Locking in reform: The Philippines’ push for primary law on beneficial ownership
The Philippines is moving to introduce its first-ever primary law on beneficial ownership transparency (BOT) — a step that would lock in years of reform and give the country a durable tool to fight illicit finance, raise more domestic revenue, and rebuild public trust in how companies are owned and controlled. This follows the country’s one-year milestone of exiting the Financial Action Taskforce greylist in May 2025, reinforcing its alignment with global financial standards and its commitment to transparency and financial integrity.
The journey towards a primary beneficial ownership law
The Philippines has made strides in BOT reform in recent years, including through:
- enhanced access to beneficial ownership (BO) information through the signing of data-sharing agreements between the Securities and Exchange Commission (SEC) and 25 government agencies;
- mandatory disclosure of the beneficial owners of companies with public contracts under the New Government Procurement Act;
- enhanced transparency and accountability in extractives under the Fiscal Regime Act;
- launch of the first digital BO register – HARBOR (Hierarchical and Applicable Relations and Beneficial Ownership Registry); and
- expanded coverage and access through revised SEC regulations on BO disclosure.
Despite its initial success, the country is still facing implementation challenges including improving data verification mechanisms, data sharing, and enforcement. A new policy brief asserts that “the Philippines’ BO framework – while substantially advanced through phased regulatory reforms – remains structurally fragmented and operationally insufficient without a dedicated primary law.”
The Congressional Policy and Budget Research Department, the primary think tank of the House of Representatives, has now set out the case for the next step: a dedicated primary law that would consolidate the Philippines' BO framework into a single, durable statute. Their brief sets out recommendations across the full legislative architecture — from definitions and thresholds to verification, tiered access, sanctions, and inter-agency coordination. It draws extensively upon Open Ownership’s Opening Extractives scoping report and Guide to Drafting Effective Legislation for Beneficial Ownership Transparency to identify gaps and develop country-specific recommendations.
Why is a beneficial ownership law important?
A well-designed legislative framework is the foundation of any BOT regime. Well-drafted legislation ensures clarity, enables compliance, and helps guarantee the sustainability of reforms by enabling them to withstand potential legal challenges.
A dedicated BOT law would do three things at once: unify a framework that is currently spread across multiple agencies and instruments; make BO data more usable across government — from tax to procurement to asset recovery; and better protect reforms against being weakened in future. For a country that has recently exited the FATF greylist, that durability matters.
The current regulations issued by the SEC are primarily based on the Revised Corporation Code and the Anti-Money Laundering Act. Hence, coverage is currently only limited to entities that the SEC regulates. A standalone BOT law would enhance implementation by providing an authoritative source for reporting obligations, expanding coverage, and improving BO data access. It could also strengthen the SEC’s role in improving compliance, data accuracy, and enforcement of sanctions - ensuring a whole-of-government approach in improving transparency.
Open Ownership, in partnership with the United Nations Office on Drugs and Crime and the Extractive Industries Transparency Initiative, has provided long-term technical assistance to the Philippines in implementing BOT reforms. Open ownership remains a key partner of the SEC and looks forward to supporting the upcoming legislative review and continuing to support the implementation of ambitious reforms that put the Philippines at the forefront of BOT globally.
