If your corporation is SEC-registered in the Philippines, the question is usually not just “Do I need to file financial statements?” but also “Do I need to file the General Form for Financial Statements or GFFS?” The short answer: GFFS is generally required from domestic corporations with annual gross sales or revenue of at least ₱5,000,000, subject to SEC rules and the corporation’s specific classification. It is separate from the Audited Financial Statements, General Information Sheet, tax returns, and industry-specific financial statement forms.
What Is the General Form for Financial Statements?
The General Form for Financial Statements, commonly called GFFS, is an SEC-prescribed electronic form, usually in Excel format, that captures financial information from a corporation’s annual financial statements in a structured format.
It is not the same as the corporation’s Annual Financial Statements or Audited Financial Statements.
Think of it this way:
| Filing | What it is | Filed with |
|---|---|---|
| Annual Financial Statements / Audited Financial Statements | The full financial statements prepared by management and, when required, audited by an independent CPA | SEC and BIR |
| General Information Sheet | Corporate information such as directors, officers, stockholders, capital structure, and meeting date | SEC |
| GFFS | SEC’s structured financial data form based on the financial statements | SEC |
| SFFS | Special form for certain regulated or public-interest entities | SEC |
The GFFS allows the SEC to capture comparable financial data from corporations in a uniform format. In practice, accountants usually prepare it after the AFS is finalized because the numbers should match the financial statements already submitted.
Who Is Required to Submit GFFS in the Philippines?
The general rule is:
A domestic corporation registered with the Securities and Exchange Commission is required to submit GFFS if it has annual gross sales or revenue of at least ₱5,000,000.
This usually covers ordinary domestic corporations such as:
- stock corporations;
- non-stock corporations with reportable revenues, when applicable;
- One Person Corporations, if they meet the applicable revenue threshold and eFAST requires the form for their entity type;
- domestic subsidiaries of foreign companies;
- family corporations;
- small and medium enterprises incorporated with the SEC;
- corporations that are non-operating now but had reportable revenue for the year covered.
A foreign-owned Philippine corporation is still a domestic corporation if it was incorporated in the Philippines. This means a Philippine corporation with foreign shareholders is not exempt from GFFS just because its owners are foreigners.
Who Usually Does Not Need to File GFFS?
A corporation may generally not be required to file GFFS if:
- it is not registered with the SEC as a corporation;
- it is a sole proprietorship registered only with the DTI;
- it is a partnership, unless a specific SEC rule or form applies;
- its annual gross sales or revenue is below ₱5,000,000;
- it is a foreign corporation not licensed to do business in the Philippines and has no SEC-registered Philippine branch;
- it is required to file a different or special financial statement form instead of, or in addition to, GFFS.
This does not mean the corporation has no SEC filing obligations. Even if GFFS is not required, the corporation may still need to file financial statements, GIS, sworn statements, affidavits of non-operation, or other reportorial requirements.
Legal Basis for GFFS and SEC Financial Reporting
The main legal foundation is the Revised Corporation Code, Republic Act No. 11232 of 2019. Section 177 requires every corporation, domestic or foreign, doing business in the Philippines to submit annual financial statements and a General Information Sheet to the SEC, unless otherwise provided by law or SEC rules. You can read the law through the Supreme Court E-Library copy of RA No. 11232.
Section 180 of the same law also authorizes the SEC to develop and implement an electronic filing and monitoring system for corporate reports. This is why SEC reportorial filings are now handled through online systems such as SEC eFAST.
For corporations covered by the capital markets rules, the Securities Regulation Code, Republic Act No. 8799 of 2000, is also important. Section 17 covers periodic and other reports of issuers, including annual reports and financial statements. Public companies, listed companies, and issuers with registered securities have stricter reporting requirements. The law is available through the Supreme Court E-Library copy of RA No. 8799.
The SEC’s financial statement rules are further implemented through Revised SRC Rule 68, which governs the form and content of financial statements submitted to the SEC. The SEC also issues annual memorandum circulars on filing deadlines and procedures.
GFFS vs AFS: Do Not Confuse the Two
Many corporations get penalized because they assume that filing the AFS automatically covers the GFFS. It does not.
The AFS is the full set of financial statements. Depending on the corporation’s size and classification, it may be audited by an independent Certified Public Accountant or accompanied by a Statement of Management’s Responsibility.
The GFFS is the SEC’s structured form based on the AFS. It is usually filed after or around the time the AFS filing is completed, depending on the SEC’s applicable deadline.
A practical way to understand the sequence is:
- Close the corporation’s books for the fiscal year.
- Prepare the financial statements.
- Have the statements audited, if an audit is required.
- File the financial statements with the BIR.
- Submit the AFS or FS to the SEC through eFAST.
- Submit the GFFS or applicable special form if the corporation is covered.
The ₱5 Million Revenue Threshold
The key practical trigger for ordinary domestic corporations is annual gross sales or revenue of at least ₱5,000,000.
This threshold refers to revenue for the year covered by the financial statements. It is not based on the corporation’s authorized capital stock, paid-up capital, or profit.
For example:
| Situation | Likely GFFS result |
|---|---|
| Corporation had ₱8 million gross sales but only ₱200,000 net income | GFFS likely required |
| Corporation had ₱4.8 million gross sales | GFFS generally not required |
| Corporation had ₱12 million revenue but operated at a loss | GFFS likely required |
| Corporation had no operations and no revenue | GFFS generally not required, but other SEC reports may still be required |
| Philippine subsidiary of a foreign parent had ₱6 million Philippine revenue | GFFS likely required |
The threshold is based on gross sales or revenue, not net income. A corporation can be unprofitable and still be required to submit GFFS.
GFFS and the New ₱3 Million Audit Threshold Are Different Tests
A common source of confusion is the SEC’s updated audit threshold.
Under current SEC financial reporting rules, corporations with total assets or total liabilities above the applicable threshold are required to submit audited financial statements. SEC rules have moved the small-corporation audit threshold from the old ₱600,000 level to ₱3,000,000 for relevant fiscal years, subject to the applicable SEC circular and Revised SRC Rule 68.
This is a separate issue from GFFS.
| Question | Main test |
|---|---|
| Do I need audited financial statements? | Assets or liabilities threshold, plus entity classification |
| Do I need GFFS? | Generally, annual gross sales or revenue of at least ₱5 million |
| Do I need GIS? | Generally, all SEC-registered corporations |
| Do I need SFFS? | Depends on whether the corporation is public, listed, or specially regulated |
This means a corporation should not rely on only one threshold. You need to check both the financial statement audit rules and the GFFS/SFFS filing rules.
Corporations That May Need Special Forms Instead of or in Addition to GFFS
Some corporations are not ordinary operating companies. They may be subject to special SEC forms.
These include:
- publicly listed companies;
- public companies under Section 17.2 of the Securities Regulation Code;
- investment companies;
- brokers and dealers;
- lending companies;
- financing companies;
- other SEC-regulated entities with secondary licenses.
The SEC’s online filing system may require an industry-specific Special Form for Financial Statements or SFFS. Examples include forms for publicly held companies, investment companies, broker-dealers, lending companies, and financing companies.
The important practical point is this: do not assume that GFFS alone is enough if your corporation has a secondary license or is publicly held. Check the form type available in eFAST and the SEC rules for your specific industry.
Foreign-Owned Companies and Foreign Corporations
Foreigners commonly misunderstand the distinction between a Philippine corporation and a foreign corporation.
A corporation incorporated in the Philippines is a domestic corporation, even if it is 40%, 60%, or 100% foreign-owned, subject to nationality restrictions under Philippine law. If it meets the GFFS revenue threshold, it is generally treated like any other domestic corporation for GFFS purposes.
A foreign corporation licensed by the SEC to do business in the Philippines, such as a branch office, representative office, regional headquarters, or regional operating headquarters, has its own SEC reportorial duties. Its financial statement requirements depend on its license type, assigned capital, assets, revenues, and applicable SEC rules.
Foreign corporations should be careful about these practical issues:
- Philippine branch financial statements should reflect Philippine operations, not merely the foreign parent’s global accounts.
- Documents executed abroad for SEC use may need apostille or consular authentication, depending on the country and document type.
- The resident agent and registered SEC contact details should be updated.
- The eFAST account should use the corporation’s correct SEC registration or license number.
- Foreign ownership does not excuse late filings.
When Is GFFS Filed?
Under SEC rules implemented through online filing, GFFS and SFFS are generally filed within 30 days from the deadline for submission of the AFS, unless the SEC provides a different schedule for a particular year or class of corporations.
For corporations with a calendar year ending December 31, the SEC usually issues an annual circular setting the filing schedule. For corporations with a fiscal year ending on another date, the AFS deadline is generally counted from the end of that fiscal year, subject to the annual SEC circular and special rules for regulated entities.
Public companies and issuers covered by Section 17.2 of the Securities Regulation Code usually follow a different timeline because their annual report, SEC Form 17-A, has its own filing rules.
Because deadlines can change from year to year, corporations should check:
- the latest SEC memorandum circular on AFS and GIS filing;
- the corporation’s fiscal year in its Articles of Incorporation;
- whether it is a regular corporation, OPC, branch, public company, or regulated entity;
- any notices or reminders inside eFAST.
Step-by-Step Guide: How to Check If You Need to Submit GFFS
1. Confirm the entity type
Start with the SEC registration documents. Check whether the entity is:
- domestic stock corporation;
- domestic non-stock corporation;
- One Person Corporation;
- foreign branch;
- representative office;
- regional headquarters or regional operating headquarters;
- lending, financing, broker-dealer, investment, or public company.
The entity type affects the reportorial requirements.
2. Check the revenue for the year
Look at the corporation’s financial statements and determine its gross sales or revenue for the fiscal year.
If the corporation’s annual gross sales or revenue is ₱5,000,000 or more, GFFS is generally required for ordinary domestic corporations.
3. Check whether a special form applies
If the corporation is public, listed, regulated, or has a secondary license from the SEC, check whether it must submit SFFS or another industry-specific form.
Examples:
- lending companies may have lending company forms;
- financing companies may have financing company forms;
- broker-dealers have separate SEC reporting requirements;
- publicly held companies may have public company forms.
4. Confirm the AFS deadline
The GFFS deadline is tied to the AFS deadline, so you must first identify when the AFS is due.
For many corporations, this depends on:
- fiscal year-end;
- annual SEC filing schedule;
- whether the corporation is covered by Section 17.2 of the SRC;
- whether the financial statements are audited by COA;
- whether the corporation is a broker-dealer or other regulated entity.
5. Prepare the GFFS using the correct template
Use the current SEC form or the form available in eFAST or the SEC reportorial requirements page. Do not reuse an old file blindly because templates and validation rules may change.
The amounts should match the AFS. Inconsistencies between the AFS and GFFS can cause questions, reversion, or penalties.
6. Submit through eFAST
The SEC no longer treats email, courier, ordinary mail, or over-the-counter submission as the normal method for these annual reports. Covered reports are submitted through eFAST.
The SEC eFAST user guide explains the basic online process, including uploading, selecting the form type, entering the period covered, and monitoring whether the report is uploaded, submitted, accepted, or reverted. The SEC’s eFAST user guide and guide to avoid reversion are useful references.
7. Wait for acceptance and QR confirmation
Uploading is not the same as final acceptance.
In practice, eFAST statuses matter:
| Status | Practical meaning |
|---|---|
| Uploaded | File is in the system but may not yet be submitted |
| Submitted | Sent for SEC review |
| Accepted | SEC accepted the report and issues confirmation or QR code |
| Reverted | Treated as not filed or not received until properly corrected and resubmitted |
A reverted report can become a late filing problem if the correction is made after the deadline.
Documents and Information Commonly Needed
Before preparing GFFS, gather the following:
| Requirement | Why it matters |
|---|---|
| Final AFS or FS | Source of the financial data |
| BIR filing proof for AFS | Usually needed for the SEC AFS submission |
| SEC registration number | Must match the eFAST company profile |
| Corporate name exactly as registered | Name mismatch can cause reversion |
| TIN | Used in tax and financial records |
| Principal office address | Should match SEC records or latest GIS |
| PSIC or industry classification | Needed for proper classification |
| Revenue, assets, liabilities, equity, income, and cash flow figures | Main GFFS data |
| MC28 registered email and mobile number | Used for SEC notices and access |
| Board authority or Secretary’s Certificate for filer | Needed for authorized filing access |
| Correct eFAST credentials | Required for online submission |
Common Mistakes That Cause Problems
Filing AFS but forgetting GFFS
This is one of the most common mistakes. The corporation may have timely filed its AFS and GIS but still missed GFFS.
Using net income instead of gross revenue
The ₱5 million trigger is generally based on gross sales or revenue. A corporation with large sales but small profit may still be covered.
Treating “uploaded” as “filed”
In eFAST, a file may be uploaded but not yet submitted. Always check the final status.
Ignoring reversion notices
If SEC reverts the report and the corporation does not correct it, the filing may be considered not received.
Wrong period covered
The period covered should match the fiscal year or financial statement period. Using the annual meeting date, tax filing date, or upload date by mistake can cause reversion.
Wrong company profile
The uploaded form should match the SEC registration number and corporate name in the eFAST account. This is especially important for groups with several related companies.
Using an old Excel template
Old templates may have outdated fields, formulas, or formatting. Use the current template from SEC sources or eFAST.
Assuming non-operation removes all filing duties
A non-operating corporation may still need to file reports, such as GIS, FS, and an Affidavit of Non-Operation when applicable. Non-operation does not automatically erase SEC obligations.
What Happens If a Corporation Does Not Submit GFFS?
Failure to file GFFS when required may result in SEC penalties. The corporation may also face problems when requesting:
- a Certificate of Good Standing;
- amendment of Articles of Incorporation or By-Laws;
- increase or decrease of capital stock;
- dissolution;
- merger or consolidation approval;
- secondary license renewal;
- bank account compliance documents;
- due diligence clearance for investors or buyers.
For many business owners, the bigger problem is not only the monetary penalty. It is the delay caused when the corporation later needs SEC clearance and discovers years of missing reports.
Frequently Asked Questions
Do all SEC-registered corporations need to submit GFFS?
No. All SEC-registered corporations generally have reportorial obligations, but GFFS is generally required from domestic corporations with annual gross sales or revenue of at least ₱5,000,000. Corporations below that threshold may still need to file AFS or FS, GIS, and other required reports.
Is GFFS the same as Audited Financial Statements?
No. The AFS is the full financial statement package. GFFS is a separate SEC-prescribed structured form based on the financial data in the AFS or FS.
Is a corporation required to file GFFS if it had ₱5 million sales but no profit?
Yes, generally. The threshold is based on gross sales or revenue, not net income. A corporation can have a net loss and still be required to file GFFS.
Does a One Person Corporation need to submit GFFS?
An OPC is still a corporation. If it is a domestic corporation and meets the applicable revenue threshold, it should check eFAST and SEC rules to confirm whether GFFS is required for the year. OPCs also have specific financial statement and disclosure obligations under the Revised Corporation Code and SEC issuances.
Does a foreign-owned Philippine corporation need to submit GFFS?
Yes, if it is incorporated in the Philippines and meets the GFFS threshold. Foreign ownership does not exempt a domestic corporation from SEC reportorial requirements.
Does a foreign branch need to submit GFFS?
A licensed foreign branch has SEC financial reporting obligations, but the exact form depends on its license type, assigned capital, assets, revenues, and SEC classification. Some foreign corporations may have different reporting requirements from ordinary domestic corporations.
When is GFFS due?
GFFS is generally due within 30 days from the deadline for filing the AFS, unless the SEC provides a different schedule. Because the SEC may issue annual filing circulars, always check the current year’s SEC deadline.
Where is GFFS filed?
GFFS is filed through SEC eFAST. The normal filing method is online, not email, courier, ordinary mail, or walk-in filing.
What if eFAST rejects or reverts the GFFS?
A reverted filing is generally treated as not filed or not received until corrected and accepted. Review the reversion reason, correct the issue, resubmit promptly, and keep the final acceptance or QR confirmation.
Can the accountant file GFFS for the corporation?
Yes, if properly authorized. The corporation should ensure that the accountant, law firm, or service provider is authorized in the required SEC manner and uses the correct eFAST account, company profile, and registered contact details.
Key Takeaways
- GFFS is generally required from domestic corporations with annual gross sales or revenue of at least ₱5,000,000.
- GFFS is separate from the AFS, GIS, tax returns, and industry-specific SEC forms.
- The ₱5 million GFFS revenue threshold is different from the SEC audit threshold for financial statements.
- Foreign ownership does not exempt a Philippine corporation from GFFS.
- Public, listed, lending, financing, broker-dealer, and other regulated entities may have special forms in addition to or instead of ordinary GFFS.
- GFFS is filed through SEC eFAST, usually in Excel format.
- A report that is only uploaded, reverted, or rejected should not be treated as successfully filed.
- Late or missing GFFS can cause penalties and future SEC clearance problems.