The rapid proliferation of online lending applications (“lending apps”) in the Philippines has provided convenient access to credit for millions of Filipinos, particularly the unbanked and underbanked. However, it has also given rise to predatory lending practices, harassment by collectors, usurious interest rates, and blatant violations of data privacy laws. To curb these abuses, regulators have imposed a registration and licensing regime centered on the Credit Information Corporation (CIC) and the Securities and Exchange Commission (SEC).
This article explains everything a borrower, lawyer, or compliance officer needs to know about verifying whether a lending app is legitimately registered with the CIC, what “CIC registration” actually means, its limitations, and the correct steps to confirm the lawfulness of an online lending platform under Philippine law as of December 2025.
1. The Legal Framework Governing Online Lending Platforms
The primary laws and issuances are:
- Republic Act No. 9510 (Credit Information System Act) and its IRR
- SEC Memorandum Circular No. 18, series of 2019 (as amended by SEC MC No. 3, s. 2023) – Rules and Regulations Governing Online Lending Platforms (OLPs)
- SEC Memorandum Circular No. 10, series of 2022 – Registration of Financing Companies and Lending Companies with Online Platforms
- Bangko Sentral ng Pilipinas (BSP) Circular No. 1133 (2021) and Circular No. 1171 (2023) – Regulation of Operators of Payment Systems that include lending activities
- Republic Act No. 10175 (Cybercrime Prevention Act) and RA 11765 (Financial Products and Services Consumer Protection Act of 2022)
- Data Privacy Act of 2012 (RA 10173) and NPC advisories on lending apps
Key takeaway: No entity may legally operate an online lending platform in the Philippines without first being registered with the SEC as a Financing Company or Lending Company AND being accredited by the CIC as a Submitting Entity (SE) or Accessing Entity (AE) authorized to submit and access credit data.
2. What “Registered with CIC” Actually Means
Many predatory apps falsely advertise “Registered with CIC” or display a fake CIC logo to appear legitimate. Borrowers must understand the distinction between:
| Term | Meaning | Publicly Verifiable? |
|---|---|---|
| CIC-Accredited Submitting Entity (SE) | Entity authorized to submit credit data of its borrowers to the CIC | Yes |
| CIC-Accredited Accessing Entity (AE) | Entity authorized to inquire and receive credit reports from the CIC | Yes |
| SEC-Registered Financing/Lending Company | Corporate registration and license to engage in lending/quasi-banking | Yes |
| “Registered with CIC” (used by illegal apps) | Usually a complete fabrication or misrepresentation | No |
Being accredited by the CIC does NOT automatically mean the lender is allowed to lend money. CIC accreditation only governs credit information flow. The license to lend comes from the SEC (or BSP for banks).
3. Step-by-Step Guide: How to Verify if a Lending App is Legitimate
Follow this exact sequence (as of 2025):
Step 1: Check the SEC Official List of Registered Online Lending Platforms
- Go to the official SEC website → https://www.sec.gov.ph/lending-companies-and-online-lending-platforms/
- Look for the latest “List of Registered Online Lending Platforms (OLPs)” (updated monthly).
- The list contains:
– Company name
– SEC Registration Number
– Certificate of Authority (CA) number
– Approved app names (very important: one company may own several apps)
– Date of latest CA renewal
If the app name or company is NOT on this list → it is operating illegally, full stop.
Step 2: Verify CIC Accreditation Status
- Visit the CIC official website → https://www.creditinfo.gov.ph
- Under “List of Participating Institutions” or “Accredited Entities” (direct link usually: https://www.creditinfo.gov.ph/list-of-submitting-and-accessing-entities)
- Download the latest Excel or PDF file of accredited Submitting Entities (SE) and Accessing Entities (AE).
- Cross-match the exact company name from the SEC list with the CIC list.
A legitimate OLP must appear on BOTH lists.
Step 3: Additional Red-Flag Checks
- SEC Company Registration Verification Portal (https://secexpress.ph) – confirm the company is not dissolved or suspended.
- Check the app on Google Play Store or Apple App Store: legitimate apps usually disclose the full registered company name and SEC CA number in the app description.
- NPC Registration: legitimate lenders processing personal data of more than 1,000 individuals must be registered with the National Privacy Commission (verify at https://privacy.gov.ph).
4. Common Tricks Used by Illegal Lending Apps
| Trick | Explanation | How to Spot It |
|---|---|---|
| Fake CIC logo or “CIC-registered” badge | CIC does not issue logos for public display by lenders | No official CIC logo exists for lenders |
| Displaying an old 2019–2020 CIC letter | Accreditation must be renewed; old letters are meaningless | Always check the current CIC list |
| Showing SEC registration only | SEC registration ≠ lending license | Must have Certificate of Authority to lend |
| “Licensed by BSP” claim | BSP does NOT license non-bank lending apps (except for payment operators under Circular 1133) | Verify actual BSP list if applicable |
| Using the name of a legitimate company but different app | Example: “Pesocredito” vs legitimate “UnaCash” by Digido | Match exact app name with SEC approved list |
5. Legal Consequences for Operating Without Registration
- SEC may impose fines up to ₱5,000,000, order cessation of operations, and file syndicated estafa or cybercrime cases.
- Directors and officers may face imprisonment of up to 7 years (syndicated estafa under PD 1689 if five or more persons are involved).
- Collection agents using shame tactics (posting photos, contacting employer) violate RA 11765 and may be charged with unjust vexation, grave coercion, or violation of the Data Privacy Act (up to 7 years imprisonment + ₱4M fine).
6. What to Do if You Borrowed from an Unregistered App
- Stop paying immediately (payments to illegal lenders are not legally demandable).
- File a complaint with:
– SEC Markets and Securities Regulation Department (e-mail: olpmonitoring@sec.gov.ph)
– CIC (for misuse of credit data)
– National Privacy Commission (privacy.gov.ph)
– NBI Cybercrime Division or PNP Anti-Cybercrime Group - Preserve all evidence: screenshots, loan agreement, collection messages.
7. Official Links You Must Bookmark (as of December 2025)
- SEC List of Registered OLPs: https://www.sec.gov.ph/lending-companies-and-online-lending-platforms/
- CIC List of Accredited Entities: https://www.creditinfo.gov.ph/list-of-submitting-and-accessing-entities
- SEC Search Portal: https://secexpress.ph
- NPC Registry of Data Controllers: https://privacy.gov.ph
Conclusion
“Registered with CIC” has become one of the most abused phrases in Philippine fintech. Legitimacy is not established by a logo or a screenshot of an old letter. A lending app is legitimate only if:
- The operating company possesses a current Certificate of Authority from the SEC as a Financing or Lending Company with an approved online platform, and
- The same company appears on the latest CIC list of accredited Submitting/Accessing Entities.
Any app that fails either requirement is operating illegally, and borrowers are under no legal obligation to repay loans obtained under usurious or predatory terms. Always verify using the official SEC and CIC lists before downloading or borrowing.