The Philippine securities regulator requires listed companies and large private companies to file a sustainability report based on the global IFRS S1 and S2 standards.
The largest listed companies start with their 2026 financial year and file their first report in 2027; mid-sized listed companies start with 2027, and smaller listed companies and private companies with yearly revenue above PHP 15 billion start with 2028.
Each company's board approves the report, which is filed with the company's annual report or, for private companies that file no annual report, with the annual accounts.
Supply-chain emissions (Scope 3) are required from each company's third reporting year, and an independent check of its direct emissions and emissions from purchased energy (Scope 1 and 2) starts in the same year.
| Regulator | Securities and Exchange Commission (SEC). The Financial and Sustainability Reporting Standards Council adopted the standards, approved by the Professional Regulatory Board of Accountancy |
| Standard | SEC Memorandum Circular No. 16, Series of 2025 (Sustainability Reporting Guidelines and PFRS Adoption Roadmap); PFRS S1 and PFRS S2, the Philippine adoption of IFRS S1 and IFRS S2 |
| Companies in scope | Companies listed on the Philippine Stock Exchange, companies with debt listed only on the Philippine Dealing & Exchange Corp., and non-listed companies with annual revenue above PHP 15 billion |
| Estimated population | Not yet published |
| First reporting year | Tier 1, listed companies above PHP 50 billion market capitalisation: financial years beginning on or after 1 January 2026 (reports in 2027). Tier 2, listed companies above PHP 3 billion up to PHP 50 billion: 2027. Tier 3, all other in-scope companies: 2028 |
| Scope 3 required | Yes, for all tiers, from the third reporting year: financial year 2028 (Tier 1), 2029 (Tier 2), 2030 (Tier 3) |
| Assurance | Limited assurance on Scope 1 and 2 greenhouse gas emissions two years after first adoption: financial year 2028 (Tier 1), 2029 (Tier 2), 2030 (Tier 3), under ISSA 5000. The SEC states the requirement will progress toward reasonable assurance, with no date set |
| Penalty regime | Listed companies: the SEC's penalty for an incomplete annual report, with a separate scale for late or missing sustainability reports. Large non-listed companies: Not yet published |
The Philippine Securities and Exchange Commission (SEC) made sustainability reporting under PFRS S1 and PFRS S2, the Philippine adoption of IFRS S1 and IFRS S2, compulsory through Memorandum Circular No. 16, Series of 2025, issued in December 2025 and in force since 8 January 2026. Listed companies with a market capitalisation above PHP 50 billion report first, on financial years beginning on or after 1 January 2026, followed by listed companies above PHP 3 billion from 2027, and smaller listed, debt-only listed and large non-listed companies (revenue above PHP 15 billion) from 2028.
Since the 2019 annual reports (filed in 2020), listed companies have attached a sustainability report under Memorandum Circular No. 4, Series of 2019. That circular required a reporting template, built on the Global Reporting Initiative (GRI) standards, the Integrated Reporting Framework, the Sustainability Accounting Standards Board standards and the Task Force on Climate-related Financial Disclosures recommendations, attached to the annual report, on a comply-or-explain basis for the first three years.
On 17 October 2024 the Professional Regulatory Board of Accountancy approved PFRS S1 and PFRS S2 (Resolution No. 61). On 4 December 2025 the SEC's Commission en banc adopted them, and Memorandum Circular No. 16, Series of 2025, published on 24 December 2025, set the phased roadmap and repealed the 2019 circular. Each listed company files under the 2019 template for each financial year up to and including the year before its tier starts.
Each company in scope files an annual sustainability report prepared under PFRS S1 and PFRS S2, reviewed and approved by its board of directors before issue.
PFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information): the Philippine adoption of IFRS S1. The company reports material sustainability-related risks and opportunities across governance, strategy, risk management, and metrics and targets.
PFRS S2 (Climate-related Disclosures): the Philippine adoption of IFRS S2, covering climate-related physical and transition risks, scenario analysis, and gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions.
The GHG Protocol as the measurement standard: IFRS S2 paragraph 29(a)(ii) requires emissions to be measured under the GHG Protocol Corporate Accounting and Reporting Standard (2004), unless a jurisdictional authority or exchange requires another method. The Philippine rule lets a company keep a different method for its first year only.
Filing: listed companies, and large non-listed companies that are reporting entities under the Securities Regulation Code, attach the report to their annual report. Other large non-listed companies file it with their audited financial statements.
Other frameworks: a company can add disclosures under other international frameworks, such as GRI, in the same report, provided they do not conflict with PFRS S1 and S2, keep material information clear, and name the framework used.
Transition reliefs: the SEC extended some of the standards' reliefs:
Climate-only reporting: one year for Tiers 1 and 2, two years for Tier 3.
Scope 3 omitted: two years for all tiers.
Publication after the financial statements (with the half-year interim accounts, or within nine months of year-end): one year.
No comparative information: one year.
A measurement method other than the GHG Protocol: one year.
Every listed company in the Philippines, plus the largest non-listed companies, reports under the circular, phased in three tiers by size.
Tier 1, financial years from 1 January 2026: companies listed on the Philippine Stock Exchange with a market capitalisation above PHP 50 billion.
Tier 2, financial years from 1 January 2027: listed companies with a market capitalisation above PHP 3 billion up to PHP 50 billion.
Tier 3, financial years from 1 January 2028: listed companies at or below PHP 3 billion; companies whose debt securities are listed only on the Philippine Dealing & Exchange Corp.; and large non-listed companies with annual revenue above PHP 15 billion in the preceding financial year.
Market capitalisation is measured at 31 December 2025, or at the listing date for companies listed after that. Large non-listed status is first tested on the financial year ending on or after 31 December 2027, using group revenue for a parent company. Companies below the threshold are retested in each following year. Once in a tier, a company reports every year.
Parent-company exemption: a large non-listed company can opt out if its immediate, intermediate or ultimate parent files a publicly available report under PFRS S1 and S2, or under the framework required where the parent reports (such as the EU's European Sustainability Reporting Standards), that fully includes the subsidiary's disclosures. The subsidiary attaches a Certificate of Exemption to its annual financial statements.
Supply-chain reach: every reporting company adds Scope 3 from its third reporting year. Scope 3 covers emissions in its value chain, so suppliers and logistics providers become sources of its reported data.
Note on banks: the central bank (Bangko Sentral ng Pilipinas) has published a draft circular proposing PFRS S1 and S2 disclosures for universal, commercial and listed banks, starting in 2027 for its largest tier. This page covers the SEC rule.
| Milestone | Measurement year | First reporting date |
| Memorandum Circular No. 4, Series of 2019: sustainability report template for listed companies | Financial year 2019 onward | 2020, with the annual report |
| PFRS S1 and S2 approved (Resolution No. 61) | Adopted by the SEC in December 2025 | 17 October 2024 |
| Memorandum Circular No. 16, Series of 2025, in force | Tier start dates below; early transition encouraged | 8 January 2026 |
| Tier 1: listed, above PHP 50 billion market capitalisation | Financial year 2026 | 2027 |
| Tier 2: listed, above PHP 3 billion up to PHP 50 billion | Financial year 2027 | 2028 |
| Tier 3: smaller listed, debt-only listed and large non-listed companies | Financial year 2028 | 2029 |
| Scope 3 and limited assurance on Scope 1 and 2, Tier 1 | Financial year 2028 | 2029 |
| Scope 3 and limited assurance on Scope 1 and 2, Tier 2 | Financial year 2029 | 2030 |
| Scope 3 and limited assurance on Scope 1 and 2, Tier 3 | Financial year 2030 | 2031 |
| Reasonable assurance | Not yet published | Not yet published |
The SEC will issue further rules on assurance, and guidance materials for companies.
1. Supply-chain reach across the region. Tier 1 covers the country's largest listed groups, and they add Scope 3 from financial year 2028. In our experience, buyers ask suppliers for emissions data a year or more before their first Scope 3 disclosure, so Scope 3 supplier engagement data built now serves Philippine buyers and overseas customers alike.
2. Regional convergence on the ISSB standards. The Philippines joins Singapore and Malaysia, which also base their climate reporting on the ISSB standards. In our view, a group with operations in all three can build one emissions inventory and adapt it to each regime's scope, timing and reliefs.
3. Large private companies are covered. The PHP 15 billion revenue test brings large non-listed groups into scope from financial year 2028, unless a parent's report already includes them. In our view, those groups need a corporate carbon footprint that consolidates every entity in the same way their financial statements do.
In our view, the reliefs are short, so the work starts with the first reporting year.
Establish your greenhouse gas inventory on the GHG Protocol. Measure Scope 1 and Scope 2 for every consolidated entity under the 2004 Corporate Standard. The relief for other methods lasts one year.
Map your value-chain exposure. Scope 3 enters each report in year three. Identify the categories that dominate your footprint and the suppliers who hold the data.
Build assurance-ready processes early. Limited assurance on Scope 1 and 2 starts in the same year as Scope 3. Document methodologies, emission factors and review controls during measurement, so every figure answers the assurance provider's question: where did this number come from?
Build on the frameworks you already use. The 2019 template drew on GRI, the Sustainability Accounting Standards Board and climate-risk reporting recommendations. In our experience, much of that data carries over; the new work is the investor-focused materiality lens of PFRS S1, scenario analysis and industry-based metrics.
Terrascope's AI-powered platform helps companies across APAC move from baseline emissions data to audit-ready disclosures, including Singapore-headquartered Banyan Group, which measured Scope 1, 2 and 3 emissions across 79 properties, 76 entities and more than 130,000 business activities in weeks.
Scope 1, 2, and 3 emissions measurement. Integrations pull emissions data from your source systems monthly, so your inventory stays current across every consolidated entity and Scope 3 category.
Audit-ready reporting. Audit Trail makes every figure traceable from data entry to disclosure, with assurance-provider access built in, so your assurance provider works from traceable evidence.
Supply-chain intelligence. Analytics shows where your Scope 3 hotspots sit, so you prioritise the suppliers that matter before year three.
Multi-framework alignment (Climate reporting). ISSB Reporting drafts your PFRS S1 and PFRS S2 disclosures from your measured data, reviewed by your team, ready for board approval.
Are you ready to get ahead of the Philippines' PFRS S1 and S2 requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.