The Philippines has seen explosive growth in online lending platforms since 2018. While many legitimate SEC-registered lending companies and financing companies provide convenient credit access, a significant number of unregulated or marginally regulated apps engage in predatory and illegal collection practices — including aggressive harassment that begins days or even weeks before the loan due date.

These “pre-due date” tactics include incessant calls and texts, threats of public shaming, unauthorized contact list access, mass messaging to contacts, doctored obscene photos, and threats of fake lawsuits or police visits. Such conduct is not only unethical but expressly illegal under multiple Philippine laws and regulatory issuances.

This article consolidates every relevant law, regulation, circular, advisory, and reporting procedure as of December 2025 so borrowers know exactly what constitutes illegal harassment, what their rights are, and how to stop it permanently.

I. What Constitutes Illegal Pre-Due Date Harassment?

The following acts are expressly prohibited by law even if the loan is not yet due:

Sending more than three (3) reminders per week before due date (SEC guidelines benchmark; excessive reminders become harassment).
Using threats of violence, lawsuits, arrest, or “barangay visits” when no default has occurred.
Threatening to shame the borrower on social media or “blast” contacts.
Actually contacting employers, family members, or any third party without a court order.
Using obscene, insulting, or profane language.
Calling before 6:00 a.m. or after 10:00 p.m., or calling the workplace repeatedly.
Creating or threatening to create morphed obscene images.
Demanding payment of exorbitant penalties or interest not disclosed in the Truth in Lending statement.
Accessing or threatening to access the borrower’s phone contacts without explicit, separate, and withdrawable consent.

Any one of these acts is sufficient to file administrative, criminal, and civil complaints.

II. Governing Laws and Issuances (as of December 2025)

Republic Act No. 9474 (Lending Company Regulation Act) and Republic Act No. 8556 (Financing Company Act)
All lending and financing companies must be SEC-registered. Unregistered apps have no legal right to collect.
SEC Memorandum Circular No. 18, series of 2019
“Prohibition on Unfair Debt Collection Practices of Financing Companies and Lending Companies”
Explicitly bans the acts listed in Section I above, regardless of whether the borrower is in default.
SEC Memorandum Circular No. 19, series of 2020
Additional guidelines reinforcing fair debt collection and imposing fines up to ₱1,000,000 per violation.
SEC Office of the General Counsel Opinion No. 21-03 (2021) and subsequent opinions
Confirmed that collection activities may only intensify upon default. Pre-default communications must be limited to courteous reminders.
Republic Act No. 10175 (Cybercrime Prevention Act of 2012)
Covers online libel, cyber-threatening, and identity theft when apps post defamatory content or use fake profiles.
Republic Act No. 10173 (Data Privacy Act of 2012)
Forcing access to contacts or sharing personal data without freely given, specific, and informed consent is a criminal offense punishable by up to 7 years imprisonment and fines up to ₱5,000,000 (NPC Circular 2022-04 and 2023-01).
Revised Penal Code
- Art. 282 – Grave threats
- Art. 287 – Unjust vexation
- Art. 358 – Oral defamation/slander
  Criminal cases can be filed even if the lender is abroad.
Republic Act No. 3765 (Truth in Lending Act)
Failure to disclose true cost of credit renders penalty clauses void.
BSP Circular No. 1133 (2021) and Circular No. 1163 (2023)
Banks and their third-party collectors are also prohibited from abusive practices.
DTI Department Administrative Order No. 22-01 (2022)
Declares certain online lending tactics as unfair trade practices.

III. Rights of Borrowers When Harassed Before Due Date

You are not required to answer calls or reply to messages that are harassing in nature.
You may record all calls and screenshot all messages without informing the collector (one-party consent rule under Philippine jurisprudence).
You may demand in writing that all communication cease except through email or registered mail.
You may revoke contact list access at any time; continued use after revocation is a criminal privacy violation.
If the app is unregistered, you have no legal obligation to pay any interest or penalty — only the principal may be demanded in court, and many courts now declare the entire contract void.

IV. Step-by-Step Reporting Procedure (2025)

Step 1: Gather Evidence (Essential)

Screenshots of loan agreement, disclosure statement, harassing messages, call logs, and threats.
Screen recordings of calls if possible.
Affidavit of witnesses (family/employer who received messages).

Step 2: Send Formal Demand Letter (Optional but Highly Recommended)

Use this template:

[Your Name and Address]
[Date]

[Name of Lending App / Company]
[Email and Address if known]

Subject: Formal Demand to Cease and Desist from Illegal Collection Practices

Dear Sir/Madam:

I am a borrower under Loan Reference No. ____. My loan is not yet due as of this date. Despite this, your agents have been [describe acts].

These acts violate SEC MC No. 18 s. 2019, RA 10173, and the Revised Penal Code.

I demand that you immediately:

Cease all forms of harassment;
Delete all my personal data including contacts;
Confirm compliance in writing within 48 hours.

Failure to comply will constrain me to file complaints with the SEC, NPC, PNP-ACG, NBI, and appropriate courts for damages exceeding ₱1,000,000.

Sincerely,
[Your Name]

Send via email (keep read receipt) and LBC with return card.

Step 3: File Complaints (File in ALL agencies simultaneously)

A. Securities and Exchange Commission (SEC) – Primary regulator
Online: https://www.sec.gov.ph/complaint-form/
Select “Online Lending Harassment” category (updated 2024 form).
Attach evidence and demand letter.
SEC can impose fines up to ₱5,000,000 and revoke Certificate of Authority permanently (recent 2024–2025 cases resulted in permanent bans of over 300 apps).

B. National Privacy Commission (NPC)
Online: https://privacy.gov.ph/file-a-complaint/
Use the “Online Lending” complaint template introduced in 2023.
NPC has been imposing ₱3–5 million fines per app since 2023 (e.g., Cashalo, JuanHand, UnaCash, and numerous smaller apps fined in 2024–2025).

C. Philippine National Police Anti-Cybercrime Group (PNP-ACG)
File online: https://cybercrime.pnp.gov.ph
Or visit the nearest ACG office (Camp Crame or regional desks).
File for unjust vexation, grave threats, or violation of RA 10175.
Many collectors have been arrested in 2024–2025 raids.

D. National Bureau of Investigation (NBI) Cybercrime Division
Online referral: https://nbi.gov.ph/online-services/
Particularly effective when the app is foreign-owned (Chinese, Singaporean, etc.).

E. Department of Trade and Industry (DTI)
For unfair trade practices: https://www.dti.gov.ph/file-complaint

F. Bangko Sentral ng Pilipinas (BSP) – If the lender is partnered with a bank
https://www.bsp.gov.ph/Pages/ConsumerAssistance.aspx

Step 4: File Criminal and Civil Cases (If harassment is severe)

Criminal cases (unjust vexation, grave threats, cyberlibel) – file directly with City/Provincial Prosecutor (no need for private lawyer initially).
Civil case for moral damages (₱200,000–₱1,000,000 typical award in 2023–2025 cases) plus attorney’s fees – file in Regional Trial Court or Small Claims if below ₱1,000,000.

Recent Supreme Court decisions (2024) have upheld awards of ₱500,000+ in moral damages against online lenders for pre-due harassment.

V. Blacklisted and Cease-and-Desist Apps (SEC List as of December 2025)

SEC maintains a running list of over 3,000 apps under Cease and Desist Orders (CDO). Borrowing from any CDO-listed app renders the loan contract void ab initio. Check the current list at:
https://www.sec.gov.ph/advisories-2025/online-lending-apps/

Popular apps that have been permanently banned or heavily fined in 2024–2025 include: FastPeso, QuickPera, CashJeep, Lucky Loan, Pesoloan, UnaCash (fined ₱4M by NPC in 2024), MoneyCat, Cashalo (multiple fines), and hundreds of “5–7–10” apps.

VI. Preventive Measures Every Borrower Must Take

Never grant contact list access. Revoke immediately via phone settings if already granted.
Use a separate “burner” phone or Google Voice number for loan applications.
Record every disclosure statement and check SEC registration before borrowing.
Pay through official channels only; never through individual GCash accounts.
If harassed, immediately block and report the numbers to NTC (text 7726).

Conclusion

Pre-due date harassment by online lending apps is not just unethical — it is a serious criminal and administrative offense under Philippine law. The SEC, NPC, PNP-ACG, and courts have shown increasing aggressiveness in 2024–2025 in shutting down abusive platforms and awarding substantial damages to victims.

Borrowers who document the harassment properly and file complaints with all relevant agencies almost always succeed in stopping the harassment within days and, in most cases, having their loans declared unenforceable.

Do not suffer in silence. Report immediately. The full force of Philippine law is now squarely on the side of the harassed borrower.