Verifying Registration of Online Lending Apps in the Philippines
(Updated as of 7 August 2025)
1. Why Verification Matters
Online‐only lenders can be legitimate channels for quick credit—or predatory actors that overcharge, harass, or steal data. Philippine law treats lending as a regulated activity: operating without the proper authority is a criminal offense. Verifying an app’s status protects you from:
- Exorbitant, hidden, or compound charges
- Aggressive debt-collection tactics (threats, public shaming, “doxing”)
- Unauthorized harvesting of contacts, photos, and personal files
- Civil or criminal liability for inadvertently dealing with an illegal entity
2. The Regulatory Architecture
| Regulator | Core Legal Basis | What It Oversees |
|---|---|---|
| Securities and Exchange Commission (SEC) | • Republic Act 9474 – Lending Company Regulation Act of 2007 • RA 8556/5980 – Financing Companies Act • SEC Memorandum Circular (MC) 18-2019, 28-2020, 10-2021, 7-2022, 19-2023 |
Incorporation, paid-up capital, Certificate of Authority (CA) to operate, annual reporting, online lending platform (OLP) accreditation, advertising & collection rules |
| Bangko Sentral ng Pilipinas (BSP) | • RA 7653 (BSP Charter, as amended) • Digital Banking & Electronic Money Issuer (EMI) frameworks |
Only if the lender is a bank, EMI, or uses BSP-licensed payment rails (e.g., InstaPay, PESONet) |
| National Privacy Commission (NPC) | • RA 10173 – Data Privacy Act • NPC Circular 20-01, 23-02 |
Data-processing consents, limits on contact scraping (max 2 references), lawful purpose test |
| Department of Trade and Industry (DTI) | • Consumers Act (RA 7394) | Deceptive or unfair trade practices in marketing |
| Philippine National Police – Anti-Cybercrime Group (PNP–ACG) & NTC | • Cybercrime Prevention Act (RA 10175) | Criminal harassment, doxing, SMS spam, SIM threats |
Only the SEC can grant or revoke the CA. Without it, an app is illegal—even if it is on Google Play or the Apple App Store.
3. Registration & Accreditation Requirements
| Requirement | Lending Company | Financing Company |
|---|---|---|
| SEC Company Registration | ✓ Domestic corporation (≥ 5 natural persons) | ✓ Same |
| Minimum Paid-up Capital | ₱1 million (RA 9474) | ₱10 million (RA 8556) |
| Certificate of Authority (CA) | Mandatory; renewable every 3 years (MC 19-2023) | Mandatory |
| OLP Accreditation (if the company releases loans through an app or website) | Must file Form OLP-1, disclose data-privacy protocols, collection scripts, and partner payment gateways (MC 10-2021) | Same |
| Annual Reports | Audited FS + General Information Sheet (GIS) + Lending Activity Return (LAR) | Similar |
| Collection & Privacy Rules | • MC 28-2020: No threats, obscene language, or contacting persons not named as co-borrowers/guarantors. • MC 7-2022: May access only two personal contacts; must stop accessing phonebook/photos. |
Same |
Failure to comply can trigger CA revocation, fines up to ₱1 million per violation, and criminal prosecution of directors/officers (up to 10 years’ imprisonment under RA 9474).
4. Step-by-Step Guide to Verify an App
Check the SEC “Financing & Lending Companies Corner” Go to https://www.sec.gov.ph ➜ Services ➜ Lending & Financing. • Look for:
- List of Companies with Valid CAs
- List of Registered Online Lending Platforms (OLPs)
- List of Revoked / Banned Entities The lists are updated bi-weekly. A legitimate app must appear in two places: its corporate entity in the CA list and its trade name in the OLP list.
Match Corporate Name vs. App Name Apps sometimes use a brand distinct from the corporate name. In the SEC list you will find the “Doing Business As (DBA)” or “Trade Name”. The Play Store listing’s Developer Contact should show the same corporate name and a Philippine address.
Validate the CA Number Inside the App RA 9474 §12 and MC 18-2019 require the CA number to be shown on: • the landing page of the app/website, • the loan agreement, and • all marketing materials. The format is “SEC CA No. #### (DD/MM/YYYY)”. Compare it with the SEC list.
Cross-check Privacy Compliance • The app must show a Privacy Notice referencing RA 10173 and NPC circulars. • Collection of contacts/metadata must be opt-in and limited to two references. • If the app demands camera roll, location, or social-media logins, red flag.
Review Interest & Fees Disclosure While the Usury Law ceiling is suspended, SEC MC 1-2024 compels disclosure of: • Nominal & effective interest rate (APR), • Service charges, penalties, and collection fees, • Sample amortization schedule. Lack of a clear table is a violation.
Verify Payment Channels Legit lenders integrate BSP-licensed EMIs (e.g., GCash, Maya) or PESONet partners. If payment is only via personal bank account/GCash QR belonging to a private individual, suspect illegitimacy.
Look for Red Flags in Collection Practices • Automated messages threatening to post your debt on social media. • Calls to contacts not listed as co-makers. • Collection outside 8 AM–5 PM on weekdays (MC 28-2020 limitation).
5. Enforcement & Penalties (Snapshot)
| Violation | Governing Provision | Penalty |
|---|---|---|
| Operating without CA | RA 9474 §12 | ₱10,000–₱50,000 fine and/or 6 mos–10 yrs imprisonment |
| Misrepresenting SEC registration | Securities Regulation Code §56 | Up to ₱5 million fine or 21 yrs imprisonment |
| Privacy abuses (contact scraping, public shaming) | NPC Circular 23-02 | ₱500,000 per act + suspension/closure |
| Harassment, unjust vexation | Revised Penal Code Art. 287/287-A (as amended) | Arresto menor–Mayor &/or fine |
| Cyberlibel / doxing | RA 10175 §4(c)(4) | Prison Mayor + fine up to ₱1 million |
| Unfair collection | SEC MC 28-2020 | ₱25,000–₱200,000 per act; CA suspension/revocation |
6. Remedies if You Encounter an Unregistered or Abusive App
Report to SEC Enforcement and Investor Protection Dept. • email: epd@sec.gov.ph • Submit screenshots, transaction IDs, and CA absence evidence.
File a Privacy Complaint with NPC • online portal: https://complaints.npc.gov.ph • Grounds: unauthorized processing, excessive data collection, harassment.
Lodge a Complaint with PNP-ACG • Cite violations of RA 10175 (cyber harassment, threats, identity theft).
NTC & Telcos • Request blocking of SMS originating from spoofed numbers or SIMs used for threats.
Small Claims / Civil Suit • If the loan is ≤ ₱400,000, you may file in the first-level courts without a lawyer.
7. Practical Tips Before Borrowing
- Download the latest version of the SEC lists each time—apps can be banned overnight.
- Screen-record your onboarding flow to preserve evidence of disclosures (or lack thereof).
- Keep communications inside the app or official email; avoid communicating via personal Messenger/Viber accounts of agents.
- If possible, borrow from BSP-supervised institutions (banks, thrift banks, micro-finance NGOs) subject to stricter prudential rules.
- Remember: An app’s presence in Google Play does not equal legality. Google enforces SEC take-down requests but delays happen.
8. Emerging Developments to Watch (2025-2026)
House Bill 10845 – Online Lending Regulation Act (pending in the Senate) would:
- Create a single OLP Registry hosted by SEC & BSP;
- Mandate industry self-regulatory organization (SRO) accreditation;
- Impose an APR cap of 15 % per month, replacing outdated circulars.
NPC’s draft “Algorithmic Fairness Guidelines” will require explainability for AI-driven credit scoring used by OLPs.
BSP’s Open Finance Framework Phase 2 (rolled out June 2025) enables consumers to port credit histories between lenders, improving transparency.
Conclusion
Verifying an online lending app’s registration is not optional—it is the first line of defense against fraud, data abuse, and unlawful collection tactics. By methodically cross-checking SEC accreditation, privacy compliance, and payment legitimacy, borrowers can confidently identify lawful providers. Regulators continue to tighten oversight, but vigilance remains the borrower’s best protection.