In late 2015, the Philippines Securities and Exchange Commission ("SEC") issued Amended Implementing Rules and Regulations of the Securities Regulation Code (“2015 IRR”) which effectively eliminated the requirement for issuers to submit a Notice of Exemption (via Form 10.1) for equity compensation grants to less than 19 employees in the Philippines within a 12 month period.

Previously, issuers could either file a Notice of Exemption or a Confirmation of Exemption but in releasing the 2015 IRR, the Philippine SEC eliminated all references to a Notice of Exemption (except for commercial papers) and only retained discussions on obtaining a Confirmation of Exemption.

Subsequent to the issuance of the 2015 IRR, the Commissioner of the Philippine SEC unofficially clarified the regulatory body's intent to eliminate the Notice of Exemption filing requirement (given that the 2015 IRR did not expressly state that issuers were not required to submit a Notice of Exemption) and proposed to issue a written circular to memorialize this clarification.