Philippine SEC proposes accreditation and fines for lenders' third-party debt collectors

Implications

Facts

Draft rules: the Securities and Exchange Commission (SEC) has published for comment a draft memorandum circular on the accreditation, disclosure and oversight of third-party collection agencies engaged by financing and lending companies. Once in force, only SEC-accredited agencies and lenders' in-house collectors could collect debts. Accreditation would run for three years ¹, accredited agencies would be listed in a public registry, and existing agencies would have one year after the rules take effect to obtain accreditation. ² Public comments are due by 15 October 2026.

Penalties: agencies using unfair practices such as unauthorised home visits or improper automated messages would face fines of PHP 60,000–200,000 ³, with delisting on a fourth offence ⁴ and possible blacklisting of directors and officers of delisted agencies. Financing and lending companies that knowingly use unaccredited or undisclosed agencies would face fines of up to PHP 2 million ⁵, and repeat violations could lead to suspension or revocation of their authority to operate.

Context: an SEC commissioner told a Senate hearing that the SEC received 3,315 complaints against unregistered lenders over debt-collector harassment between January and 15 September 2025. ⁶

Analysis

Rule design: the SEC's existing rule on unfair collection practices, Memorandum Circular No. 18 of 2019, defines prohibited conduct but leaves the market for outsourced collectors open. The draft adds a licensing gate on the collectors themselves and a disclosure duty on the lender, so a breach by an agency becomes a compliance exposure for the lender that hired it.

Cross-country: Indonesia took the same route under POJK 22/2023, which allows lenders to use outside collectors only if the firm is licensed and its staff certified, and keeps the lender fully responsible for their conduct. OJK's market-conduct fines so far in 2026 total IDR 8.73 bn across 43 fines, with debt-collector conduct among the cited breaches. ⁷ In both markets the harassment complaints concentrate on unregistered lenders, which licensing rules for collectors do not reach directly.

Credit link: Philippine bank consumer loans are still growing at 16.2% ⁸ while inflation reached 7.2% in September ⁹, a mix that tends to raise collection volumes at non-bank lenders.

Counterpoints and uncertainties

The rules are a draft and may change after the comment period; the effective date, the full list of unfair practices and the per-offence fine schedule are not yet final. Accreditation may shrink the pool of collection agencies and raise costs for small lenders, and it does not touch unregistered online lenders, the main source of complaints.