability Report Form (SuRe Form) was developed to standardise submissions via the SEC’s eFAST portal.

MC No. 16, Series of 2025

MC No. 16 introduced a fundamentally restructured reporting framework based on the four ISSB disclosure pillars, repealing the previous MC No. 4 of 2019. The implementation of the new Memorandum Circular makes sustainability reporting mandatory for PLCs and qualifying Large Non-Listed Entities, anchored in PFRS S1 and S2:

•       Governance: How boards and management oversee sustainability and climate-related risks and opportunities, including integration into remuneration and major decisions.
•       Strategy: How sustainability and climate risks and opportunities affect the company’s business model, planning, and financial position — including scenario analysis for climate resilience.
•       Risk Management: The processes used to identify, assess, prioritise, and monitor sustainability risks, and how these are integrated into enterprise-wide risk management.
•       Metrics and Targets: Quantitative data and targets tracking performance, including cross-industry metrics and industry-specific indicators under PFRS S2 (climate).

Who needs to comply with the SEC sustainability reporting guidelines?

Compliance is currently required for publicly listed companies (PLCs) in the Philippines. PLCs must submit sustainability reports attached to their annual report as mandated by the sustainability reporting guidelines.

Under MC No. 16, Series of 2025, the scope of mandatory sustainability reporting has been expanded significantly beyond the original PLC-only requirement. Two categories of entities are now covered:

• Publicly Listed Companies (PLCs) – All companies with equity securities listed on the Philippine Stock Exchange (PSE), regardless of size. PLCs must attach board-approved sustainability reports to their Annual Reports.
• Large Non-Listed Entities (LNLs) –  Entities covered under Section 17.2 of the Securities Regulation Code (RA 8799) with annual revenues exceeding PHP 15 billion (based on the immediately preceding fiscal year; consolidated for group entities). LNLs attach their sustainability report to their Annual Report or, where no Annual Report is required, alongside their audited financial statements.

Implementation follows a three-tier schedule based on market capitalisation (PLCs) and annual revenue (LNLs):

*PDEx-only issuers refers to companies with debt securities listed solely on the Philippine Dealing & Exchange Corp. (PDEx) with no equity listed on the PSE.

During transition periods, covered entities not yet at their PFRS adoption year may continue filing under any internationally recognised framework (such as GRI or SASB). Once a company reaches its designated adoption year, PFRS S1 and S2 become mandatory.

Transition Reliefs and Temporary Arrangements

Organisations covered by the SEC’s revised sustainability reporting rules may use certain transition reliefs during the initial adoption period. Depending on their tier and eligibility, entities may continue filing under alternative frameworks until their mandatory PFRS adoption year, while assurance over scopes 1 and 2 emissions is deferred until the relevant deadline.

• No prior-year comparatives in the first reporting year.
• Scope 3 emissions reporting may be deferred for two years.
• Limited assurance for scopes 1 and 2 emissions begins only after the transition period ends.

A Brief History of SEC Sustainability Reporting in the Philippines

• 2019 – Introduction of Sustainability Reporting Guidelines

• • • The SEC issued Memorandum Circular No. 4, Series of 2019, requiring PLCs to submit sustainability reports on a comply-or-explain basis alongside their annual reports. This was the first formal mandate for non-financial disclosure in Philippine capital markets, though disclosures remained flexible and voluntary in practice.

• 2023-2024 – Draft Revisions and Exposure Drafts

• • • In October 2023, the SEC released Draft Revised Sustainability Reporting Guidelines, including the SuRe Form template. These drafts aimed to align ESG reporting with IFRS S1 and S2 and expand coverage to LNLs. The SEC conducted public consultations, gathering industry input on scope, tiering, and disclosure requirements.

• July 2025 – Commission En Banc Approval

• • • The SEC Commission En Banc formally approved the adoption of PFRS S1 and S2 as the basis for the new sustainability disclosure framework. A final draft circular was published for public comment before issuance.

• December 2025 – MC No. 16, Series of 2025 Issued

• • The SEC formally issued Memorandum Circular No. 16, Series of 2025, mandating PFRS S1 and S2 adoption under a three-tier schedule beginning FY 2026. MC No. 4 (2019) was repealed. Coverage expanded to qualifying Large Non-Listed Entities, and mandatory limited assurance on scopes 1 and 2 GHG emissions was introduced.
• FY 2026 onwards – Phased Mandatory PFRS Reporting Begins
  • Tier 1 PLCs begin mandatory PFRS S1 and S2 reporting for FY 2026 (reports due 2027). Tier 2 follows in FY 2027 and Tier 3 in FY 2028. Two years after each tier’s adoption year, mandatory limited assurance on scopes 1 and 2 GHG emissions is required in line with ISSA 5000.

What is the SEC sustainability reporting template (SuRe Form)?

The Sustainability Report Form (SuRe Form) is the structured template that companies will be required to submit through the SEC’s Electronic Filing and Submission Tool (eFAST) under the revised guidelines. It consists of three major sections:

• Sustainability and Climate-related Opportunities and Risk Exposures
• Cross-Industry Standard Metrics (CISM)
• Industry-Specific Metrics (ISM)

What is the scope of SEC sustainability reporting?

The scope of sustainability reporting under the SEC’s guidelines covers:

• Economic performance, value creation, and governance disclosures
• Environmental impacts and risks, including resource use and climate-related considerations
• Social factors, such as labour practices, community engagement, and stakeholder relations
• Risk assessments and opportunities, especially relating to sustainability and climate change
• Standardised metrics under the sections detailed in the SuRe Form

The guidelines are designed to ensure that sustainability disclosures go beyond narrative description and incorporate comparable metrics, enabling consistent evaluation of corporate sustainability performance.

Why are the SEC sustainability regulations important?

The SEC sustainability reporting regulations are important because they improve market transparency, protect investors, strengthen corporate risk management, and align Philippine disclosures with international sustainability standards.

Strengthening transparency and investor confidence

The SEC sustainability reporting regulations require companies to disclose material ESG information alongside financial performance. This enables investors to better assess long-term risks, resilience, and value creation beyond traditional financial metrics, improving decision-making and market confidence.

Aligning the Philippines capital markets with global standards

By progressively aligning local sustainability disclosures with internationally recognised frameworks such as the IFRS sustainability disclosure standards, the SEC helps ensure that Philippine companies remain comparable with peers in other markets. This alignment supports cross-border investment and reduces reporting friction for companies with international stakeholders.

Improving corporate risk management and accountability

Mandatory sustainability reporting encourages companies to systematically identify, assess, and manage sustainability-related risks and opportunities, including climate-related and social risks. The reporting process promotes internal accountability, better governance oversight, and more disciplined tracking of non-financial performance.

Supporting national development and sustainability goals

The SEC regulations reinforce the private sector’s role in supporting broader national objectives, including climate resilience, inclusive growth, and responsible business conduct. Consistent sustainability disclosures help regulators and policymakers monitor progress toward national and international commitments, such as the UN’s Sustainable Development Goals.

How Presgo Supports SEC Sustainability Reporting

Presgo supports organizations in meeting the Philippine SEC’s ESG reporting requirements by providing a structured, end-to-end platform aligned with the Sustainability Reporting Guidelines and the SuRe Form. The platform helps companies collect data, assess materiality, prepare disclosures, and generate reports in a consistent and auditable manner.

Data Hub

Centralizes ESG data collection across departments such as finance, operations, HR, and compliance. This is particularly useful for SEC reporting, which requires companies to disclose quantitative and qualitative sustainability information across multiple ESG areas. Built-in data validation and audit trails support internal review and regulatory scrutiny.

Disclosure Hub

Supports the drafting and management of sustainability narratives aligned with regulatory requirements. ESG teams can map disclosures to SEC guideline sections and the SuRe Form structure, helping ensure consistency across reporting cycles while reducing manual interpretation of regulatory text.

Carbon Calculator

Facilitates the calculation and tracking of greenhouse gas emissions, supporting environmental disclosures required under the SEC sustainability guidelines. While climate disclosures are currently phased in, accurate emissions accounting positions companies for deeper climate reporting expectations over time.

Materiality Assessment

Enables structured identification and prioritization of material sustainability topics through stakeholder input and scoring workflows. This module directly supports compliance with the SuRe Form’s materiality disclosures.