The Short Answer
A lending app may remind you, send Demand Letters, report to credit bureaus (companies that keep records of how people pay their loans) as the law allows, and sue you to collect. It may not threaten you, insult you, lie that you will be arrested, call at unreasonable hours, or message the people in your contact list other than the guarantors you named (people who agreed to pay if you do not). The Securities and Exchange Commission (SEC) bans these practices, and the Data Privacy Act bans using your contacts and photos to shame you. You still owe what you validly borrowed.
Example: Mark Santos and a ₱5,000 App Loan in Cainta
Names and details in this example are made up.
Mark Santos is a delivery rider in Barangay San Isidro, Cainta, Rizal. In July 2026 he borrowed ₱5,000 through a lending app, payable in 14 days. When he installed it, the app asked for access to his contacts and photos, and he tapped "Allow".
His motorcycle broke down, and he missed the due date by three days. The app began calling him from different numbers at 11:00 p.m. Then his mother in Iloilo, his supervisor, and his barkada group chat received messages with his photo: "Si Mark Santos ay scammer. Ayaw magbayad ng utang." One message to Mark said a "warrant" would be served at his house.
What was not allowed.
- Messaging his mother, supervisor and friends. None of them was a guarantor Mark named. Tapping "Allow" did not make this legal.
- Calling him a scammer and sending his photo to shame him.
- The fake warrant. Not paying a loan is not a crime, and only a judge issues a warrant.
- The 11:00 p.m. calls, since his account was less than 15 days past due and he had not agreed to calls at that hour.
What Mark did. He screenshotted everything and asked his mother and supervisor for screenshots too. He looked up the app on the SEC's list and found the company's registered name. He sent the company a letter by email, asked for his statement of account, offered to pay the ₱5,000 and the agreed charges in two weekly instalments, and demanded that it stop contacting third parties (other people). He then filed complaints with the SEC about the collection and with the National Privacy Commission (NPC) about the use of his contacts and photo.
What Mark still owes. The harassment does not cancel the loan. He still owes the ₱5,000 and the interest and charges he validly agreed to, so he keeps his payment receipts.
What the App May Lawfully Do
- Remind you of your due date and your balance, by text, call, email or in-app notice, at reasonable hours.
- Contact the guarantor or co-maker (the person who signed on to pay if you do not) you named in your loan application.
- Send a Demand Letter and charge the interest and penalties stated in your Loan Agreement and disclosure statement, within the limits the SEC sets.
- Report your account to credit bureaus as the law allows. This can affect future loans.
- Sue you to collect, usually through small claims. The court can order you to pay. It cannot jail you for the unpaid loan.
What the SEC Bans
SEC Memorandum Circular No. 18, Series of 2019 (SEC MC 18-2019) bans these unfair collection practices by lending and financing companies and the collectors they hire:
- using or threatening violence or other criminal means against you, your reputation or your property;
- threatening action that cannot legally be taken, such as arrest for an unpaid loan;
- using obscenities, insults or profanity;
- disclosing or publishing the names and personal information of borrowers who have not paid, except as the circular allows;
- spreading false information about your loan;
- pretending to be a lawyer, a court, the police or a government office;
- contacting you before 6:00 a.m. or after 10:00 p.m., unless the account is more than 15 days past due or you agreed to those hours; and
- contacting people in your contact list other than the guarantors or co-makers you named, even if you gave the app access.
The SEC can fine the company, suspend it, or revoke its certificate of authority (its license to operate). The SEC has also issued later rules on online lending platforms, including limits on interest and fees for small, short-term loans. Ask the app for your disclosure statement, which must show the total cost of the loan.
Your Phone Data and the Data Privacy Act
Under the Data Privacy Act, Republic Act No. 10173 (RA 10173), and the NPC's rules on loan-related transactions (NPC Circular No. 20-01, as amended by NPC Circular No. 2022-02):
- A lending app may ask only for the phone permissions it actually needs.
- Using your contact list to collect from anyone other than your named guarantor, or to harass you or your contacts, is prohibited.
- Your photos may be used to check your identity, but never to harass or embarrass you.
- A character reference you listed is not a guarantor and should not be asked to pay.
Contact-list shaming, posting your photo, or calling you a scammer in group chats can be both an SEC violation and a data privacy violation. See data privacy complaints.
Check Whether the App Is Registered
A lending or financing company must be registered with the SEC and hold a certificate of authority, and its online lending platforms must be registered too. The SEC publishes lists of registered lending and financing companies and their apps, and lists of apps it has ordered to stop.
- Find the company's registered name, not just the app's brand. It is usually in the app's terms, the Loan Agreement or the disclosure statement.
- Search the SEC website for that company and app.
- If the app is not on the list, report it to the SEC as well.
Whether you must still pay an unregistered app depends on your specific case. Keep your records and get legal advice. The Public Attorney's Office helps people who qualify.
Where to Complain
In short: threats, insults, late-night calls, false claims and texting your contacts go to the SEC. Use of your contact list or photos, shaming posts and sharing your data go to the National Privacy Commission, after you write to the company's Data Protection Officer (see data privacy complaints). Threats of harm, fake legal notices and defamatory posts online (posts that damage your name) go to the PNP Anti-Cybercrime Group or the NBI Cybercrime Division. For a bank or credit card issuer, or its collection agency, complain to the bank first, then the Bangko Sentral ng Pilipinas (BSP).
Start with a written letter to the lending company, and keep proof you sent it.
For the steps and papers, see harassment by lending apps and debt collectors.
Common Questions
Pumayag Ako na I-access ng App ang Contacts Ko. Legal na ba na I-text Nila Sila?
No. SEC MC 18-2019 bans contacting people in your contact list other than the guarantors or co-makers you named, even if you allowed access. The NPC's rules also prohibit using your contact list to collect or to harass.
Can an Online Lending App Have Me Arrested?
Not for an unpaid loan. The Constitution says no one shall be imprisoned for debt. A text saying a warrant is coming is a false threat, which the SEC also bans. See can I go to jail for not paying a debt.
Can They Post My Photo on Facebook and Call Me a Scammer?
No. The SEC bans publishing borrowers' names and information to shame them, and the NPC's rules say your photos may never be used to harass or embarrass you. Screenshot the post with the date and the account, and complain to the SEC and the NPC.
If I Complain to the SEC, Do I Still Have to Pay?
Yes, a complaint does not cancel what you validly owe. It stops the harassment and can lead to sanctions against the company. You can dispute charges you think are wrong and ask for your statement of account.
How Do I Know If a Lending App Is Legitimate?
Look for the company's registered name and SEC Certificate of Authority in the app or Loan Agreement, then check the SEC's published lists of lending and financing companies and their registered apps.
Not legal advice. This is general information. For advice on your own situation, consult a lawyer. If you cannot afford one, the Public Attorney's Office (PAO) or an IBP legal aid office may help for free.
Government fees, rules and requirements change, so always check with the office concerned before you go. This page explains the general rules; it cannot tell you how they apply to your own family or case. Last reviewed October 8, 2026.