In May 2026 the SEC gave companies behind on their filings a temporary break: it suspended the monthly penalty that piles up for late or non-filed reportorial requirements. The relief comes through SEC Memorandum Circular No. 16, Series of 2026. It's a narrow, time-bound measure — useful if you're catching up on overdue filings, but easy to misread. Here's exactly what it does.
What's suspended
SEC penalties for late filing have a component that accrues per month of delay — the longer a filing sits unfiled, the more it grows. MC 16 suspends that monthly component. For the covered period, the per-month penalty isn't added on top of an overdue filing. This is the part that makes catching up far cheaper than it would otherwise be, especially for filings that have been outstanding for a long stretch.
Tip
The suspension targets the monthly-accrual portion of the penalty. Read the circular's text for exactly which charges are lifted before assuming a given assessment drops to zero — "suspended monthly penalty" is not the same as "no penalty at all."
The window
The relief is bounded by clear dates:
| Event | Date |
|---|---|
| Circular took effect | May 14, 2026 |
| Monthly penalty not imposed | May 14, 2026 – December 31, 2026 |
| Normal monthly penalty resumes | January 1, 2027 |
So there's a defined window — roughly mid-May through year-end 2026 — to bring overdue reportorial filings current without the monthly penalty accruing. Once 2027 begins, the per-month charge is back.
What it doesn't undo
This is the point companies most often get wrong: the suspension is forward-looking, not a refund. Monthly penalties that were already assessed and settled before May 14, 2026 stay final. You don't get them back, and you can't apply them as a credit. The circular relieves the period it covers — it doesn't reverse penalties you'd already paid.
For filings still outstanding, the SEC's Company Registration and Monitoring Department and its extension offices issue updated assessments that leave out the per-month delay component during the covered window. In practice that means the assessment you receive while catching up reflects the suspension automatically rather than requiring you to claim it.
What to do with the window
The sensible response is straightforward: if you have overdue reportorial filings — a General Information Sheet, financial statements, or similar — this is the cheapest moment in the near term to clear them. The monthly penalty stops growing during the window and returns in 2027, so getting current before year-end is the move that captures the relief.
Key takeaways
- MC 16 (2026) suspends the per-month delay penalty on late or non-filed SEC reportorial requirements.
- The suspension runs from May 14, 2026 to December 31, 2026; normal penalties resume January 1, 2027.
- Monthly penalties already assessed and settled before May 14, 2026 remain final — no refund or credit.
- Updated SEC assessments during the window exclude the monthly component, so it's the cheapest time to bring overdue filings current.
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