The Philippine Securities and Exchange Commission has released for public comment a draft memorandum circular that would require publicly listed companies and large non-listed (LNL) entities to prepare sustainability reports using Philippine Financial Reporting Standards Sustainability Disclosure Standards, based on PFRS S1 and PFRS S2, and sets out reporting guidelines and a phased implementation roadmap. Under the draft, entities covered by Section 17.2 of the Securities Regulation Code would submit a sustainability report as an attachment to their annual reports, while LNLs outside that provision would file sustainability reporting with their audited financial statements. PFRS S1 and S2 formatting would apply starting fiscal year 2026, with fiscal year 2025 allowed to follow any internationally recognized framework. Reporting would be tiered for publicly listed companies by market capitalization as of 31 December 2025 (or as at listing after 2025): Tier 1 (over PHP 50 billion) reporting begins in 2027 for fiscal years on or after 1 January 2026, Tier 2 (over PHP 3 billion up to PHP 50 billion) begins in 2028 for fiscal years on or after 1 January 2027, and Tier 3 (PHP 3 billion or less, plus LNLs with annual revenue over PHP 15 billion) begins in 2029 for fiscal years on or after 1 January 2028. The draft also flags a potential requirement for mandatory limited assurance of Scope 1 and 2 greenhouse gas emissions by an independent assurance practitioner two years after PFRS S1 and S2 implementation for each tier, alongside transition reliefs including temporary limits on climate-only disclosures, delayed Scope 3 reporting, no comparative information, and timing flexibilities for submission. Penalties for publicly listed companies would follow the existing incomplete-report framework, while penalties for LNLs would be set out in subsequent issuances. Stakeholders can submit comments on the draft guidelines until 15 August.