Meta description: Philippine LNLs are now covered under SEC MC No. 10, s. 2022. Learn what’s required for sustainability reporting and how GCSS, Inc. helps you comply.

Updated October 6, 2025

The Securities and Exchange Commission (SEC) Memorandum Circular No. 10, s. 2022 marked a turning point for sustainability reporting in the Philippines. Originally, sustainability reporting was mandatory only for Publicly Listed Companies (PLCs) under SEC MC No. 4, s. 2019. But now, with MC 10, the scope has expanded to include Large Non-Listed Companies (LNLs)—an important recognition of their economic footprint and role in driving sustainable development.

For Philippine LNLs, this means that sustainability reporting is no longer a question of if, but how fast and how well they can comply.

What does SEC MC No. 10, s. 2022 Require? 

Here are the key provisions companies need to understand:

1. Expanded Coverage – Large Non-Listed Companies (those meeting thresholds on assets, revenue, or workforce size) are now encouraged to submit sustainability reports. While initially “comply or explain,” the SEC is signaling a shift toward mandatory ESG disclosure
2. Alignment with Global Frameworks – Reports must follow recognized frameworks such as GRI Standards, IFRS S1 and S2, and the Task Force on Climate-related Financial Disclosures (TCFD)
3. Template for Reporting – The SEC provides a Sustainability Reporting Template (SRT) designed to harmonize disclosures across companies. This ensures comparability for investors, regulators, and other stakeholders
4. Integration with Corporate Governance – ESG oversight must be embedded at the board level, linking sustainability to accountability and strategy
5. Assurance and Transparency – Companies are encouraged to pursue third-party assurance to strengthen credibility and reliability of ESG data.

Why Does This Matter for LNLs?

Unlike PLCs, LNLs may not yet be under constant investor scrutiny. But the pressure is rising from regulators, banks, and even customers. Here’s why MC No. 10 matters for large unlisted firms:

• Access to Finance – Banks and investors increasingly require ESG-aligned disclosures to assess risk. Without a sustainability report, LNLs could face higher capital costs or lose access to green financing
• Regulatory Preparedness – As ESG reporting becomes mandatory, those that start early will avoid last-minute compliance headaches
• Risk Management – From climate change impacts like typhoons to supply chain disruptions, LNLs must disclose how they plan to build resilience
• Competitive Advantage – Strong ESG disclosures build trust with clients, partners, and employees—helping attract business opportunities

Future-proof your ESG reporting and prepare your company for regulatory convergence with global standards.
Talk to GCSS, Inc. 

How Consultants Can Help LNLs Comply with MC 10

Meeting the SEC’s requirements can be daunting without expertise. A trusted sustainability consultant like GCSS, Inc. helps by:

• Conducting Materiality Assessments – Identifying ESG issues that are most relevant to your company and stakeholders
• Disclosure Mapping – Aligning SEC templates with IFRS, TCFD, and GRI frameworks
• Strengthening Governance – Training boards and executives to embed ESG oversight into decision-making
• Data System Design – Building robust data collection, monitoring, and assurance-ready systems
• Report Preparation and Assurance Support – Producing investor-grade sustainability reports that stand up to scrutiny

Don’t risk missteps. Ensure your report is both compliant and credible.
Work with GCSS, Inc. 

The GCSS, Inc. Advantage

As a member of the Philippine Chamber of Commerce and Industry (PCCI), GCSS, Inc. is uniquely positioned to bridge the gap between regulatory requirements, global standards, and practical business realities.

We’ve worked with publicly listed companies, large non-listed firms, and industry leaders across sectors, helping them transform sustainability reporting from a compliance requirement into a driver of investor trust and long-term growth.

Compliance is Just the Beginning

SEC MC No. 10, s. 2022 is more than a regulatory update—it’s a wake-up call for LNLs to integrate sustainability into governance, strategy, and disclosure.

Those that delay will face risks. Those that act now will gain credibility, investor confidence, and competitive edge.

Reach out at sales@gcssinc.com to begin your IFRS- and TCFD-aligned ESG journey. Book your discovery call here and talk to our experts today.

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Start your sustainability reporting now—and turn compliance into opportunity.

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