The PCC has resumed the 30-day deadline for filing compulsory merger notifications. Two new Memorandum Circulars (MC No. 26-003 and MC No. 26-004), published today, 18 September 2026, take effect on 3 October 2026. The key points are as follows:

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• Transactions signed on or after 3 October 2026 — parties must notify the PCC within 30 calendar days from the signing of definitive agreements.
• Transactions signed before 3 October 2026 — parties must notify the PCC no later than 1 January 2027.
• Failure to file within the prescribed period may result in administrative fines of up to PHP 2 million (~USD 32,000).
• The PCC is also transitioning to electronic filing as the exclusive mode of submission, effective 1 January 2027.

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What this means for your deals: If you are currently negotiating or expect to sign any transaction that exceeds the PCC's notification thresholds, please factor the 30-day filing deadline into your transaction timeline. For deals already signed but not yet notified, the 1 January 2027 deadline provides a limited window to prepare and submit your filings. The filing deadline is in addition to the standstill obligation.

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A more detailed bulletin may be downloaded at this link.

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