Meta description: Philippine Large Non-Listed Companies must now publish sustainability reports. Learn why LNLs can’t delay ESG reporting and how GCSS, Inc. can help.

Updated October 6, 2025

For years, sustainability reporting in the Philippines was largely associated with publicly listed companies (PLCs). But with the Securities and Exchange Commission (SEC) issuing Memorandum Circular No. 10, s. 2022, the rules of the game have changed. Large Non-Listed Companies (LNLs) are now strongly encouraged—and soon expected—to publish their sustainability reports alongside their annual financial disclosures.

This shift signals a broader recognition: sustainability, ESG reporting, and corporate governance are no longer just compliance matters—they’re strategic imperatives that affect access to capital, investor trust, and long-term resilience.

Why is the SEC Pushing LNLs to Report?

The SEC Memorandum Circular No. 10, s. 2022 builds on MC No. 4, s. 2019, which first required PLCs to disclose sustainability reports. Now, the focus extends to large unlisted companies, defined as firms meeting the threshold in assets, revenues, or employee size.

By expanding reporting obligations, the SEC is:

• Aligning with global standards such as IFRS S1, IFRS S2, and TCFD
• Ensuring that non-listed but influential companies are transparent about their climate action, ESG risks, and net zero commitments
• Preparing Philippine businesses for green financing and sustainable investment opportunities that require credible disclosures

   

Confused about which framework to follow—GRI, IFRS, or TCFD?
See how GCSS, Inc. helps companies map disclosures against multiple standards.

The Risks of Delaying Sustainability Reporting

Some LNLs may see sustainability reporting as optional or a “nice-to-have.” But in 2025, delaying ESG disclosures can be costly:

1. Regulatory Risk – Failure to comply with SEC requirements may result in penalties and reputational damage
2. Investor Distrust – Investors and banks increasingly require ESG data to assess risk. Without credible reporting, access to capital shrinks
3. Reputational Harm – Companies that fail to disclose may be seen as laggards compared to peers that lead in sustainable development
4. Missed Opportunities – Without proper reporting, LNLs may be excluded from green financing or sustainability-linked funding

Avoid costly mistakes.
Talk to our experts at GCSS, Inc.

How LNLs Can Get Started

Publishing a sustainability report may feel daunting, especially for companies doing it for the first time. Here’s how LNLs can start:

1. Conduct a Materiality Assessment – Identify the ESG issues most relevant to your stakeholders and business model
2. Choose the Right Framework – Align with IFRS S1, S2, TCFD, and GRI Standards to meet both local and global expectations
3. Strengthen Governance – Embed sustainability into the board and management agenda to ensure accountability
4. Invest in Data Systems – Build reliable systems for climate action, net zero tracking, and ESG metrics
5. Work with a Trusted Sustainability Consultant – Partnering with experts like GCSS, Inc. ensures reporting is investor-grade, compliant, and strategically valuable

First-time reporting?
Our end-to-end sustainability reporting services are designed to guide you every step of the way.

The GCSS, Inc. Advantage

As a trusted sustainability consultant in the Philippines and a proud member of the Philippine Chamber of Commerce and Industry (PCCI), GCSS, Inc. helps businesses move beyond compliance.

Our team supports companies with:

• Disclosure mapping against IFRS S1, S2, TCFD, and SEC templates
• Board and governance training to integrate ESG into decision-making

   

• Data readiness and reporting systems to ensure consistency and auditability
• Investor-grade sustainability reporting for both PLCs and LNLs

Reporting is the New Business Imperative

The SEC’s push for LNL sustainability reporting is a clear signal: transparency, ESG alignment, and corporate governance leadership are no longer optional. Companies that act now will position themselves for green financing, investor trust, and long-term competitiveness.

Compliance is the baseline—but leadership is the differentiator.

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 reporting today—and position your company as a sustainability leader in 2025.

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