QAU Memo No. 18, s2021 : SEC Updates

NO. 3, SERIES OF 2019, NO. 4, SERIES OF 2020 and NO. 34, SERIES OF 2021

To: All Concerned

The Commission on various dates has issued the following MCs relative to the pronouncements by the Philippine Interpretations Committee (PIC) and International Financial Reporting Interpretations Committee (IFRIC) on the implementation of PRFRS 15, Revenue from Contract with Customers:




SEC MC No. 14, Series of 2018

Deferral of the application of the provisions of PIC Q&A No. 2018-12 with respect to the accounting for significant financing component, and the treatment of uninstalled materials and land in the calculation of the percentage of completion (POC) for a period of three (3) years.

29 October 2018

SEC MC No. 3, Series of 2019

Deferral of PIC Q&A 2018-12(H) on Accounting for Common Usage Service Area (CUSA) Charges and PIC Q&A 2018-14 on Accounting for Cancellation of Real Estate Sales until December 31, 2020.

08 February 2019

SEC MC No. 4, Series of 2020

Deferral of the Implementation of IFRIC Agenda Decision on Over Time Transfer of Constructed Goods [Philippine Accounting Standards (PAS) 23-Borrowing Cost] for the Real Estate Industry until December 31, 2020.

21 February 2020

SEC MC No. 34, Series of 2020

Deferral of PIC Q&A 2018-12 and IFRIC Agenda Decision on Over-Time Transfer of Constructed Goods (PAS 23- Borrowing Cost) for the Real Estate Industry for Another Period of Three (3) Years or Until 2023.

17 December 2020

In connection to this, the Commission in its meeting, resolved the following:

  1. Approved the amendment to the transitional provisions in the above MCs that allows company to apply the provisions of the PIC and IFRIC pronouncements in either full retrospective approach or modified retrospective approach.
  2. Approved the option for companies to halt availing the above reporting reliefs whether in full or in part.

The aforementioned approvals aim to enable companies to fully comply with PFRS 15 and revert to reporting in full PFRS.

Issued July 8, 2021.

MC No. 08, S2021, MC No. 14, S2018, MC No. 03, S2019, MC No. 04, S2020, and MC No. 34, S2020


To: All Concerned

Please be informed that the Commission has extended the deadline for Corporations, Partnerships, and Individuals under the jurisdiction and supervision of the Commission to comply with SEC Memorandum Circular No. 28, series of 2020, without penalty, until August 31, 2021.

You may file the forms/notices of the MC 28, s. 2020 online through the email platform MC28_S2020 [at] sec [dot] gov [dot] ph.

Filing of the forms/notices beyond August 31, 2021 shall be considered as non-compliant and will be subject to penalty in the amount of P10,000.00.

For your guidance.

Effective July 15, 2021.

MC No. 28, s 2020:

SEC Notice:


QAU Memo is the official publication of R.S. Bernaldo & Associates to keep the Firm’s professional staff informed of the issues affecting the practice. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.    

The Firm cannot be held liable for any losses suffered as a result of reliance upon information contained in this memo.

This is a property of R.S. Bernaldo & Associates. Reproduction of any material included in the memo should be subject to the approval of the Editorial Board.

R.S. Bernaldo & Associates is a member firm of the PKF International Limited family of legally independent firms   and does not accept any responsibility or liability for the actions or inactions of any individual member or correspondent firm or firms.

Comments and suggestions are welcome.

Editorial Board    
  • Anthony D. Paño

Partner | Head of QAU/

anthony [dot] pano [at] rsbernaldo [dot] com


  • Mary Rose A. Lorilla

Assistant Quality Assurance Manager/

Quality Assurance Leader

rose [dot] lorilla [at] rsbernaldo [dot] com


  • Charmaine S. De Guzman

Senior Auditor/ Assistant Quality Assurance Leader

charmaine [dot] deguzman [at] rsbernaldo [dot] com


  • Baby Joy A. Bautista

Quality Assurance Associate/ Engagement Quality Control
Review Leader

babyjoy [dot] bautista [at] rsbernaldo [dot] com


  • Sandae E. Dela Torre

Quality Assurance Associate/

Ethics Leader

sandae [dot] delatorre [at] rsbernaldo [dot] com


  • Janna J. Pacis

Quality Assurance Associate/

Learning and Training Leader

janna [dot] pacis [at] rsbernaldo [dot] com


  • Yves Michael O. Anadon

Quality Assurance Associate/

Consultation Leader

yvesmichael [dot] anadon [at] rsbernaldo [dot] com