Editorial guide · Philippines

SEC Wants to Accredit Third-Party Debt Collectors. What Would Change for Philippine Borrowers?

The SEC has proposed accrediting third-party debt collectors hired by Philippine lenders. What the September 2026 draft says, what is not yet law, and which borrower protections already apply.

A collection agency contacts you about an overdue loan. You recognise the lender, but not the company making the call. Can you check whether that agency really has authority to contact you?

The Philippine Securities and Exchange Commission (SEC) has proposed a new way to regulate part of that relationship. On 30 September 2026, it opened a public consultation on accrediting, disclosing and supervising third-party collection agencies hired by financing and lending companies. The SEC listed a related announcement on 5 October. According to Philippine reporting on the proposal, the consultation runs through 15 October 2026.

These are proposed rules, not an accreditation system already in force. The comment deadline is not an implementation date, and an agency cannot be judged against a future SEC TPCA register that has not yet been established under these rules.

What the SEC wants to change

The proposal describes a third-party collection agency (TPCA) as an SEC-registered stock corporation engaged by a financing company or lending company to provide debt collection services. If the rules are adopted, external collection work within that scope would be restricted to SEC-accredited TPCAs, alongside the lender's own internal collection personnel. The distinction matters: registering a corporation with the SEC and obtaining a separate accreditation to provide debt collection services would be different steps.

As reported in the SEC announcement reproduced by iTech Solution, agencies would apply through an SEC online system. Accreditation would last three years, with renewal applications expected at least 30 days before expiry. The SEC would also maintain a public, regularly updated list of accredited agencies. Late renewal could attract a fine; an exact penalty for late filing has not been independently established from the available text.

An accredited agency could be removed from the list following a finding of unfair debt collection, certain final administrative or criminal decisions, material or repeated breaches of applicable requirements, or its own request to leave. The proposal also contemplates blacklisting directors and officers in specified serious cases.

A public list could help answer whether an agency appears in the SEC's records. It would still leave two separate questions: whether your lender actually engaged that agency, and whether the particular caller or message came from it. A genuine company name can be used by someone else.

Why the lender could face penalties too

The proposed sanctions reach beyond the collection agency. Accounts of the draft describe fines of ₱60,000 to ₱200,000 for TPCAs involved in unfair collection practices. A fourth offense could lead to removal from the registry and revocation of accreditation. Reports mention unlawful home visits and improper automated messages as examples; they do not establish that every home visit or automated payment reminder is prohibited.

Financing and lending companies could face fines of up to ₱2 million for fraudulently engaging non-accredited or non-disclosed TPCAs, according to the SEC's announcement as reproduced in local reporting. Under the proposed escalation, a fourth violation could result in suspension or revocation of the lender's certificate of authority. Revocation of its articles of incorporation is described as an exceptional outcome.

Those conditions are important. The ₱2 million amount is a proposed maximum, not an automatic penalty whenever a borrower receives a call from an unfamiliar collector. Whether an agency was engaged, what was disclosed, the relevant conduct and the eventual wording of the circular would all matter. The full penalty schedule and any implementation or transition arrangements still need verification against the SEC's original draft and, later, its final rule.

Borrowers do not need to wait for the new rules to question abusive collection

The SEC already has a rule on unfair collection by financing and lending companies: Memorandum Circular No. 18, Series of 2019. Section 1 identifies practices including threats, abusive language, deceptive collection methods and certain disclosures of borrowers' information. Section 4 requires in-house and outsourced personnel handling collections to disclose their full name or true identity to the borrower.

Section 3 is especially relevant to outsourced collectors. It treats the service provider as the financing or lending company's agent and keeps ultimate responsibility for collection practices and compliance with the company. That principle is already part of the existing framework; the proposed TPCA scheme would add accreditation and direct oversight of the collection business itself.

The SEC applied existing consumer-protection rules in a January 2026 order concerning Global Dominion Financing. As BusinessWorld reported in February, the regulator imposed a ₱50,000 administrative fine following a complaint about third-party agents' collection conduct, including alleged roadside interception and threatening messages. Global Dominion subsequently acknowledged the fine and described the incident as isolated, saying it had strengthened oversight. The company's response and the SEC's finding should be read separately.

That case concerns enforcement of existing rules, including MC No. 18 and the financial-consumer-protection framework. It is not a sanction issued under the proposed TPCA accreditation rules.

If a collector contacts you now

Ask for the caller's full name or true identity, the agency's name and the lender they claim to represent. Check the claimed assignment through the lender's published support channel—not just through a number or payment link supplied in the collection message. Confirm the account and balance separately before sending money to an unfamiliar destination.

If the contact includes threats, humiliating messages or disclosures to people outside your loan arrangement, preserve dates, messages and the claimed collector identity. Keep your record factual, and avoid posting account numbers, ID documents or unrelated contacts publicly. BorrowTalk's guide to documenting collection contact explains what evidence is useful and how to limit unnecessary disclosure.

An outstanding debt does not give a collector permission to use prohibited methods. Equally, an abusive call or a question about the caller's identity does not automatically extinguish a valid loan obligation. These are separate issues that need separate evidence.

If the lender falls under SEC supervision, collection-conduct concerns can be raised with the lender and through the appropriate SEC process. Separate misuse of personal information may also involve the National Privacy Commission. BorrowTalk's guide to Philippine loan complaints helps distinguish those channels.

The next milestone for this proposal is the reported 15 October comment deadline. A final SEC circular, effective date, transition arrangements and any actual TPCA register must be checked independently when issued. Until then, the proposed accreditation system should not be presented as a completed licensing check for individual collection agencies.