SEC Introduces GIS 2026 and New Beneficial Ownership Disclosure Process

The Securities and Exchange Commission (SEC) has announced significant updates to corporate disclosure requirements with the release of SEC Memorandum Circular No. 15, Series of 2025, paving the way for the full implementation of the Beneficial Ownership (BO) Disclosure Rules of 2026.

These changes aim to streamline corporate filings, improve transparency, and strengthen regulatory oversight—particularly in identifying the true owners and controllers of corporations.

What’s New: GIS Version 2026

As part of this initiative, the SEC has officially released General Information Sheet (GIS) Version 2026. While the overall structure and required information remain largely the same, there is one major change:

• The Beneficial Ownership Declaration (BOD) page has been removed from the GIS

Instead of submitting BO information within the GIS, corporations will now disclose Beneficial Ownership details through a separate, centralized system.

Introducing HARBOR: The New BO Disclosure Platform

All Beneficial Ownership information will now be submitted through the Hierarchical and Applicable Relations and Beneficial Ownership Registry (HARBOR).

Key points to note:

• HARBOR is integrated with the SEC’s Electronic Filing and Submission Tool (eFAST)

• BO disclosures are now handled separately from the GIS

• This allows the SEC to maintain a more structured, up-to-date Beneficial Ownership registry

Compliance Reminders for Corporations

To ensure compliance with the new rules, corporations should take note of the following requirements:

For Newly Registered Corporations

• Beneficial Ownership information must be submitted upon registration

For Existing Corporations

• Beneficial Ownership information must be submitted together with the next GIS filing

For Changes in Beneficial Ownership

• Any changes in BO information must be reported to the SEC within seven (7) calendar days

Important Effectivity Date

Starting 30 January 2026, all Beneficial Ownership Declaration (BOD) submissions must be filed exclusively through HARBOR, via its integration with eFAST.

The SEC has also indicated that additional guidelines on the BO Registry submission process will be released in due course.

Accessing GIS 2026 Forms

Corporations may already begin preparing for compliance by using the updated forms:

• GIS 2026 forms are available for download at: bit.ly/2026GISForms

The SEC encourages corporations to adopt the GIS 2026 form for their upcoming filings to ensure alignment with the new disclosure framework.

Final Thoughts

These updates mark an important step toward greater transparency and regulatory efficiency in corporate governance. Corporations are advised to review their Beneficial Ownership records early, prepare for HARBOR registration, and ensure internal processes are in place to meet the new reporting timelines.

Staying proactive will help avoid compliance issues as the Beneficial Ownership Disclosure Rules of 2026 come into full effect.