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Philippine Amusement and Gaming Corporation — Philippines online-gambling standards explorer (PD 1869 PAGCOR Charter, RA 9487 extension, EO 13/2017 regulatory clarification, PIGO RegFramework 2020, IGL Rules 2023, EO 74/2024 POGO ban, RA 10927 + RA 11521 AMLA casino cover, PAGCOR Responsible Gaming Framework, Anti-Online Gambling Bill 2025)
All 266 Philippine standards, organised by theme
A searchable, filterable index of the Philippines' online-gambling rulebook, drawn from Presidential Decree 1869 (the PAGCOR Charter of 1983), Republic Act 9487 of 2007 (Charter extension to 2033), Executive Order 13 of 2017 (regulatory clarification), the PAGCOR Philippine Inland Gaming Operator (PIGO) Rules and Regulations of 2020, the Internet Gaming Licensee (IGL) Rules of 2023, Executive Order 74 of 2024 (the Marcos order abolishing POGO and IGL operations by 31 December 2024), Republic Act 9160 as amended by Republic Acts 10927 and 11521 (the Anti-Money Laundering Act covering casinos including internet-based and ship-based), the PAGCOR Responsible Gaming Framework, and the pending Anti-Online Gambling Bill of 2025 (Senate Bill 2868 and counterpart House Bills). Standards are grouped by theme, tagged editorially and deep-linkable.
Editorial summary, not legal advice. Every card on this page is a plain-English summary of the regulator's own rule, cross-checked against the primary source. Always verify against the published text before filing, launching, or advising.
The Philippines vests both regulator and state-operator functions in a single corporation. PAGCOR's authority flows from a 1983 Marcos-era presidential decree, was extended to 2033 by RA 9487 in 2007, and was clarified (without separation) by EO 13 of 2017 — leaving the dual role intact.
24 standards7 player-flagged
29%
player-flagged
Regulatory risks this theme addresses
Operating any game of chance without PAGCOR authority or a special law (e.g. PCSO, games and amusements board)
Confusing PAGCOR's regulatory and operator hats when negotiating licence terms or compliance audits
Treating the 2033 Charter sunset as remote — major licence terms increasingly reference Charter expiry
Charter & corporate mandate 3
PD 1869 sec. 8
PAGCOR franchise and territorial jurisdiction
Player Rights
Presidential Decree 1869 of 1983 (the consolidated PAGCOR Charter) grants the Corporation the franchise to operate and license games of chance throughout the Philippines, on land and water within Philippine territorial jurisdiction. The franchise is exclusive within its scope, subject only to other special laws (notably the PCSO charter for lotteries).
Requirements
Operate or license games of chance only inside Philippine territorial jurisdiction under this franchise
Acknowledge PCSO's parallel mandate for lotteries and sweepstakes
Treat the Charter as the constitutive source of PAGCOR's regulatory and operator capacity
Map every licence product back to a franchise basis under PD 1869
PD 1869 consolidated PD 1067-A, 1067-B, 1067-C, 1399 and 1632 into a single instrument and is the foundational reference for every downstream PAGCOR rule.
PD 1869 sec. 13
Corporate powers and dual regulator-operator role
Player Rights
Section 13 of PD 1869 vests PAGCOR with the powers to regulate, operate, authorise and license games of chance and to centralise and integrate the right and authority to operate gambling. The same provision is the legal source of the dual regulator-operator role that international observers and the IMF have repeatedly flagged as a structural conflict.
Requirements
Recognise PAGCOR as simultaneously regulator, licensor and competing operator (Casino Filipino brand)
Apply the Corporation's own conflict-management protocols when an operator competes with PAGCOR-run venues
File all gaming-operation applications via the regulatory branch even when subject is a PAGCOR-operated site
Reference PD 1869 sec. 13 as the statutory basis when documenting fit-and-proper challenges
Long-running policy debates about privatisation of PAGCOR's operator arm have not changed the statute; sec. 13 remains in force.
PD 1869 sec. 14
Prohibited classes of casino patrons
RG CriticalPlayer Rights
Section 14 of PD 1869 bars specific classes of persons from entering PAGCOR-licensed casinos: government officials connected with the gaming operation, members of the Armed Forces of the Philippines including the Philippine National Police, directors and employees of PAGCOR, Filipinos under 21 years of age, and persons financially incapable of betting. Foreign nationals are admissible from age 18.
Requirements
Verify patron age 21+ for Filipino citizens and 18+ for foreign nationals at every entry point
Refuse entry to AFP, PNP and PAGCOR personnel even on personal time
Refuse entry to schoolteachers and other prohibited public officials where prescribed
Maintain a documented denial-of-entry log auditable by PAGCOR inspectors
The age-21 floor for Filipinos is one of the strictest in Asia and is reinforced by the PIGO online rule that all account holders must be at least 21.
Charter extension & regulatory clarification 4
RA 9487 sec. 1
Charter extension to 2033
Player Rights
Republic Act 9487 of 20 June 2007 amended PD 1869 by extending the PAGCOR franchise for a further 25 years from its expiry on 11 July 2008, taking the Charter to 11 July 2033. The Act also expanded PAGCOR's authority to enter into joint ventures and licensing arrangements with private parties.
Requirements
Treat 11 July 2033 as the current Charter sunset for all long-tenor product, investment and licensing planning
Reference RA 9487 (not the Marcos-era PD alone) when relying on the joint-venture authority
Build contractual exit and successor-regime clauses into any licence stretching past 2030
Track legislative efforts to further extend or restructure the Charter
RA 9487 is the live legal basis for PAGCOR's licensing of integrated resort casinos in Entertainment City and Clark.
EO 13 (2017) sec. 2
Regulatory clarification on illegal gambling
Player Rights
Executive Order 13 of 2 February 2017 strengthened the fight against illegal gambling and clarified PAGCOR's regulatory jurisdiction over gaming operations under its franchise, including offshore gaming activities. The EO instructed the Department of Justice, the PNP, the NBI and PAGCOR to coordinate enforcement against unauthorised gambling.
Requirements
Coordinate enforcement intelligence between PAGCOR Gaming Licensing and Enforcement, DOJ, PNP and NBI
Treat any unauthorised online gambling targeted at Philippine residents as illegal under EO 13
Reference EO 13 when supporting takedown or domain-blocking requests against unlicensed sites
File regular enforcement reports to the Office of the President as the EO requires
EO 13 did not separate PAGCOR's operator and regulator hats; multiple administrations have since debated but not enacted a structural split.
PAGCOR Fit & Proper Rule
Shareholder and key-personnel vetting
Player Rights
Every PAGCOR licensee must clear a fit-and-proper test covering ultimate beneficial owners holding five percent or more, directors, the CEO, the Chief Compliance Officer and the AML Compliance Officer. Vetting includes police clearance, NBI clearance, BIR tax compliance and AMLC look-back.
Requirements
Submit NBI and police clearances for every UBO at five percent or above and every key officer
Disclose every change in beneficial ownership above the threshold within 15 days
Maintain a current AML Compliance Officer registered with PAGCOR
Refresh fit-and-proper documentation at licence renewal
PAGCOR Reg. 1-2020
Licence classes and product perimeter
Player Rights
PAGCOR licences are issued by product category: land-based integrated resort casino, PAGCOR-operated Casino Filipino, e-Games (PeGS) cafes, e-Bingo halls, specialty games, PIGO domestic online and (historically) POGO/IGL offshore. Each class has its own rule set; cross-class operation requires separate authorisations.
Requirements
Apply for a separate authorisation per product class even where the operator group is identical
Map every product variant to its rule set before launch (PIGO, IGL, PeGS, e-Bingo, Specialty)
File change-of-product notifications via the Gaming Licensing and Development Department
Maintain a perimeter matrix in the compliance manual reconciling SKUs to authorisations
PD 1869 — Corporate structure & governance 3
PD 1869 sec. 3
Corporate name and juridical personality
Section 3 of PD 1869 establishes PAGCOR as a government-owned and -controlled corporation with a separate juridical personality, the power to sue and be sued, and the capacity to enter into contracts in its own name. This independent personality is what allows PAGCOR to license, contract with private operators and remit to the National Treasury without channelling through a line department.
Requirements
Contract with PAGCOR in its own corporate name, not via the Office of the President or DOF
Serve legal process at PAGCOR's principal office for any licensee dispute
Treat PAGCOR resolutions as acts of a corporate body, not executive issuances
File all licensing-related litigation against PAGCOR, not the Republic of the Philippines
PD 1869 sec. 4
Board of Directors composition
Section 4 of PD 1869 constitutes PAGCOR's Board of Directors with a Chairman and four Members appointed by the President of the Philippines. The Chairman concurrently serves as Chief Executive Officer, fusing oversight and management in a single appointee — a structural feature carried through every charter amendment.
Requirements
Recognise the Chairman-CEO as the principal decision-maker on licensing matters
Engage all five Board members for matters requiring Board resolution
Track presidential reappointment cycles when planning multi-year licence applications
Disclose any prior or pending PAGCOR Board relationship in fit-and-proper filings
The fused Chairman/CEO role is one of the governance features international observers cite alongside the regulator-operator duality.
PD 1869 sec. 5
Powers of the Board
Section 5 of PD 1869 vests the Board with the power to promulgate rules and regulations to implement the Charter, fix the salaries and benefits of personnel, appoint officers, and adopt by-laws. The rule-making power is the legal source of every PAGCOR Regulation, Circular and licence condition issued since 1983.
Requirements
Trace every PAGCOR rule, regulation and circular back to a sec. 5 board resolution
Submit any challenge to a PAGCOR rule via the Board, not the line department
Recognise PAGCOR's by-laws as binding internal governance
Reference sec. 5 as the rule-making source when documenting compliance obligations
PD 1869 — Franchise scope 3
PD 1869 sec. 9
Regulatory and supervisory authority
Section 9 of PD 1869 grants PAGCOR full regulatory and supervisory authority over every games-of-chance operation conducted under its franchise, including the right to enter, inspect and audit any licensed premises at any time without prior notice. The provision underpins PAGCOR's no-notice inspection power and shift-level oversight presence.
Requirements
Permit PAGCOR inspectors to enter and audit licensed premises at any time without prior notice
Maintain inspection-ready records, surveillance feeds and CDD files at every site
Provide PAGCOR inspectors with on-demand access to gaming-management systems
Treat refusal to allow inspection as an immediate ground for sanction
PD 1869 sec. 10
Gaming sites and jurisdictional limits
Section 10 of PD 1869 authorises PAGCOR to establish and operate gaming sites within Philippine territorial jurisdiction, on land and water, and to license private operators to do the same. Selection of a site requires Board approval and may be subject to host local-government coordination, though the Charter places ultimate jurisdiction with PAGCOR.
Requirements
Locate every gaming site within Philippine territorial jurisdiction including territorial waters
Obtain explicit PAGCOR Board approval for each gaming site before commencement
Coordinate with the host LGU on permits while recognising PAGCOR's primary jurisdiction
Map every floor extension or satellite venue back to a Board-approved site authorisation
PD 1869 sec. 11
Scope of franchise and licensing power
Section 11 of PD 1869 defines the scope of the PAGCOR franchise to include every game of chance and game of skill with a wagering component, with the express power to license, operate, authorise and contract for such games. This is the textual source of PAGCOR's authority to license e-Games, e-Bingo, sports betting and the modern online classes.
Requirements
Treat sec. 11 as the franchise textual basis for any new product class PAGCOR introduces
Document franchise-scope conformity when launching a novel product or wager type
Reject any third-party assertion that a wager-bearing product falls outside PAGCOR's authority
Reference sec. 11 alongside sec. 8 when filing licence applications
PD 1869 — Franchise term & exemptions 6
PD 1869 sec. 12
Twenty-five year franchise term
Section 12 of PD 1869 originally granted PAGCOR a 25-year franchise from 11 July 1983, expiring 11 July 2008. RA 9487 extended the term by a further 25 years to 11 July 2033, and the section remains the legal anchor for the sunset date used in every long-tenor licence and joint-venture agreement.
Requirements
Treat 11 July 2033 as the current statutory sunset for franchise-dependent rights
Embed Charter-expiry contingency language in any commercial agreement past 2030
Track legislative bills proposing a further extension or restructure
Reference both PD 1869 sec. 12 and RA 9487 when documenting the term
PD 1869 sec. 13(1)
Five-percent franchise tax in lieu of all taxes
Section 13(2) of PD 1869 imposes a franchise tax of five percent of gross revenue from gaming operations, payable to the National Government in lieu of all kinds of taxes, levies, fees and assessments of any kind. The in-lieu-of-all-taxes clause has been the subject of decades of litigation with the Bureau of Internal Revenue and remains the foundational fiscal feature of PAGCOR licensees' revenue model.
Requirements
Compute and remit the five-percent franchise tax on gross gaming revenue to the National Government
Apply the in-lieu-of-all-taxes treatment to gaming income (BIR jurisprudence on non-gaming income is separate)
Maintain a class-by-class GGR ledger reconciling to the franchise-tax filing
Track Supreme Court rulings on the scope of the in-lieu-of-all-taxes clause
BIR has historically pushed to subject non-gaming income (F&B, hotel) to ordinary corporate income tax; gaming-revenue treatment remains under the franchise tax.
PD 1869 sec. 13(2)(a)
Customs and import-duty exemption on gaming equipment
PD 1869 exempts PAGCOR from customs duties, taxes and assessments on the importation of gaming equipment, vessels, supplies and accessories used in gaming operations. The exemption flows to private licensees only where contractually conferred; in practice integrated-resort operators import slot cabinets, table-game equipment and live-dealer hardware against PAGCOR's exempt account.
Requirements
Route gaming-equipment imports through the PAGCOR exempt account where the licence permits
Maintain documentary support for every exempt importation for BOC and BIR review
Apply ordinary customs duties to non-gaming items (F&B, hotel) that fall outside the exemption
File supplemental declarations for any post-clearance discovery
PD 1869 sec. 13(2)(b)
Income-tax exemption for PAGCOR gaming income
Gaming income earned by PAGCOR itself is exempt from corporate income tax under PD 1869, with the five-percent franchise tax operating in substitution. RA 9337 in 2005 attempted to remove the exemption; the Supreme Court restored it in PAGCOR v. BIR (G.R. No. 172087, 2011) for gaming income only, leaving non-gaming income subject to regular corporate income tax.
Requirements
Treat PAGCOR gaming income as exempt from corporate income tax; pay only franchise tax
Subject PAGCOR non-gaming income (F&B, hotel, lease) to regular corporate income tax
Apply PAGCOR v. BIR (G.R. 172087, 2011) when characterising income lines
Refresh tax position whenever the SC revisits the boundary between gaming and non-gaming
PD 1869 sec. 13(4)
Fifty-percent net-income remittance to the National Government
Section 13(4) of PD 1869 requires PAGCOR to remit fifty percent of its net earnings to the National Government as a direct contribution to the General Fund, separate from the five-percent franchise tax. The remittance is the principal mechanism by which gaming revenue feeds the national budget alongside the BIR-collected franchise tax.
Requirements
Remit fifty percent of net earnings to the National Government on the Charter schedule
Treat the remittance as separate from and additional to the five-percent franchise tax
Reconcile the net-earnings calculation to audited PAGCOR financials
Account for the remittance as a charge against retained earnings, not an operating expense
PD 1869 sec. 13(5)
Charitable allocations and Cultural Fund
PD 1869 earmarks portions of PAGCOR's net income for charitable, civic and cultural purposes including allocations to the Philippine Sports Commission, the Board of Claims, the Cultural Centre of the Philippines and various social-welfare programmes. The earmarks are a long-standing source of public-interest justification for the PAGCOR monopoly.
Requirements
Apply the Charter earmarks to PAGCOR net income before discretionary use
Document recipient-by-recipient allocation in audited disclosures
Recognise that the social-purpose framing limits political appetite to dilute the franchise
Track legislative proposals that reroute earmarks (e.g. to specific local governments)
PD 1869 — Corporate audit & accounting 3
PD 1869 sec. 15
Auditor and accounting system
Section 15 of PD 1869 places PAGCOR under the audit jurisdiction of the Commission on Audit and requires the Corporation to maintain an accounting system conforming to government auditing standards. COA resident auditors sit inside PAGCOR and review every disbursement, including remittances to the National Treasury and licensee receipts.
Requirements
Cooperate with COA resident auditors on every disbursement and receipt cycle
Maintain accounting records aligned to government auditing standards
Reconcile licensee remittances to PAGCOR's COA-audited revenue ledger
Treat COA findings on licensee receivables as authoritative for collection follow-up
PD 1869 sec. 16
Annual report to the President
Section 16 of PD 1869 requires PAGCOR to submit an annual report on its operations, finances and remittances to the President of the Philippines and to Congress. The annual report is the principal public-facing accountability document for the franchise and is the source of GGR, remittance and licence-count time series cited by analysts.
Requirements
Treat the PAGCOR annual report as the authoritative GGR and remittance dataset
Cross-reference licensee filings to the PAGCOR annual report for industry benchmarking
Track late or delayed reports as a signal of governance friction
Reference the annual report when documenting market sizing for investors
PD 1869 sec. 17
Exemption from Civil Service and salary standardisation
Section 17 of PD 1869 exempts PAGCOR personnel from the Civil Service Law and from the Salary Standardisation Law, allowing the Corporation to fix compensation on a commercial basis. The exemption has historically been justified by the need to attract gaming-industry talent and remains in force through every Charter amendment.
Requirements
Recognise that PAGCOR sets its own personnel compensation outside the SSL
Apply commercial recruitment terms when sourcing PAGCOR-aligned roles
Engage PAGCOR HR rather than the CSC on personnel disputes
Track legislative proposals to bring PAGCOR within the SSL
RA 9487 — Charter extension provisions 2
RA 9487 sec. 2
Expanded joint-venture authority
Section 2 of RA 9487 expanded PAGCOR's authority to enter into joint ventures, management contracts and similar arrangements with private parties for the operation of gambling casinos and other gaming activities. The provision is the legal basis for the Entertainment City integrated-resort model where private operators run venues under PAGCOR-issued licences.
Requirements
Document every IR or casino joint venture against the RA 9487 sec. 2 grant
Reflect PAGCOR's joint-venture and management-contract powers in commercial structuring
Recognise that licence-fee and revenue-share arrangements derive from this authority
Reference RA 9487 sec. 2 alongside PD 1869 sec. 11 in joint-venture filings
RA 9487 sec. 3
Congressional oversight committee
RA 9487 created a Congressional Oversight Committee on PAGCOR composed of members of the Senate and House of Representatives. The Committee receives periodic reports on PAGCOR operations, remittances and licensing and is the legislative channel through which Charter amendments and policy adjustments are surfaced.
Requirements
Track Congressional Oversight Committee hearings for forward-looking regulatory signals
Provide PAGCOR with timely information needed for its oversight-committee filings
Engage Committee members through proper public channels on policy proposals
Reference Committee hearings as primary sources when documenting industry policy positions
2
Theme 2
PIGO — domestic online gaming
The Philippine Inland Gaming Operator framework, launched in 2020 to legalise remote play during the pandemic, is the only sanctioned route for taking online wagers from players physically inside the Philippines. PIGO authorisations are extensions of an existing land-based licence and carry hard geo-fencing.
13 standards13 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Accepting wagers from players physically outside Philippine territory under a PIGO authorisation
Operating a PIGO product without an underlying land-based licence to extend from
Using unaccredited Authorised Service Providers for platform, game content or payments
Authorisation & licence classes 3
PIGO RegFramework rule 1.1
PIGO as extension of land-based licence
Player Rights
The PIGO Rules and Regulations issued in September 2020 grant existing PAGCOR-licensed integrated resort casino operators, PAGCOR-operated venues and accredited e-Games licensees the ability to extend offerings to the online channel for Philippine-resident players. PIGO is not a standalone licence; it is an authorisation layered on top of a land-based permit.
Requirements
Hold a current PAGCOR land-based or e-Games licence before applying for a PIGO authorisation
Surrender the PIGO authorisation automatically if the underlying land-based licence is suspended or revoked
Operate the PIGO product under the same corporate entity holding the land-based licence
File the PIGO operations manual and platform topology with PAGCOR
This architectural choice locks PIGO market entry to incumbents and is the principal reason no greenfield online-only operator can lawfully serve Philippine residents.
PIGO RegFramework rule 2.3
PIGO product classes
Game Design
PIGO authorisations are scoped by product class: Sports Betting, e-Casino (table games and slots), e-Bingo and Specialty Games. Live dealer content streamed from a PAGCOR-approved studio falls inside e-Casino. Each class requires a separate PAGCOR approval and corresponding technical certification.
Requirements
Apply per product class; do not launch e-Casino on a Sports Betting authorisation
Stream live dealer only from a PAGCOR-approved studio inside the Philippines
Submit a separate game-launch certification for each new title within the class
Maintain a class-by-class revenue ledger for PAGCOR remittance
PIGO RegFramework rule 4.2
Mandatory Philippine geo-fence
Player Rights
PIGO licensees may only accept wagers from natural persons physically located within Philippine territory at the moment of the transaction. Operators must deploy geo-location verification at registration, log-in and every wager, and must block any IP geolocated outside the Philippines.
Requirements
Verify player location at registration, log-in and every wager using IP plus secondary geo signals
Block all sessions geolocated outside Philippine territorial waters and airspace
Retain geo-location logs for at least five years for PAGCOR audit
Self-report any material geo-fence breach within 72 hours
PAGCOR has cited geo-fence failures as a ground for PIGO authorisation suspension in 2023-2024 enforcement actions.
Service Provider accreditation 2
PIGO RegFramework rule 6.1
Authorised Service Provider accreditation
Player Rights
Every B2B vendor supplying platform, game content, RNG, live dealer studio, payment processing or KYC to a PIGO licensee must hold a PAGCOR Authorised Service Provider (ASP) accreditation. Accreditation is by service category and requires technical certification by a PAGCOR-recognised testing laboratory.
Requirements
Source platform, content, RNG, studio, payment and KYC services only from accredited ASPs
Update the PAGCOR ASP register within 15 days of any change of supplier
Hold testing-lab certificates on file for every game and platform version live
Contractually pass-through PAGCOR audit rights to every ASP
PIGO RegFramework rule 7.4
Licensee server and data residency
Player Rights
Primary gaming servers, player account databases and transaction logs for a PIGO product must be hosted on infrastructure physically located within the Philippines. Disaster recovery sites may sit outside the country provided the primary stays in-country and PAGCOR has live read access.
Requirements
Host production gaming servers and player account databases inside the Philippines
Provide PAGCOR with on-demand read access to live wager and account data
Document and pre-clear any disaster-recovery site outside the country
Maintain a network topology diagram annually refreshed and lodged with PAGCOR
PIGO Licence Conditions 5
PIGO RegFramework rule 13.2
Regulatory fee and GGR share remittance
Player Rights
PIGO licensees must remit a regulatory fee calculated as a percentage of gross gaming revenue to PAGCOR on a monthly cycle, with reconciliation filings due on the 15th of the following month. Late remittance accrues interest and may trigger suspension under rule 14.1.
Requirements
Reconcile monthly GGR per product class against the PAGCOR remittance return
Submit GGR returns and remit the regulatory share by the 15th of the following month
Track and pay interest on any late remittance
Retain remittance and reconciliation records for at least five years
PIGO RegFramework rule 14.1
Suspension, revocation and show-cause procedure
Player Rights
PAGCOR may suspend or revoke a PIGO authorisation on grounds including geo-fence breach, AML failure, technical-standard non-conformance, late remittance of regulatory fees or fit-and-proper degradation. The licensee is entitled to a show-cause notice and a hearing before the PAGCOR Adjudication Committee, except in cases of imminent player harm where summary suspension is available.
Requirements
Respond to PAGCOR show-cause notices within the prescribed reply window
Suspend operations immediately upon receipt of a summary-suspension order
Preserve all wager, account and audit data while a sanction proceeding is open
Exhaust the PAGCOR Adjudication Committee process before any judicial appeal
PIGO RegFramework rule 3.1
PHP 100M minimum paid-up capital
Player Rights
An applicant for a PIGO authorisation must demonstrate a minimum paid-up capital of PHP 100 million inside the corporate entity that holds the underlying PAGCOR land-based licence. Capital must be unencumbered, fully subscribed and verified by audited financial statements lodged with PAGCOR at application and at each renewal.
Requirements
Maintain at least PHP 100 million in unencumbered paid-up capital throughout the PIGO authorisation term
Submit audited financials evidencing capital at application and at every renewal
Notify PAGCOR within 15 days of any capital reduction or material encumbrance
Top up capital within 30 days of any breach of the minimum
The PHP 100M floor is in addition to the capital posted under the land-based licence and is intended to prove the operator can fund player wallets, segregation accounts and incident response without parent guarantees.
PIGO RegFramework rule 3.4
Land-based anchor requirement
Player Rights
A PIGO authorisation may only be granted to an entity already operating, or under firm commitment to operate, a PAGCOR-licensed land-based gaming venue inside the Philippines. The land-based anchor must be operational and revenue-generating within the term of the PIGO authorisation; failure to bring the anchor online voids the PIGO.
Requirements
Maintain a continuously operating PAGCOR-licensed land-based venue while the PIGO is active
Notify PAGCOR within 5 days of any closure, suspension or change of status of the land-based anchor
Cease PIGO operations within 24 hours if the underlying land-based licence is suspended or revoked
Document the corporate identity between PIGO holder and land-based licensee in every renewal filing
PIGO RegFramework rule 5.2
PIGO licence term and renewal
Player Rights
PIGO authorisations are issued co-terminus with the underlying land-based licence, subject to a maximum interim term of three years. Renewal applications must be filed no later than 90 days before expiry and require an updated technical audit, fit-and-proper refresh and proof of continuing PHP 100M capital.
Requirements
File renewal applications at least 90 days before the PIGO expiry date
Submit refreshed technical audit, fit-and-proper documentation and capital evidence at renewal
Treat the PIGO term as co-terminus with the land-based anchor licence
Cease taking new wagers once the authorisation expires without an approved renewal
Authorised Service Providers 3
PAGCOR ASP Reg sec. 11
ASP suspension and blacklist
Player Rights
PAGCOR maintains a register of suspended and blacklisted Authorised Service Providers. PIGO and land-based licensees must remove a suspended or blacklisted provider from production within 24 hours of notification and substitute an accredited provider before resuming the affected service.
Requirements
Subscribe to PAGCOR ASP register updates and act on suspensions within 24 hours
Document substitution to an alternate accredited ASP before resuming service
Notify affected players of any service interruption caused by ASP removal
Retain evidence of removal and substitution for PAGCOR review
PIGO RegFramework rule 6.3
ASP accreditation categories
Player Rights
PAGCOR Authorised Service Provider accreditation is granted by service category: gaming platform, game content and RNG, live dealer studio, payment processing, KYC and identity verification, geo-location, hosting and managed services, and customer support. Each category has its own fit-and-proper, technical and AML requirements, and a provider must obtain a separate accreditation per category it intends to deliver.
Requirements
Apply for ASP accreditation in every service category the provider will deliver
Maintain category-specific fit-and-proper, technical and AML documentation
Disclose any sub-contracting and ensure sub-contractors hold the correct ASP category
Re-apply if the scope of services expands into a category not previously accredited
PIGO RegFramework rule 6.5
Pass-through audit rights over ASPs
Player Rights
Every PIGO licensee contract with an Authorised Service Provider must include unrestricted PAGCOR pass-through audit and inspection rights, immediate access to source systems and data, and a step-in right enabling PAGCOR or the licensee to operate the service in an enforcement scenario.
Requirements
Insert PAGCOR pass-through audit, inspection and step-in clauses in every ASP contract
Ensure ASPs can deliver data and system access to PAGCOR on demand and without notice
Maintain an exit-and-continuity plan covering termination of any critical ASP
Review ASP contracts annually for clause currency and counterpart compliance
3
Theme 3
IGL & offshore-licensing post-EO 74
The Philippine offshore gaming sector — POGOs created in 2016, rebranded to IGLs in 2023 — was abolished by President Marcos's Executive Order 74 in late 2024. The framework remains relevant for run-off, residual tax liability under RA 11590, and the cross-border money-laundering and human-trafficking enforcement that followed the ban.
76 standards76 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Continuing any offshore gaming activity inside Philippine territory after 31 December 2024
Failing to settle outstanding RA 11590 5% gaming tax and 25% withholding tax on foreign employees
Underestimating cross-agency enforcement (BI deportations, BIR closures, PEZA blacklisting)
Offshore framework (historical) 1
RA 11590 sec. 11
POGO tax regime (historical)
Player Rights
Republic Act 11590 of 22 September 2021 imposed a 5 percent gaming tax on the gross gaming revenue of POGO licensees and a 25 percent final withholding tax on the gross income of every foreign individual employed by a POGO. The regime now applies only to residual liabilities crystallised before EO 74's closure deadline.
Requirements
Settle all 5% GGR gaming tax assessments outstanding on the closure date
Remit the 25% final withholding tax on foreign employee compensation for periods prior to cessation
Cooperate with BIR closure-audit programmes
Reference RA 11590 only for residual tax matters; the operating regime it taxed no longer exists
The RA 11590 tax framework was a key political pressure point: critics noted the macro tax take never materially exceeded social-cost externalities.
EO 74 ban & wind-down 2
EO 74 (2024) sec. 1
POGO and IGL prohibition
Player Rights
Executive Order 74, signed by President Ferdinand Marcos Jr. on 5 November 2024, prohibits all forms of Philippine Offshore Gaming Operations including those rebranded as Internet Gaming Licensees. PAGCOR was directed to cease issuing or renewing licences and to wind down all existing operations by 31 December 2024.
Requirements
Cease all offshore gaming operations inside Philippine territory on or before 31 December 2024
Surrender PAGCOR offshore authorisations and physical site permits by the deadline
Cooperate with BIR final tax assessments and PAGCOR exit audits
Do not solicit, accept or process any offshore wager from Philippine-based infrastructure post-deadline
EO 74 cited the social cost of POGO/IGL operations — human trafficking, financial crime and reputational harm — as the basis for outright prohibition rather than further restriction.
EO 74 (2024) sec. 3
Foreign employee deportation and utility shutoff
Player Rights
Section 3 of EO 74 directed the Bureau of Immigration to downgrade and cancel visas of foreign nationals employed by POGOs or IGLs, the Department of Labor to recall Alien Employment Permits, and the Department of Energy, Department of Information and Communications Technology and local government units to terminate utility, internet and lease services at known operator sites.
Requirements
Voluntarily repatriate foreign personnel ahead of BI downgrade actions
Cancel AEPs proactively to avoid blacklist consequences for the corporate group
Notify landlords, utilities and ISPs of cessation to avoid joint enforcement exposure
Document every step of the wind-down for future regulatory clearance applications
RA 12312 — Anti-POGO Act of 2025 10
RA 12312 sec. 3
Statutory definition of offshore gaming operations
Player Rights
Section 3 of Republic Act 12312 (the Anti-POGO Act of 2025) defines 'offshore gaming operations' as any internet- or telecommunications-based gambling activity conducted from within the Philippines or using Philippine-based infrastructure, personnel, payment rails or service providers, where the wagers are accepted from natural persons located outside the Philippines. The definition expressly captures rebranded successor models including Internet Gaming Licensees, Inland-Offshore hybrids and service providers whose principal economic activity supports an offshore gaming operator wherever incorporated.
Requirements
Treat any Philippine-territory infrastructure, personnel or payment leg that supports a cross-border wager as captured by the Act
Apply the prohibition to rebranded models including IGL successors and offshore service providers irrespective of place of incorporation
Do not rely on offshore-incorporation or holding-company structures to escape the definition
Map every cross-border touchpoint — KYC, payments, customer support, content streaming — against the Act's perimeter
The statutory definition deliberately broadens EO 74 by capturing the support-services economy (BPO-style back offices) that survived the 2024 executive ban.
RA 12312 sec. 4
Absolute prohibition on offshore gaming operations
Player Rights
Section 4 of RA 12312 imposes an absolute prohibition on the conduct, operation, facilitation, financing or hosting of offshore gaming operations anywhere in the Philippines. The prohibition is permanent — unlike EO 74, which could in principle be reversed by a successor executive order, RA 12312 requires repeal by Congress to be lifted. PAGCOR is statutorily barred from issuing any licence, accreditation or service-provider authorisation that would enable an offshore gaming operation.
Requirements
Cease and do not resume any offshore gaming operation regardless of any future PAGCOR rulemaking
Recognise that the prohibition cannot be lifted by executive action alone
Decline any business proposal premised on a 'restored' or 'restructured' POGO/IGL pathway
Withdraw any pending PAGCOR application or appeal predicated on an offshore model
RA 12312 sec. 5
Scope of prohibited persons and roles
Affiliate RulesPlayer Rights
Section 5 of RA 12312 extends criminal liability beyond operators to expressly named participant classes: directors, officers, employees and beneficial owners of any offshore gaming entity; landlords leasing premises knowing the intended use; banks, e-wallets and payment processors financing or settling the wagers; marketers, agents and influencers promoting the offering; and lawyers, accountants and corporate-service providers facilitating formation or maintenance. Knowledge or recklessness as to the prohibited use is required for non-principal participants.
Requirements
Screen tenants of leased premises for any offshore gaming connection before signing or renewing leases
Reject account openings, payment processing and e-wallet onboarding for entities with offshore gaming indicia
Decline marketing, affiliate or influencer engagements promoting any offshore offering targeting non-Philippine residents from Philippine infrastructure
Refuse corporate-service work (formation, secretarial, accounting) where the intended business is captured by the Act
The participant-class drafting mirrors AMLC guidance on professional enablers and is the principal new exposure for landlords, banks and law firms.
RA 12312 sec. 8
Criminal penalties for operators and principals
Player Rights
Section 8 of RA 12312 punishes any person operating, financing or maintaining an offshore gaming operation with imprisonment of reclusion temporal in its maximum period to reclusion perpetua (17 years and four months to 40 years), plus a fine of not less than PHP 10 million and not more than PHP 50 million per offence. Each day of continued operation after notice constitutes a separate offence.
Requirements
Recognise principal-operator exposure as a non-bailable, near-life-sentence offence at the upper band
Cease all operations on first notice to avoid per-day offence stacking
Treat PHP 10–50 million per-offence fines as the floor for corporate exposure modelling
Brief boards and senior management on personal criminal exposure independent of corporate liability
RA 12312 sec. 9
Criminal penalties for enablers and facilitators
Player Rights
Section 9 imposes lesser but still substantial penalties on non-principal participants — landlords, payment facilitators, marketers, professional advisers — of prision mayor (six years and one day to 12 years) plus a fine of PHP 5 million to PHP 20 million, where the participant knew or should have known the premises, services or funds were directed to an offshore gaming operation. Repeat violations elevate the offence to the principal-operator band.
Requirements
Document robust 'know-your-tenant', 'know-your-merchant' and 'know-your-client' diligence to rebut constructive-knowledge findings
Terminate exposed leases, accounts and engagements immediately on red-flag detection
Avoid second-offence escalation by maintaining an audit trail of prior compliance terminations
Train staff on the constructive-knowledge standard — 'should have known' is the prosecutorial pressure point
RA 12312 sec. 10
Aggravating circumstances — trafficking, minors, public officers
Player Rights
Section 10 elevates penalties to the maximum statutory band where the offshore gaming operation is connected to trafficking in persons under RA 9208 as amended, employs or victimises minors, is operated by or with the participation of a public officer, or involves laundering of proceeds of unlawful activity under the AMLA. Where the offender is an alien, deportation after service of sentence is mandatory and re-entry is permanently barred.
Requirements
Treat any indication of trafficking, minor involvement or public-officer participation as triggering maximum-band exposure
Cooperate with IACAT (Inter-Agency Council Against Trafficking) on any overlap investigation
Recognise mandatory post-sentence deportation and permanent re-entry ban for alien offenders
Map AMLA predicate-offence overlap when designing remediation programmes
RA 12312 sec. 12
Corporate sanctions — dissolution and SEC revocation
Player Rights
Section 12 of RA 12312 directs the Securities and Exchange Commission, on conviction of a corporation under the Act, to revoke its certificate of incorporation and dissolve the entity. Foreign corporations have their licence to do business in the Philippines cancelled. Successor entities formed by the same controlling persons within five years are presumed to be in violation of the Act.
Requirements
Recognise SEC dissolution as automatic on conviction with no discretionary path
Withdraw any foreign-corporation Philippine business licence proactively if exposure crystallises
Do not attempt to re-incorporate with overlapping beneficial ownership within five years
File final tax returns and BIR clearance ahead of SEC dissolution to preserve director clearance
RA 12312 sec. 14
Asset forfeiture and civil recovery
Player Rights
Section 14 authorises civil forfeiture of all proceeds, instrumentalities and property used in or derived from offshore gaming operations, including real property, vehicles, gaming equipment, cryptocurrency holdings and bank balances. AMLC may apply ex parte for asset preservation orders pending criminal conviction. Forfeited assets accrue to the National Treasury, with a portion earmarked for victim restitution and anti-trafficking programmes.
Requirements
Anticipate ex parte AMLC freeze and preservation orders on first enforcement notice
Maintain segregated records distinguishing offshore-linked from unrelated assets to support narrow forfeiture
Cooperate with AMLC tracing requests including cryptocurrency wallet attribution
Recognise that beneficial-owner real property and vehicles fall within the forfeiture perimeter
RA 12312 sec. 18
Repeal of RA 11590 POGO tax regime
Player Rights
Section 18 of RA 12312 expressly repeals Republic Act 11590 (the 2021 POGO Tax Law) effective with the Act's entry into force, save for residual liabilities crystallised on or before the effective date of EO 74. The repeal removes the 5 percent GGR gaming tax and the 25 percent final withholding tax on alien employee compensation as live revenue measures, leaving them operative only as historical assessment tools for BIR collection of pre-cessation tax debt.
Requirements
Treat RA 11590 as repealed prospectively — no forward tax planning is possible under the regime
Settle any residual pre-cessation 5% GGR and 25% alien-employee withholding tax assessments
Cooperate with BIR's POGO closure-audit and tax-mapping units on residual collections
Do not rely on RA 11590's 'in lieu of all other taxes' clause for post-effective-date periods
The repeal is symbolically important: Congress declined to keep a tax base for a prohibited activity, removing any fiscal incentive to revisit the prohibition.
RA 12312 sec. 22
Implementing Rules and Regulations (draft, Q1 2026)
Player Rights
Section 22 directs the Department of Justice, in coordination with PAGCOR, the Bureau of Immigration, the Bureau of Internal Revenue, AMLC, the Department of Information and Communications Technology, the Department of Labor and Employment, the NBI and the PNP, to issue Implementing Rules and Regulations within 90 days of the Act's effectivity. Draft IRR were released for public comment in Q1 2026; final consolidated IRR are pending publication in the Official Gazette as of 30 May 2026. Operational enforcement proceeds in the interim under the Act's self-executing criminal provisions.
Requirements
Monitor the Official Gazette and DOJ portal for publication of the final consolidated IRR
Apply the draft IRR as best-practice compliance baseline pending finalisation
Recognise that self-executing criminal provisions of RA 12312 are already enforceable without IRR
Submit comments and clarifications through the DOJ-IRR public consultation channel where exposure is unclear
Inter-agency drafting reflects the cross-cutting nature of the Act — no single regulator owns it, which slows IRR finalisation but broadens enforcement reach.
EO 74 inter-agency mechanics 4
EO 74 (2024) sec. 2
Inter-agency task force composition and mandate
Player Rights
Section 2 of EO 74 established an inter-agency task force chaired by the Executive Secretary and composed of PAGCOR, the Bureau of Immigration, the Bureau of Internal Revenue, the National Bureau of Investigation, the Philippine National Police, the Department of Labor and Employment, the Anti-Money Laundering Council, the Department of Information and Communications Technology and the Department of Justice. The task force coordinates physical-site shutdowns, deportation operations, tax assessments and ISP-level blocking of residual offshore platforms.
Requirements
Expect coordinated multi-agency action rather than single-regulator enforcement
Designate a single internal liaison for the task force across operational units
Pre-position documentation responsive to the most likely simultaneous demands (employment, tax, AML, ISP)
Track task-force public bulletins for emerging enforcement priorities
The chair sitting in the Office of the Executive Secretary signals presidential-level political backing and outranks any single agency-head pushback.
EO 74 (2024) sec. 4
Foreign-worker downgrade and deportation procedure
Player Rights
Section 4 of EO 74 directs the Bureau of Immigration to downgrade the visa status of every foreign national identified as a POGO/IGL worker, with a 59-day grace period to voluntarily depart, after which removal proceedings commence. The Department of Labor and Employment cancels the corresponding Alien Employment Permit; the Department of Foreign Affairs coordinates repatriation with sending-country embassies, particularly the People's Republic of China.
Requirements
Encourage voluntary departure inside the 59-day grace window to avoid blacklist consequences
Surrender corresponding AEPs proactively to DOLE to limit corporate-group exposure
Coordinate repatriation logistics with the relevant embassy ahead of BI's forced-removal track
Retain departure records for AMLC and BI compliance reporting
EO 74 (2024) sec. 5
Landlord, utility and ISP cooperation duties
Player Rights
Section 5 of EO 74 requires landlords leasing premises to identified POGO/IGL operators, electric and water utilities serving those premises, and internet service providers carrying their traffic, to cooperate with the task force in terminating leases, disconnecting services and blocking access on official notice. Non-cooperation triggers referral to the DOJ for prosecution as a co-conspirator in continued illegal operation; cooperation insulates the third party from successor-liability claims under the Act.
Requirements
Terminate leases, utility supply and ISP connectivity within the period stated in the official task-force notice
Retain the notice and proof-of-action file as a defence to successor-liability claims
Refuse to renew leases or re-supply services to any blacklisted operator or successor
Train property and operations managers on the cooperation-as-safe-harbour structure
EO 74 (2024) sec. 7
Asset disposition and gaming-equipment disposal
Player Rights
Section 7 of EO 74 directs PAGCOR, in coordination with the BIR and the Bureau of Customs, to inventory, seize and dispose of gaming equipment, servers, cryptocurrency mining rigs and ancillary infrastructure abandoned at decommissioned POGO/IGL sites. Equipment may be auctioned (where lawful resale outside the prohibited use is possible) or destroyed; proceeds flow to the National Treasury. Import duties and VAT on residual inventory are assessed against the licensee's bond.
Requirements
Inventory all gaming equipment, servers and crypto-mining infrastructure ahead of cessation
Coordinate lawful disposal with PAGCOR and the Bureau of Customs to avoid post-cessation seizure
Settle residual import-duty and VAT exposure on inventory against the operating bond
Retain disposal certificates as proof of compliance for any future re-entry application by group affiliates
Run-off enforcement (2024-2026) 3
BI Run-off Bulletin 2025
(run-off) Bureau of Immigration mass-deportation campaign
Player Rights
Through 2025 the Bureau of Immigration conducted rolling deportation operations against foreign nationals identified as former POGO/IGL workers who had overstayed the EO 74 grace period. Cumulative deportations exceeded 25,000 by mid-2025, the largest single-vector immigration enforcement programme in Philippine history. Sending countries — China, Vietnam, Indonesia, Malaysia — coordinated chartered flights with the Department of Foreign Affairs.
Requirements
Recognise that the BI run-off campaign extends well beyond the formal EO 74 deadline
Encourage any residual foreign personnel of group affiliates to surface voluntarily
Cooperate with sending-country embassies on chartered repatriation logistics
Document the absence of any remaining foreign POGO/IGL workforce in corporate compliance attestations
BIR RMO POGO Closure 2025
(run-off) BIR final POGO delinquency assessments
Player Rights
The Bureau of Internal Revenue's POGO closure-audit unit issued final delinquency assessments through 2025 covering pre-cessation 5 percent gaming tax under RA 11590, 25 percent withholding on alien employee compensation, regular corporate income tax on non-gaming revenues, VAT on service-provider invoicing and surcharges and interest. Tax-clearance certificates required for SEC dissolution and director clearance are conditional on settlement of these assessments.
Requirements
Engage proactively with the BIR POGO closure-audit unit on residual assessments
Settle or formally contest delinquency assessments before applying for SEC dissolution
Preserve documentation supporting deductions and exemptions claimed under RA 11590
Treat tax-clearance certification as the gating step for any director clearance
BIR has signalled it will not issue tax-clearance for any director seeking to operate in a new corporate venture until the POGO assessment is fully settled.
NBI Cybercrime POGO Case File 2025
(run-off) NBI Ponzi-overlay and trafficking investigations
Player Rights
Through 2024-2026 the NBI Cybercrime Division and Anti-Human Trafficking Division ran joint investigations into ex-POGO sites repurposed as crypto-investment Ponzi operations and pig-butchering scam hubs, often using the same foreign workforce held under conditions of debt bondage. Landmark raids at Bamban (Tarlac), Porac (Pampanga) and Pasay produced trafficking-in-persons indictments alongside RA 12312 enforcement.
Requirements
Recognise that the POGO/IGL workforce migration to scam hubs is the dominant residual enforcement vector
Cooperate with NBI joint Cybercrime + Anti-Human Trafficking investigations on any site connection
Treat former-POGO real estate as a high-risk diligence flag for any future tenancy or acquisition
Coordinate with IACAT on victim identification and witness protection
POGO Rules (historical) — Title I Policies and Objectives 3
POGO Rules sec. 1
(historical) Statement of policy centralising offshore gaming under PAGCOR
Player Rights
Section 1 declared that the Rules and Regulations for Philippine Offshore Gaming Operations were promulgated pursuant to the state policy of centralizing and integrating into one corporate entity all games of chance not heretofore authorized by existing franchises or permitted by laws. The provision anchored PAGCOR's exclusive franchise authority over offshore-facing internet gaming originating from the Philippines.
Requirements
Operated only under a PAGCOR-issued offshore gaming licence; no other Philippine franchise sufficed
Treated all unlicensed offshore online games of chance as outside the state-sanctioned franchise regime
Recognised PAGCOR as the sole integrating authority for offshore games of chance
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 2
(historical) Five licensing objectives of the offshore regime
Player Rights
Section 2 set five licensing objectives invoking PAGCOR's P.D. 1869 mandate: (a) curtail proliferation of illegal online games within Philippine territorial jurisdiction whether on land or sea; (b) ensure proper regulation and monitoring especially of operators using foreign franchises in fact operating outside the franchisor's territorial limits; (c) provide a legal pathway for operators absent any home regulator; (d) safeguard the welfare of the Filipino people by ensuring no Filipino, whether minor or of age, could place bets or be exploited; and (e) monitor that the games were not used to commit crimes or circumvent anti money-laundering laws.
Requirements
Operated only as the legal alternative to illegal online gaming inside Philippine jurisdiction
Demonstrated active monitoring against foreign-franchise operators bleeding into Philippine territory
Excluded all Filipino bettors (minor or of age) from the offered offshore games
Implemented AML and anti-crime monitoring tied to PAGCOR oversight
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 3
(historical) Offshore gaming licence as a mere privilege
Player Rights
Section 3 stated that an offshore gaming license was a mere privilege and not a vested right, and that the licence could be suspended or cancelled at any time at the discretion of the PAGCOR Board of Directors for grounds provided under the Rules. The provision foreclosed any due-process or contractual-rights argument against revocation.
Requirements
Treated the licence as discretionary, not vested
Accepted that PAGCOR Board discretion governed suspension and cancellation
Could not invoke vested-right doctrine against PAGCOR action
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules (historical) — Title II Definitions 4
POGO Rules sec. 4(a-c-d)
(historical) Definitions — Licensing Body, POGO and Licensee
Player Rights
Section 4(a) defined the Licensing Body or PAGCOR as the regulator of gaming licensees operating within the territorial jurisdiction of the Philippines whether on land or on sea. Section 4(c) defined Philippine Offshore Gaming Operators (POGO) as entities which provide and participate in offshore gaming services i.e. provide the game to players, take bets and pay players' winnings. Section 4(d) defined Licensee as a POGO duly licensed and authorized by PAGCOR to provide offshore gaming services, clarifying that gaming agents, service providers and gaming support providers supplying only a particular component were not the Licensee but required separate registration with PAGCOR.
Requirements
Recognised PAGCOR as the sole licensing body with jurisdiction over both land and sea
Treated only the POGO entity providing the game and taking bets as the Licensee
Required separate PAGCOR registration for every agent, service provider and gaming support provider
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 4(f-g-h)
(historical) POGO Gaming Agent, Service Providers and Gaming Support Provider definitions
Player Rights
Section 4(f) defined POGO Gaming Agent as the representatives in the Philippines of offshore-based licensees. Section 4(g) defined Service Providers as entities providing components of offshore online gaming operations, comprising three sub-tiers: (g.1) Gaming Software / Platform Provider for gaming systems, games, sports book and pool betting; (g.2) Business Process Outsourcing Provider for call centres and IT support services whose service excluded the taking of actual bets; and (g.3) Data/Content Streaming Provider for real-time streaming of casino games produced from a live dealer studio set-up. Section 4(h) defined Gaming Support Provider as a company producing proprietary products and services not necessarily inside the licensee's gaming system but important to the online gaming set-up, e.g. payment solutions, player registration, rewards and marketing modules.
Requirements
Recognised four distinct PAGCOR-regulated counterparty tiers: agent, software/platform, BPO, streaming, support
BPO service providers were expressly barred from taking actual bets
Used the Gaming Support Provider category for payment, registration, rewards and marketing modules
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 4(b)
(historical) Definition of Offshore Gaming and its three components
Player Rights
Section 4(b) defined Offshore Gaming as the offering by a PAGCOR-authorised licensee of online games of chance via the internet using a network and software or program, exclusively to offshore authorized players excluding Filipinos abroad, who have registered and established an online gaming account with the licensee. The definition listed three components: (b.1) a prize consisting of money or something of value won under the rules of the game; (b.2) a player physically located outside the Philippines who is not a Filipino citizen, enters the game remotely via a communication device with internet access, and gives or undertakes to give monetary payment or other valuable consideration; and (b.3) winning of a prize decided by chance.
Requirements
Offered games only to registered account-holders located outside the Philippines
Excluded all Filipinos including Filipinos abroad from accepted players
Ensured every offered game met the prize + remote payment + chance trifecta of the definition
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 4(e)
(historical) Authorized Players definition — age 21, non-Filipino, registered
Responsible Gaming
Section 4(e) defined Authorized Players as those who could access the licensee's games via its website subject to four criteria: (e.1) offshore individuals physically in another country (excluding Filipino citizens even if abroad and individuals in countries which prohibit participation of their citizens in online gaming); (e.2) foreign nationals while within Philippine territory were NOT allowed to participate; (e.3) age of at least 21 years old or the applicable legal age in foreign countries where the players reside; and (e.4) players must be registered.
Requirements
Verified physical location outside the Philippines for every player at entry
Refused play to all Filipino citizens including Filipinos abroad and to any foreign national while inside the Philippines
Enforced a 21-year-old minimum age or the higher legal age of the player's residence jurisdiction
Required full player registration before any wager
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules (historical) — Title III Licensing structure 4
POGO Rules sec. 6
(historical) Offshore Gaming Licence — Philippine-based vs offshore-based operator classes
Player Rights
Section 6 limited the Offshore Gaming Licence (issued to the Licensee) to two entity classes: (a) Philippine-based operator, a duly constituted business enterprise organised in the Philippines; and (b) Offshore-based operator, a duly constituted business enterprise organised in any foreign country that engaged the services of a PAGCOR-accredited Service / Support Provider for its online gaming activity.
Requirements
Incorporated either in the Philippines or in a foreign jurisdiction with a PAGCOR-accredited counterparty
Offshore-based operators were strictly dependent on a PAGCOR-accredited Service / Support Provider
No third licence class existed under Sec. 6
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 7
(historical) Coverage — e-Casino and Sports Betting verticals
Game Design
Section 7 limited the Offshore Gaming Licence coverage to two verticals: (a) e-Casino, comprising RNG-based or 'live' dealer games and including table games, slots, other card, wheel and dice games, skill games and arcade-type games; and (b) Sports betting.
Requirements
Operated only e-Casino (RNG or live-dealer) or Sports Betting verticals
Treated table games, slots, card/wheel/dice, skill games and arcade-type games as one e-Casino class
No peer-to-peer poker, lottery or other vertical was authorised under the licence
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 8 set the Offshore Gaming Licence requirements: (a) duly constituted business enterprise organised in the Philippines or any foreign country, with a POGO Gaming Agent mandatory for any non-Philippine entity; (b) compliance with PAGCOR's licensing process including (b.1) third-party probity check on the applicant's identity and on each key official covering finances, integrity, competence and criminality, (b.2) review of business plan, (b.3) review of statutory and operational documentation, and (b.4) review of the gaming system aptly certified by a PAGCOR-accredited gaming laboratory; and (c) a Letter of No Objection (LONO) from the LGU on which the offshore gaming operations would be conducted.
Requirements
Engaged a POGO Gaming Agent if not Philippine-incorporated
Submitted to a third-party probity check covering finances, integrity, competence and criminality on every key official
Obtained gaming-system certification from a PAGCOR-accredited gaming laboratory
Secured an LGU Letter of No Objection for the operating site
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 9
(historical) Application fees, licence fees and interim gaming taxes
Player Rights
Section 9 set the Offshore Gaming Licence fee schedule: (a) Application and Processing Fees of US$50,000 for e-Casino and US$40,000 for Sports Betting; (b) Licence Fees on approval of US$200,000 for e-Casino and US$150,000 for Sports Betting; and (c) interim Gaming Taxes for the initial six-month period (pending an effective intermediary platform) of US$10,000/month per table for Live Studio Set-up, US$100/month per player for RNG-based games (card, dice, wheel and tile, slots, video poker, arcade-type and skill games), and US$40,000/month for Sports Betting.
Requirements
Paid US$50,000 e-Casino or US$40,000 Sports Betting application & processing fee at filing
Paid US$200,000 e-Casino or US$150,000 Sports Betting licence fee before issuance
Remitted US$10,000/month/table for Live Studio, US$100/month/player for RNG, or US$40,000/month for Sports Betting until the intermediary platform took over
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules (historical) — Title III Service-provider tiers 15
Section 10 established POGO Gaming Agent Accreditation as the mechanism for providing in-Philippines representation to an offshore-based gaming operator.
Requirements
Offshore-based operators retained a PAGCOR-accredited POGO Gaming Agent as their in-country representative
Treated the agent as a regulated PAGCOR counterparty distinct from the Licensee
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 11
(historical) POGO Gaming Agent requirements — PH incorporation and probity
Player Rights
Section 11 required the representative agent of the offshore gaming operator to be a duly constituted business enterprise organised in the Philippines, compliant with PAGCOR's licensing process including (a) probity check on the applicant's identity and on each key official covering finances, integrity, competence and criminality, and (b) review of statutory and operational documentation.
Requirements
Incorporated the gaming agent vehicle in the Philippines
Submitted to PAGCOR probity check on identity and each key official
Filed full statutory and operational documentation for PAGCOR review
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 12 set the POGO Gaming Agent accreditation fee at US$20,000 to cover probity cost and site visit as necessary.
Requirements
Paid US$20,000 accreditation fee covering probity and site-visit cost
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 13 established Gaming Software/Platform Provider Registration as the registration class for Service Providers of gaming systems or platforms leased by the offshore gaming operator.
Requirements
Registered with PAGCOR before leasing any gaming system or platform to a Licensee
Operated only as a regulated Service Provider tier distinct from the Licensee
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 14 required the Gaming Software or Platform Provider to be a duly constituted business enterprise compliant with PAGCOR's licensing process, including (a) probity check on identity and each key official covering finances, integrity, competence and criminality, and (b) review of statutory and operational documentation.
Requirements
Operated only as a duly constituted business enterprise
Cleared PAGCOR probity check on identity and each key official
Filed full statutory and operational documentation
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 15 set the Gaming Software/Platform Provider registration fee at US$20,000 to cover probity cost and site visit as necessary.
Requirements
Paid US$20,000 registration fee covering probity and site-visit cost
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 16
(historical) Gaming Support Provider registration — purpose
Player Rights
Section 16 established Gaming Support Provider Registration as the class for providers of gaming products sourced separately by the operator outside its leased gaming system, such as payment solutions and player registration systems, among others.
Requirements
Registered with PAGCOR before supplying payment, registration or analogous products to a Licensee
Operated only outside the leased gaming-system perimeter
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 17
(historical) Gaming Support Provider requirements
Player Rights
Section 17 required the Gaming Support Provider to be a duly constituted business enterprise compliant with PAGCOR's licensing process, including (a) probity check on identity and each key official covering finances, integrity, competence and criminality, and (b) review of statutory and operational documentation.
Requirements
Operated only as a duly constituted business enterprise
Cleared PAGCOR probity check on identity and each key official
Filed full statutory and operational documentation
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 18
(historical) Gaming Support Provider registration fee — US$20,000
Player Rights
Section 18 set the Gaming Support Provider registration fee at US$20,000 to cover probity cost and site visit as necessary, payable for eligibility to engage in the supply or sale of gaming products and solutions.
Requirements
Paid US$20,000 registration fee covering probity and site-visit cost
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 19 required Business Process Outsourcing (BPO) providers offering call-centre services to the operator to be registered with PAGCOR.
Requirements
Registered every BPO providing call-centre services to a Licensee
Did not undertake any taking of actual bets (per Sec. 4(g.2))
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 20
(historical) BPO registration requirements — PH incorporation, probity, service agreement
Player Rights
Section 20 required BPO registration applicants to (a) be a duly constituted business enterprise in the Philippines; (b) comply with PAGCOR's licensing requirements including (b.1) probity check on identity and each key official and (b.2) review of statutory and operational documentation; and (c) submit a duly executed Service Agreement with a licensed Offshore Gaming Operator when applicable.
Requirements
Incorporated the BPO vehicle in the Philippines
Cleared PAGCOR probity check on identity and each key official
Filed full statutory and operational documentation
Submitted a duly executed Service Agreement with the licensed Offshore Gaming Operator
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 21
(historical) BPO registration fee — US$50,000
Player Rights
Section 21 set the BPO registration fee at US$50,000 to cover probity cost and site visit as necessary.
Requirements
Paid US$50,000 BPO registration fee covering probity and site-visit cost
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 22
(historical) Data/Content Streaming Provider and Permit to Possess (PTP)
Game Design
Section 22 required Data/Content Streaming Providers (real-time streaming of casino games from a live dealer gaming studio) to be registered and to obtain a Permit to Possess (PTP) of their gaming equipment and paraphernalia. The PTP allowed the provider to import, store, transfer/move, ship-out and operate gaming equipment and paraphernalia in its gaming studio for the sole purpose of video streaming live gaming action in conjunction with offshore gaming operations; the PTP was site-specific and issued on a per-venue basis, and taxes and duties on importation of equipment were for the provider's sole account.
Requirements
Registered as a Data/Content Streaming Provider before any live-dealer streaming activity
Obtained a per-venue PTP authorising import, storage, transfer, ship-out and operation of gaming equipment
Bore all taxes and duties on imported gaming equipment and paraphernalia
Used the equipment only for video streaming live gaming action under the Rules
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 23 required Data/Content Streaming Provider applicants to submit (a) a duly accomplished Application for Permit to Possess (OG Form), (b) registration certificates from DTI or SEC as applicable, (c) photocopy of the Mayor's Permit or Business Permit, (d) compliance with PAGCOR licensing requirements including probity check on identity and each key official and review of statutory and operational documentation, and (e) a duly executed Service Agreement with a licensed Offshore Gaming Operator.
Requirements
Filed the OG Form Application for Permit to Possess
Submitted DTI or SEC registration certificates and the Mayor's/Business Permit
Cleared PAGCOR probity check on identity and each key official
Submitted a duly executed Service Agreement with a licensed Offshore Gaming Operator
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 24
(historical) Data/Content Streaming and Licensee-owned studio PTP fees and equipment penalty
Game Design
Section 24 assessed Data/Content Streaming Provider applicants an application and processing fee of US$40,000 plus a Permit to Possess fee of US$100,000 per studio (covering probity, regular inspection and monitoring). Licensed Offshore Gaming Operators in possession of their own live gaming studios likewise had to apply for a PTP at US$2,000 per table. Any unexplained loss, unauthorised transfer or sale of the equipment or paraphernalia was fined US$100,000 chargeable against the licensee's posted bond.
Requirements
Paid US$40,000 application/processing fee plus US$100,000 PTP fee per studio
Faced a US$100,000 fine — chargeable against the performance bond — for any unexplained loss, unauthorised transfer or sale of gaming equipment
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 25 required licensees, agents and service providers to renew their licences, accreditations and registrations yearly and to comply with the renewal requirements at least one month prior to expiration, for a fee similar to their application and processing fees.
Requirements
Filed renewal at least one month prior to expiration
Paid a renewal fee mirroring the original application and processing fee
Complied with the same documentation and probity standards on each renewal cycle
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules (historical) — Title IV General conditions 23
POGO Rules sec. 26
(historical) Qualifications of Licensee — five eligibility tests
Player Rights
Section 26 forbade the PAGCOR Board from granting a licence unless satisfied that the applicant met five eligibility tests: (a) good repute considering character, honesty and integrity; (b) not associated with any person of poor repute or with undesirable or unsatisfactory financial resources; (c) sufficient experience and ability to establish and manage offshore gaming operations; (d) not among those excluded from gaming under the Rules or any other law; and (e) for an artificial person, stable financial standing and satisfactory corporate structure.
Requirements
Demonstrated good repute on character, honesty and integrity
Disclosed and avoided association with persons of poor repute or weak finances
Demonstrated experience and ability to establish and manage offshore gaming operations
Showed stable financial standing and satisfactory corporate structure
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(a)
(historical) US$250,000 performance bond replenished within 72 hours
Player Rights
Section 27(a) required licensees to post a cash performance bond of TWO HUNDRED FIFTY THOUSAND (US$250,000) dollars, to be used to settle accountabilities with PAGCOR in case the licensee absconded or was found to be under-declaring gross winnings to deprive PAGCOR of its rightful share. Any amount deducted from the cash bond had to be replenished within 72 hours of the deduction, and the bond had to remain valid for the entire duration of the licence and any renewal.
Requirements
Posted US$250,000 cash performance bond before commencing operations
Replenished any deduction from the bond within 72 hours
Kept the bond valid for the entire licence term and through every renewal
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(b)
(historical) Three-day prior notice for any stoppage or interruption
Player Rights
Section 27(b) barred licensees from stopping or interrupting operations during the licence's validity without due notice to PAGCOR at least three days ahead of the scheduled stoppage or interruption, so that players were properly notified and to avoid creating the notion that the licensee had suddenly stopped its operations to abscond from its obligations.
Requirements
Gave PAGCOR at least three days' notice before any scheduled stoppage or interruption
Communicated the stoppage to players to prevent abandonment concerns
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(c)
(historical) Monthly transaction reports during the remittance period
Player Rights
Section 27(c) required licensees to submit to PAGCOR, during the period of remittance, the stipulated monthly reports of all offshore gaming transactions in the format required by PAGCOR.
Requirements
Submitted monthly reports of all offshore gaming transactions in PAGCOR's required format
Aligned reporting cadence with the PAGCOR remittance period
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(d)
(historical) Mandatory integration with PAGCOR intermediation platform within 6 months
Player Rights
Section 27(d) required licensed offshore gaming operators to fully integrate their offshore online gaming operations with PAGCOR's intermediation platform within six months from commencement of operations, for monitoring purposes.
Requirements
Integrated offshore online gaming operations into the PAGCOR intermediation platform within six months of commencement
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(e)
(historical) Open-premises inspection rights for PAGCOR monitoring
Player Rights
Section 27(e) required the licensee to allow inspection of premises, machines and equipment being used in its operations at any time upon request of PAGCOR's monitoring and enforcement personnel duly assigned for the purpose.
Requirements
Granted PAGCOR monitoring and enforcement personnel unrestricted inspection access at any time
Made premises, machines and equipment available on demand
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(f)
(historical) Pre-implementation PAGCOR approval of wagering/financial/admin software
Game Design
Section 27(f) subjected all wagering, financial and administrative software to PAGCOR's evaluation and approval, with testing and inspection of the wagering system — particularly the components intended to safeguard against betting by Filipinos or persons prohibited from gambling in their home countries — conducted by PAGCOR prior to implementation.
Requirements
Submitted all wagering, financial and administrative software for PAGCOR evaluation and approval
Did not implement any system before PAGCOR testing and inspection
Demonstrated safeguards against Filipino bettors and against bettors from prohibited jurisdictions
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(g)
(historical) PAGCOR control over hardware install, modify, decommission or destroy
Game Design
Section 27(g) subjected all hardware equipment to PAGCOR's evaluation and approval; licensed offshore gaming operators could not install, modify, decommission, remove or destroy any such equipment without written authority from PAGCOR.
Requirements
Submitted all hardware for PAGCOR evaluation and approval
Obtained written PAGCOR authority before any install, modify, decommission, remove or destroy action
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(h)
(historical) Sole responsibility to reject Filipinos, under-21s and prohibited jurisdictions
Responsible Gaming
Section 27(h) made licensed offshore gaming operators solely responsible for ensuring that no wagers would be accepted from Filipinos, persons below 21 years of age, and from jurisdictions where such forms of gambling are prohibited.
Requirements
Blocked all wagers from Filipinos
Blocked all wagers from persons under 21
Blocked all wagers from jurisdictions where the form of gambling was prohibited
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(i)
(historical) 'Void where prohibited by law' player notification
Player Rights
Section 27(i) required licensed offshore gaming operators to notify all of their players that bets shall be deemed 'void where prohibited by law'.
Requirements
Displayed the 'void where prohibited by law' notification to every player
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 27(j)
(historical) Automatic termination on AMLA or other Philippine law violation
Responsible Gaming
Section 27(j) provided that if a licensed offshore gaming operator was found to be violating any provision of the Anti-Money Laundering Law or any law of the Republic of the Philippines, the licence would be deemed automatically terminated.
Requirements
Operated full AMLA compliance — any violation was a self-executing termination event
Avoided violation of any Philippine law — same automatic-termination consequence
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(a)
(historical) Suspension ground — licensee no longer suitable
Player Rights
Section 28(a) authorised the PAGCOR Board to suspend a licence during the pendency of investigation where, in the opinion of the Board, the licensee was not, or was no longer, a suitable person to hold the licence.
Requirements
Maintained continuing suitability in PAGCOR Board's opinion or risked suspension during investigation
Treated suitability as an ongoing — not one-time — condition
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(b)
(historical) Suspension ground — conviction under PH anti-gambling laws
Player Rights
Section 28(b) made conviction of an offence in violation of the anti-gambling laws of the Philippines a suspension ground.
Requirements
Maintained zero convictions under Philippine anti-gambling laws
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(c)
(historical) Suspension ground — conviction of serious offence under any other law
Player Rights
Section 28(c) made conviction of any serious offence under any other law a suspension ground.
Requirements
Maintained zero convictions for serious offences under any other law
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(d)
(historical) Suspension ground — breach of a licence condition
Player Rights
Section 28(d) made violation of any condition attached to the licence a suspension ground.
Requirements
Complied with every condition attached to the licence — any breach triggered suspension
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(e)
(historical) Suspension ground — unexplained one-day cessation or absconding from player obligations
Player Rights
Section 28(e) made a one-day cessation of operations without due notice to PAGCOR — with no explanation of cause — or any attempt to abscond from obligations to players a suspension ground.
Requirements
Avoided any one-day cessation without PAGCOR notice and a documented cause
Honoured every obligation to players to avoid absconding-based suspension
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(f)
(historical) Suspension ground — failure to discharge financial commitments
Player Rights
Section 28(f) made failure to discharge financial commitments a suspension ground.
Requirements
Discharged every financial commitment on time to avoid suspension
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(g)
(historical) Suspension ground — bankruptcy or rehabilitation
Player Rights
Section 28(g) made bankruptcy of the licensee or being under rehabilitation a suspension ground.
Requirements
Notified PAGCOR of any rehabilitation proceeding immediately
Maintained solvency or risked suspension and cancellation
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(h)
(historical) Suspension ground — licence obtained by materially false or misleading representation
Player Rights
Section 28(h) made obtaining the licence by a materially false or misleading representation, or in some other improper way, a suspension ground.
Requirements
Filed wholly accurate and non-misleading representations at application
Avoided any improper means of obtaining the licence
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(i)
(historical) Suspension ground — failure to prevent Filipinos, minors and prohibited persons from playing
Responsible Gaming
Section 28(i) made failure to prevent Filipino citizens, minors and those prohibited by law from participating in the offshore games a suspension ground.
Requirements
Operated demonstrable controls to prevent Filipinos, minors and prohibited persons from playing
Treated any participation by such persons as exposing the licence to suspension
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(j)
(historical) Suspension ground — failure to operate within one month of licence issuance
Player Rights
Section 28(j) made failure to operate within one month of the licence's issuance a suspension ground.
Requirements
Commenced operations within one month of licence issuance
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 28(k)
(historical) Suspension ground — public-interest or gaming-integrity protection plus bond forfeiture
Player Rights
Section 28(k) authorised suspension where required to ensure that the public interest was not adversely or materially affected, or that the integrity of the conduct of gaming was not jeopardised. The closing paragraph of Section 28 provided that a finding of guilt for any of the Sec. 28 grounds would result in cancellation of the licence and automatic forfeiture of the performance bond, with suspension or cancellation effected by written notice taking effect on receipt or tender if the licensee refused.
Requirements
Operated without adversely or materially affecting public interest or gaming integrity
Accepted that any guilty finding under Sec. 28 triggered cancellation plus automatic bond forfeiture
Accepted that written-notice service — including refused or untendered notice — was effective
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
Section 29 provided that licences took the form of a certificate for licensed operators and could not be transferred by sale, inheritance succession, gift or otherwise to any person without prior consent of the PAGCOR Board, under any additional transfer condition the Board imposed, and only if the transferee met the Rules' requirements.
Requirements
Treated the licence as non-transferable absent prior PAGCOR Board consent
Ensured any prospective transferee independently met every requirement of the Rules
Accepted PAGCOR Board authority to impose additional transfer conditions
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules (historical) — Title V Interim provisions and Task Force POGO 6
POGO Rules sec. 30
(historical) Six-month amendment window for the Rules
Player Rights
Section 30 stated that the provisions of the Rules were for the initial six (6) months of implementation only, and could be revised, amended, supplemented or totally replaced as needed after six months based on evaluation of the results of the initial implementation.
Requirements
Treated the Rules as a six-month interim framework subject to wholesale revision
Tracked PAGCOR's post-implementation evaluation as the trigger for any rule change
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 31
(historical) Initial cap of 25 offshore-licence applications
Player Rights
Section 31 limited applications for the offshore gaming licence to twenty-five (25) applicants during the initial six months of implementation, to ensure focused and comprehensive monitoring and evaluation. The Board could increase the number at its discretion if circumstances warranted.
Requirements
Applied within the initial cap of 25 applicants during the six-month implementation window
Accepted PAGCOR Board discretion to lift the cap
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 32
(historical) Eligibility limited to existing franchise-holders; illegal operators barred
Player Rights
Section 32 restricted applicants to those who could establish they were previously operating under franchises issued by other regulatory agencies. Operators previously running online games illegally were not permitted to apply for licences.
Requirements
Documented a prior franchise from another regulatory agency as the eligibility predicate
Operators previously running games illegally were barred from applying
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 33
(historical) Ad Hoc Licensing Committee from GLDD + Office of the CEO
Player Rights
Section 33 established an Ad Hoc Licensing Committee for speedy processing of licences, accreditations and registrations, composed of select employees from the Gaming, Licensing and Development Department (GLDD) in close coordination with a representative from the Office of the CEO. Final grant of licence was subject to PAGCOR Board approval.
Requirements
Submitted applications to the GLDD-led Ad Hoc Licensing Committee for processing
Recognised the PAGCOR Board as the final approval authority
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
POGO Rules sec. 34
(historical) Task Force POGO inter-agency monitoring with NBI and Bureau of Immigration
Player Rights
Section 34 directed PAGCOR to make proper representations with other law-enforcement agencies tasked with gambling and immigration laws, securing the participation of those agencies in an inter-agency task force tasked with: (a) surveillance and identification of illegal online gaming operators; (b) recommendations on closure and cessation; (c) reporting violations by licensed offshore operators; and (d) reporting extortion activities directed at licensed offshore operators by other law-enforcement agencies. The body was named Task Force POGO and was composed of personnel from the Office of the CEO, select CMED employees of PAGCOR, the National Bureau of Investigation and the Bureau of Immigration.
Requirements
Treated Task Force POGO (Office of CEO + CMED + NBI + Bureau of Immigration) as the operative enforcement counterparty
Reported any extortion attempts by other law-enforcement agencies to Task Force POGO
Cooperated with surveillance, closure and cessation activities aimed at illegal online operators
Cancelled 15 December 2024 by EO 74 implementation; PAGCOR public notice confirms all IGLs and Authorized Providers were cancelled effective that date.
PAGCOR Notice 15 Dec 2024
(historical) Cancellation of all Internet Gaming Licensees and Authorized Providers
Player Rights
Following the issuance of Executive Order No. 74 which mandates the immediate ban of Philippine offshore gaming operations in the country, please be advised that ALL Internet Gaming Licensees and Authorized Providers were cancelled effective December 15, 2024. PAGCOR further warns that any company claiming to hold a valid offshore gaming/internet gaming license from PAGCOR is fraudulent and unauthorized.
Requirements
Verify directly with PAGCOR at ogld@pagcor.ph before transacting with any entity claiming offshore PAGCOR licensure
Treat any claim of active offshore PAGCOR licence as fraudulent post-15 Dec 2024
Reconcile pre-15 Dec 2024 transactions for tax / AML successor liability
PAGCOR's own public notice confirming the cancellation; the operative source for all post-2024 due diligence on entities claiming offshore PAGCOR licensure.
4
Theme 4
AML & casino financial crime prevention
Philippine casinos including internet-based and ship-based casinos were brought under the Anti-Money Laundering Act by RA 10927 of 2017 and tightened by RA 11521 of 2021. The Anti-Money Laundering Council issues sector-specific regulatory issuances; PAGCOR enforces alongside, and AML failures are a leading cause of administrative sanction.
39 standards36 player-flagged
92%
player-flagged
Regulatory risks this theme addresses
Failing to report a single covered transaction at or above PHP 5 million within five working days
Treating online-only operations as outside the AMLA perimeter — RA 10927 captured internet-based casinos explicitly
Missing the AMLC Regulatory Issuance refresh cycle for casino-sector specific obligations
Statutory framework 3
RA 10927 sec. 3
Casinos as AMLA covered persons
Player Rights
Republic Act 10927 of 14 July 2017 amended Section 3 of the AMLA to add casinos, including internet-based casinos and ship-based casinos, as covered persons. The amendment closed the FATF-identified gap that had kept Philippine casinos outside customer-due-diligence and reporting obligations until the year after the 2016 Bangladesh Bank heist.
Requirements
Apply full AMLA covered-person obligations to every PAGCOR-licensed casino product including online
Register the casino with AMLC and appoint an AML Compliance Officer
Conduct customer due diligence in line with AMLC casino-sector guidelines
File covered and suspicious transaction reports through AMLC's reporting portal
RA 10927 is the post-Bangladesh-Bank reform; it deliberately extended cover to internet-based casinos to pre-empt future arbitrage.
RA 11521 sec. 5
Expanded CDD and targeted financial sanctions
Player Rights
Republic Act 11521 of 29 January 2021 further amended the AMLA to expand customer due-diligence obligations, codify targeted financial sanctions for proliferation financing, and grant AMLC additional investigative tools. Casinos must screen against UNSC consolidated lists and the AMLC sanctions list at onboarding and on an ongoing basis.
Requirements
Screen every player against UN Security Council and AMLC sanctions lists at onboarding
Re-screen the active customer base whenever the sanctions list is updated
Freeze and report any matched account immediately under TFS protocols
Document the risk-based approach to ongoing monitoring for senior management approval
RA 10927 sec. 11
PHP 5 million casino covered-transaction threshold
RG CriticalPlayer Rights
RA 10927 fixed the casino covered-transaction threshold at a single cash transaction in excess of PHP 5 million or its equivalent in any other currency. Every transaction at or above the threshold must be reported to AMLC within five working days of occurrence, irrespective of whether suspicion of money laundering exists.
Requirements
Capture every cash-in, cash-out and chip purchase against the PHP 5 million threshold
File the Covered Transaction Report to AMLC within five working days
Aggregate linked transactions to detect structuring designed to stay under the threshold
Retain all CTR supporting records for at least five years
The PHP 5 million ceiling sits well above the PHP 500,000 banking threshold and reflects casino-industry compromise; AMLC has periodically signalled review.
AMLC casino guidelines 4
AMLC ARI for Casinos sec. 4
Risk-based customer due diligence
Player Rights
The AMLC Regulatory Issuance for the casino sector requires risk-based CDD calibrated to the customer's profile, transaction patterns and channel risk. Enhanced due diligence applies to politically exposed persons, junket players, high-rollers and customers from FATF high-risk jurisdictions.
Requirements
Apply standard CDD to all players at onboarding including verified government ID
Apply enhanced CDD to PEPs, junket players, high-rollers and FATF high-risk jurisdiction customers
Refresh CDD at trigger events including a step change in deposit or wager volume
Record CDD outcomes in an auditable customer file
AMLC ARI for Casinos sec. 7
Suspicious transaction reporting
RG Critical
Casinos must file a Suspicious Transaction Report with AMLC within five working days of becoming aware of the suspicion, regardless of the amount involved. STRs cover transactions with no underlying legal or trade obligation, transactions inconsistent with the customer profile and transactions linked to predicate offences including human trafficking and corruption.
Requirements
Train every customer-facing employee on STR red flags including chip-walking and minimal-play laundering
File STRs through goAML-equivalent AMLC portal within five working days of suspicion
Apply tipping-off prohibition strictly — the subject must not be alerted
Maintain a quarterly STR statistics review at board level
AMLC ARI for Casinos sec. 12
AML Compliance Officer and board accountability
Player Rights
Every PAGCOR-licensed casino must appoint a senior AML Compliance Officer (AMLCO) with direct access to the board, independent reporting lines, and authority to file STRs without management vetting. The board is personally accountable for AML programme effectiveness and must approve the enterprise-wide risk assessment annually.
Requirements
Appoint an AMLCO at senior management level with independent board access
Ensure the AMLCO can file STRs without operational management approval
Conduct and document an enterprise-wide AML risk assessment annually
Submit AML programme effectiveness reports to the board at least semi-annually
PAGCOR AMLCO Site Rule
On-site compliance officer per venue
Player Rights
PAGCOR requires every land-based casino site and every PIGO operations centre to have a dedicated on-site AML compliance officer reporting into the group AMLCO. The on-site officer is the first point of contact for PAGCOR inspectors and is personally responsible for shift-level CTR and STR triage.
Requirements
Designate a named on-site AMLCO per venue and per PIGO operations centre
Schedule on-site AMLCO cover across all gaming shifts
Maintain an inspection-ready file at each site with current CDD, CTR and STR registers
Report on-site AMLCO changes to PAGCOR within 15 days
RA 9160 — AMLA original framework 3
RA 9160 sec. 3(b)
Covered transaction definition (general AMLA)
Section 3(b) of RA 9160 defines a covered transaction as a single transaction in cash or other equivalent monetary instrument involving an amount in excess of the threshold prescribed by law. The general AMLA threshold for non-casino covered persons is PHP 500,000; RA 10927 sets the casino-sector threshold at PHP 5 million as a sector-specific carve-out.
Requirements
Recognise that the casino threshold (PHP 5M) is a sector carve-out from the general AMLA framework
Apply the general PHP 500,000 threshold to any non-casino financial activity within the licensee group
Track legislative proposals to harmonise or lower the casino threshold
Reference RA 9160 sec. 3(b) as the parent definition when documenting casino-sector reporting
RA 9160 sec. 3(i)
Predicate unlawful activities
Section 3(i) of RA 9160 enumerates the predicate unlawful activities whose proceeds trigger the money-laundering offence, including kidnapping, drug trafficking, plunder, robbery, swindling, illegal recruitment, trafficking in persons, terrorism financing and qualified theft. RA 11521 added tax evasion above defined thresholds in 2021, materially widening the casino-sector typology surface.
Requirements
Calibrate suspicious-activity typologies to the current RA 9160 predicate list as amended through RA 11521
Treat tax-evasion proceeds as in-scope for AML purposes following the 2021 amendment
Refresh red-flag training whenever new predicate offences are added
Maintain a documented mapping between casino-sector typologies and statutory predicates
RA 9160 sec. 4
Money laundering offence
Section 4 of RA 9160 defines money laundering as the transacting, conversion, transfer, disposal, movement or concealment of monetary instruments or property representing the proceeds of an unlawful activity. The definition reaches knowing facilitation by employees of covered persons and is the substantive offence underlying every casino-sector STR filing.
Requirements
Train customer-facing staff on the substantive elements of the money-laundering offence
Treat knowing facilitation by an employee as personal criminal exposure on top of corporate liability
Reference RA 9160 sec. 4 alongside the casino-sector AMLC guidance when designing STR triage
Calibrate red-flag indicators to the statutory elements, not only to typology checklists
RA 10927 — casino AMLA coverage (operative sections) 5
RA 10927 sec. 2
Internet-based and ship-based casinos expressly in scope
Player Rights
Section 2 of RA 10927 amends AMLA section 3(a) to add casinos — including internet-based casinos and ship-based casinos — to the enumerated list of covered persons, with the qualifier that the AML obligations attach only to casino cash transactions related to gaming. The amendment removed the long-standing carve-out that had kept Philippine casino activity outside AMLC's perimeter.
Requirements
Treat every internet-based casino product authorised by PAGCOR as a covered person regardless of player domicile
Apply AMLA obligations to ship-based casino operations operating in Philippine waters
Confine reporting to cash transactions related to gaming as defined in sec. 2
Document the scoping decision for non-gaming hospitality cash flows separately
The internet-based casino extension was explicitly designed to pre-empt online arbitrage after the 2016 Bangladesh Bank heist and FATF mutual evaluation findings.
RA 10927 sec. 4
Casino customer identification and record-keeping duty
Player Rights
Section 4 of RA 10927 amends AMLA section 9 to require casinos to establish and record the true identity of their customers based on official documents and to maintain a system of verifying that identity for the duration of the customer relationship and for at least five years after the account closes or the transaction is completed.
Requirements
Capture true-name identification using one government-issued photographic document at every customer onboarding
Re-verify identity at trigger events including suspicious activity and threshold-crossing transactions
Retain customer identification files for at least five years after relationship termination
Make identification records available to AMLC and PAGCOR on request without prior notice
RA 10927 sec. 6
AMLC as the casino AML supervisory authority
Player Rights
Section 6 of RA 10927 designates the Anti-Money Laundering Council as the primary supervisory authority for casino AML/CFT compliance, with PAGCOR retaining its statutory mandate as gaming regulator. AMLC may issue rules, conduct examinations, impose administrative fines and coordinate with PAGCOR on licence-affecting referrals.
Requirements
Recognise AMLC as the AML/CFT supervisor and PAGCOR as the gaming regulator with concurrent jurisdiction
Cooperate with AMLC examination teams including onsite inspection without prior notice
Provide AMLC and PAGCOR with synchronised reporting where the same finding has gaming and AML implications
Treat AMLC administrative findings as enforceable independent of PAGCOR action
RA 10927 sec. 12
Statutory suspicious-transaction trigger events
RG Critical
Section 12 of RA 10927 codifies the suspicious-transaction trigger events for casinos: no underlying legal or trade obligation, deviation from customer profile, structuring designed to evade the threshold, transactions tied to a predicate offence under AMLA section 3(i), and any transaction reasonably believed to be connected to unlawful activity. The trigger is reasonable belief, not certainty.
Requirements
Train staff to recognise each statutory trigger event including structuring patterns
File an STR on reasonable belief without waiting for confirmatory evidence
Calibrate transaction-monitoring rules to each enumerated trigger
Document the trigger basis on every STR for AMLC quality review
RA 10927 sec. 14
Five-year record retention for casino AML records
Player Rights
Section 14 of RA 10927 fixes a five-year minimum retention period for all casino AML records including customer identification, transaction records, account files, business correspondence and STR/CTR working papers. Records under active investigation must be retained until AMLC certifies release.
Requirements
Retain customer identification and transaction records for at least five years from account closure or transaction date
Hold STR and CTR working papers including red-flag analysis for the same minimum period
Extend retention indefinitely for records under active AMLC, PAGCOR or court investigation
Maintain records in a format that allows AMLC to reconstruct individual transactions on demand
RA 11521 — 2021 AMLA amendment (operative sections) 4
RA 11521 sec. 3
Beneficial-ownership reporting on every casino account
Player Rights
Section 3 of RA 11521 expands AMLA section 9(a) to require covered persons including casinos to identify and verify the beneficial owner behind every account, defined as any natural person who ultimately owns or controls 25 percent or more of the customer, or who exercises effective control by other means. Beneficial-ownership data must be kept current throughout the relationship.
Requirements
Identify and verify the natural-person beneficial owner at the 25 percent threshold on every casino account
Apply the effective-control test where ownership is dispersed or held through legal arrangements
Refresh beneficial-ownership data at trigger events and at periodic review
Maintain a beneficial-ownership register accessible to AMLC and PAGCOR on demand
RA 11521's beneficial-ownership rule was a direct response to FATF Recommendation 24 and the 2019 Mutual Evaluation Report's negative finding on the Philippines.
RA 11521 sec. 8
Expanded predicate-offence catalogue
Player Rights
Section 8 of RA 11521 expands the predicate-offence catalogue under AMLA section 3(i) to include tax evasion above PHP 25 million per taxable year, violation of the Strategic Trade Management Act, and proliferation-financing offences. Casino STRs must reference the specific predicate offence reasonably believed to underlie the suspicious activity.
Requirements
Update STR triage rules to recognise tax evasion above PHP 25 million as a predicate offence
Screen high-value player transactions for Strategic Trade Management Act linkages
Apply proliferation-financing typologies to high-risk-jurisdiction players
Cite the specific predicate offence on every STR filed with AMLC
RA 11521 sec. 10
AMLC ex parte targeted-financial-sanctions freezing power
RG Critical
Section 10 of RA 11521 grants AMLC the power to issue an ex parte freeze order on any property or funds related to UN Security Council Resolution 1267 (terrorism) and 1718 (proliferation) designations, effective immediately upon issuance and without prior notice to the account holder. Casinos must implement the freeze within 24 hours.
Requirements
Maintain a 24/7 channel to receive AMLC ex parte freeze orders
Implement a UNSCR 1267 or 1718 freeze within 24 hours of order receipt
Block player withdrawal, chip redemption and account transfer for any frozen account
File a freeze-implementation confirmation with AMLC and PAGCOR
RA 11521 sec. 12
AMLC subpoena and bank-inquiry power over casinos
Player Rights
Section 12 of RA 11521 extends AMLC's subpoena and bank-inquiry powers to casino accounts and casino-held property, permitting examination without a court order where the AMLC has probable cause to believe the account is related to an unlawful activity or AML/CFT offence enumerated in AMLA.
Requirements
Recognise AMLC ex parte inquiry authority over casino chip, e-wallet and player wallet accounts
Produce subpoenaed records within the AMLC-specified deadline (typically five working days)
Maintain confidentiality and apply tipping-off rules during any AMLC inquiry
Document the chain of custody for every record produced under subpoena
AMLC Casino Implementing Rules and Regulations (CIRR) 8
CIRR rule 10.B
Sanctions screening and watchlist coverage
Player Rights
Rule 10.B of the CIRR requires casinos to screen every player and every beneficial owner against the UN Security Council consolidated list, the AMLC sanctions list and the lists of designated terrorist organisations under the Human Security Act and the Anti-Terrorism Act of 2020. Screening must occur at onboarding, on every list refresh and at periodic review.
Requirements
Screen new players and beneficial owners at onboarding against UNSC, AMLC and Philippine ATC lists
Re-screen the active customer base on every list update
Block onboarding and freeze existing accounts on confirmed matches pending AMLC instruction
Maintain a documented false-positive review process with senior-management sign-off
CIRR rule 11.A
Branch and group AML coordination
Player Rights
Rule 11.A of the CIRR requires multi-venue casino groups and casinos operating both land-based and online channels to maintain group-level AML coordination, with a single consolidated customer risk view, shared watchlist data and harmonised STR/CTR aggregation across every venue and channel.
Requirements
Maintain a single consolidated customer risk view across every land-based venue and online channel
Share watchlist hits, STR subjects and exclusion data across every group entity
Aggregate transactions across venues and channels for threshold and structuring detection
Designate a group AMLCO with authority over branch and channel AMLCOs
CIRR rule 3.A
Tiered customer identification programme
Player Rights
Rule 3.A of the AMLC Casino Implementing Rules and Regulations requires every casino to operate a tiered customer-identification programme: standard CDD for routine players, simplified CDD where AMLC-approved low-risk indicators apply, and enhanced CDD for PEPs, junket players, customers from high-risk jurisdictions and customers triggering monitoring alerts. Each tier has its own minimum documentation set.
Requirements
Default new customers to standard CDD with one primary government photographic ID
Apply enhanced CDD with source-of-funds documentation for PEPs and high-risk-jurisdiction customers
Document the tier assignment and the basis for any change in tier
Reassess tier at every periodic review and at material change in customer behaviour
CIRR rule 5.B
Junket promoter due diligence and accountability
Player Rights
Rule 5.B of the CIRR holds the host casino accountable for the AML compliance of every junket promoter operating on its premises or under its brand. The casino must conduct full due diligence on the junket operator, its beneficial owners and its agents, monitor junket-player transactions in real time, and file STRs on suspicious junket activity even where the underlying player is identified by the junket rather than the casino.
Requirements
Conduct enhanced due diligence on every junket promoter and its beneficial owners before granting room access
Identify every junket player at the same standard as a direct casino patron
Monitor junket-room chip movements, settlements and rebates in real time
File STRs on suspicious junket activity regardless of whether the junket originated the relationship
Junket-related vulnerabilities were a central finding in the Philippines' 2019 FATF Mutual Evaluation and remain a priority enforcement area.
CIRR rule 6.C
Electronic-payment and cashless-gaming AML controls
Player Rights
Rule 6.C of the CIRR requires casinos using electronic-payment rails, ticket-in-ticket-out systems and cashless wallets to apply the same CDD, monitoring, threshold and reporting obligations as physical cash. Wallet top-ups, ticket redemptions and player-to-player transfers must be aggregated against the PHP 5 million covered-transaction threshold.
Requirements
Aggregate cashless wallet top-ups and redemptions against the PHP 5 million CTR threshold
Apply CDD to every player loading or redeeming a cashless instrument
Disable player-to-player wallet transfers unless an explicit AML risk assessment authorises them
Reconcile cashless-system ledgers to the casino accounting general ledger daily
CIRR rule 7.B
Documented Money Laundering and Terrorist Financing Prevention Programme
Player Rights
Rule 7.B of the CIRR requires every casino to maintain a board-approved Money Laundering and Terrorist Financing Prevention Programme (MTPP) covering risk assessment, CDD, monitoring, reporting, training, record-keeping, independent audit, and the AMLCO function. The MTPP must be reviewed at least annually and resubmitted to AMLC after material changes.
Requirements
Maintain a current board-approved MTPP covering all CIRR-required elements
Review the MTPP at least annually and after material business or regulatory change
File the updated MTPP with AMLC within 30 days of material amendment
Make the MTPP available to PAGCOR examiners on site without prior notice
CIRR rule 8.A
Mandatory AML training curriculum and refresh cycle
Player Rights
Rule 8.A of the CIRR requires every casino to deliver an AML/CFT training programme to all customer-facing, cage, surveillance, IT and senior-management personnel at onboarding and annually thereafter. The curriculum must cover RA 9160 as amended, CIRR obligations, red-flag typologies, STR/CTR mechanics and the tipping-off prohibition.
Requirements
Train every customer-facing, cage, surveillance, IT and senior-management employee at onboarding
Refresh training annually and on material regulatory change
Cover RA 9160 as amended, CIRR, red flags, STR/CTR mechanics and tipping-off in every cycle
Maintain attendance, assessment-pass and certificate records for AMLC inspection
CIRR rule 9.D
Independent AML audit at least every two years
Player Rights
Rule 9.D of the CIRR requires every casino to commission an independent AML/CFT audit at least every two years, conducted by personnel not involved in the design or operation of the MTPP. The audit report and management response must be submitted to the board, retained for five years and made available to AMLC and PAGCOR examiners.
Requirements
Commission an independent AML/CFT audit at least once every two calendar years
Ensure auditors have no role in MTPP design, AMLCO function or transaction monitoring
Submit the audit report and the management remediation response to the board
Retain audit files for at least five years and produce them to AMLC and PAGCOR on request
AMLC Regulatory Issuances (ARI) for casinos 6
AMLC ARI A.11-2023
Internet-based casino specific AML controls
Player Rights
AMLC Regulatory Issuance A.11-2023 extends sector-specific obligations to internet-based casinos, requiring real-time digital KYC (liveness + ID document authentication), payment-channel risk-rating, device-fingerprint linkage to player identity, and dedicated rules for e-wallet, instant-bank-transfer and cryptocurrency-adjacent rails. Anonymous or pseudonymous accounts are prohibited.
Requirements
Deploy real-time digital KYC combining liveness check and ID-document authentication at registration
Risk-rate each payment channel and apply enhanced controls to higher-risk rails
Link device fingerprints to verified player identity and flag multi-account device clusters
Prohibit anonymous or pseudonymous accounts and decline cryptocurrency-funded deposits absent explicit AMLC clearance
AMLC ARI A.2-2018
Casino reporting through the AMLC reporting portal
Player Rights
AMLC Regulatory Issuance A.2-2018 obliges casinos to file Covered Transaction Reports and Suspicious Transaction Reports electronically through the AMLC reporting portal (the Philippine implementation of the UNODC goAML platform). Paper filing is not accepted; the casino must provision dedicated user credentials and maintain submission logs.
Requirements
Provision AMLC reporting portal credentials for the AMLCO and a designated backup
File every CTR and STR electronically; do not submit paper reports
Retain portal submission acknowledgements for the five-year retention period
Test reporting-portal connectivity at least quarterly and on credential rotation
AMLC ARI A.4-2019
CTR filing mechanics and five-working-day deadline
Player Rights
AMLC Regulatory Issuance A.4-2019 specifies CTR filing mechanics: every cash transaction in excess of PHP 5 million (or foreign-currency equivalent) must be reported within five working days of the transaction date, using the prescribed casino CTR template that captures patron identity, transaction type, denomination breakdown, table or device ID and the cage shift.
Requirements
Capture patron identity, transaction type, denomination breakdown, table or device ID and shift on every CTR
File the CTR through the AMLC portal within five working days of the transaction date
Convert foreign-currency transactions to PHP at the BSP reference rate on the transaction date
Reconcile filed CTRs to cage and pit ledgers daily
AMLC ARI A.5-2020
Automated transaction-monitoring system requirements
Player Rights
AMLC Regulatory Issuance A.5-2020 requires every casino to deploy an automated transaction-monitoring system covering chip purchases, cage transactions, cashless wallet flows and online wagers. The system must apply threshold, velocity, structuring and pattern-based rules calibrated to the casino's risk assessment, and must produce alerts for AMLCO disposition within defined SLAs.
Tune threshold, velocity, structuring and pattern rules to the casino's documented risk assessment
Triage every alert within a defined SLA and document disposition in the AML case-management system
Calibrate and back-test rule performance at least annually with documented effectiveness metrics
AMLC ARI A.7-2021
Recordkeeping minimums, format and reconstructability
Player Rights
AMLC Regulatory Issuance A.7-2021 prescribes minimum record-keeping standards: customer-identification, transaction, account, AML programme and training records must be retained in a format that allows AMLC to reconstruct individual transactions within ten working days of a request. Off-site backups are required and must be located in a jurisdiction with mutual legal assistance arrangements with the Philippines.
Requirements
Retain records in a format permitting full transaction reconstruction within ten working days of an AMLC request
Maintain off-site backups in a jurisdiction with MLA arrangements with the Philippines
Encrypt records in transit and at rest using AMLC-acceptable standards
Test backup restoration at least annually and document the result
AMLC ARI A.9-2022
On-site inspection cooperation duties
Player Rights
AMLC Regulatory Issuance A.9-2022 codifies the casino's duties during on-site AMLC inspections: unrestricted access to the cage, surveillance footage, transaction-monitoring console, AML case-management system and senior-management interview availability. Refusal, delay or obstruction is itself a reportable breach and an aggravating factor in penalty calculation.
Requirements
Grant AMLC examiners unrestricted access to cage, surveillance, monitoring console and AML case files
Make the AMLCO and senior management available for interview during the inspection
Produce requested records within the timeframe stipulated by the examination team
Maintain a documented inspection log including all requests, productions and findings
PAGCOR AML circulars and AMLCO governance 3
PAGCOR AMLCO Circular 1-2019
AMLCO designation, qualifications and PAGCOR registration
Player Rights
PAGCOR Circular 1-2019 requires every licensed casino to designate an Anti-Money Laundering Compliance Officer at senior-management level, with a minimum of five years' AML/CFT experience, no disqualifying criminal record, and a fit-and-proper clearance. The AMLCO designation must be registered with PAGCOR and AMLC within 15 calendar days of appointment.
Requirements
Designate the AMLCO at senior-management level reporting directly to the board or board AML committee
Verify five years of relevant AML/CFT experience and clean NBI clearance at appointment
Register the AMLCO designation with PAGCOR and AMLC within 15 calendar days
Notify PAGCOR and AMLC of any AMLCO change within five calendar days
PAGCOR AMLCO Circular 2-2020
Mandatory AMLCO training and certification
Player Rights
PAGCOR Circular 2-2020 requires the AMLCO and the alternate AMLCO to complete an AMLC-accredited certification programme within twelve months of appointment and to log at least twenty hours of continuing AML education annually. Failure to certify within the window is grounds for suspension of the AML programme approval.
Requirements
Enrol the AMLCO and alternate in an AMLC-accredited certification within 60 days of appointment
Complete certification within twelve months of appointment
Log at least 20 hours of continuing AML education per AMLCO per calendar year
Retain certificates and CPE evidence for PAGCOR inspection
PAGCOR AMLCO Circular 4-2022
AMLCO reporting lines and board escalation
Player Rights
PAGCOR Circular 4-2022 requires that the AMLCO report functionally to the board AML committee (or full board if no committee exists) with a dotted line only to the CEO for administrative purposes. The AMLCO has unrestricted authority to escalate STR decisions, freeze recommendations and programme-effectiveness findings directly to the board without management filtering.
Requirements
Place the AMLCO under functional reporting to the board AML committee, not the CEO
Document the AMLCO's standing right to direct board escalation in the MTPP
Hold AML committee meetings at least quarterly with the AMLCO in attendance
Record AML committee minutes and STR/freeze decisions in the board pack
KYC tiering and PhilSys identity verification 2
PAGCOR PIGO KYC Tier 1
Tier 1 KYC — PhilSys or primary government photographic ID
Player Rights
PIGO and AMLC overlap requires a Tier 1 KYC capture at account opening: PhilSys National ID, passport, driver's licence, SSS UMID, GSIS eCard, PRC ID or postal ID with photograph, recorded against a verified selfie liveness match. Tier 1 is the minimum for any wagering activity above zero.
Requirements
Capture one primary government photographic ID — PhilSys, passport, DL, SSS UMID, GSIS eCard, PRC or postal ID
Require a selfie liveness check and match it to the ID document at onboarding
Validate the ID number against the issuing-authority API where available (PhilSys, LTO, PSA)
Block any wagering activity until Tier 1 verification clears
PhilSys is the preferred primary ID under the Philippine Identification System Act (RA 11055) and is steadily replacing the multi-ID approach across financial services.
PAGCOR PIGO KYC Tier 2
Tier 2 KYC — source-of-funds and enhanced due diligence
Player Rights
Tier 2 KYC applies to players exceeding cumulative deposits of PHP 500,000 in any rolling 30 days, to PEPs and to customers from FATF high-risk jurisdictions. The casino must capture source-of-funds and source-of-wealth evidence, perform adverse-media screening and obtain senior-management approval to continue the relationship.
Requirements
Trigger Tier 2 review at the PHP 500,000 rolling 30-day deposit threshold or on PEP/high-risk classification
Collect source-of-funds and source-of-wealth documentation including payslips, tax returns or business records
Perform adverse-media screening at Tier 2 onboarding and at periodic review
Document senior-management approval before continuing the relationship
Cross-border declarations and BSP coordination 1
BSP Circular 1-2023 (cross-border)
Cross-border cash and casino-chip declaration thresholds
Player Rights
Bangko Sentral ng Pilipinas rules require any natural person to declare physical transport of Philippine pesos exceeding PHP 50,000 and foreign currency or monetary instruments equivalent to USD 10,000 at the point of departure from or arrival into the Philippines. Casino chips, vouchers and electronic-money instruments fall within the declaration regime; casinos must brief high-value patrons at the cage.
Requirements
Brief patrons at the cage on the PHP 50,000 and USD 10,000 cross-border declaration thresholds
Treat casino chips, vouchers and stored-value instruments as monetary instruments for declaration purposes
Report to AMLC any patron observed transporting cash, chips or instruments exceeding the thresholds without declaration
Coordinate with the Bureau of Customs on suspected cross-border breaches involving casino instruments
BSP Circular thresholds apply alongside AMLA reporting; a single transaction can trigger both a casino CTR and a Bureau of Customs declaration.
5
Theme 5
Responsible gambling & player protection
Player-protection rules combine charter-level entry bans, the PAGCOR Responsible Gaming Framework, the Restricted Persons Register self-exclusion system and product-level safer-gambling controls. The Filipino age floor of 21 is one of the strictest in Asia.
19 standards19 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Admitting any Filipino under 21 to a casino or PIGO account, even with parental consent
Operating without a registered self-exclusion intake channel linked to the Restricted Persons Register
Marketing safer-gambling tools as optional when PAGCOR requires them by default
Self-exclusion & restricted persons 5
PAGCOR RG Framework sec. 4
Restricted Persons Register
RG Critical
PAGCOR maintains a centralised Restricted Persons Register listing self-excluded players, players excluded on family-member petition and persons banned by PAGCOR order. Every licensed land-based casino and PIGO operator must query the register at every entry or log-in and refuse service to any listed person.
Requirements
Query the Restricted Persons Register at every venue entry and online log-in
Refuse entry, registration or wager from any listed person and route them to RG support
Process self-exclusion intake within 24 hours of request
Honour family-member petitions in line with PAGCOR procedural rules
PAGCOR RG Framework sec. 5
Self-exclusion application procedure
RG CriticalPlayer Rights
A player may enroll in the PAGCOR Restricted Persons Register by lodging a signed Self-Exclusion Application with the licensee's RG desk, the PAGCOR Corporate Social Responsibility Group, or the licensee's online RG portal. The application requires a valid government ID, a photograph captured at intake for biometric matching, and a written acknowledgement of the consequences of exclusion including forfeiture of unredeemed loyalty rewards.
Requirements
Accept self-exclusion applications at every venue RG desk and via the online RG portal
Capture a current photograph at intake for cross-venue biometric matching
Forward intake packets to the PAGCOR CSR Group within 24 hours for central RPR enrolment
Issue a written confirmation to the applicant within 72 hours of enrolment
Photograph capture is the spine of cross-venue enforcement — PAGCOR's RPR is photograph-matched, not solely ID-matched.
PAGCOR RG Framework sec. 6
Self-exclusion minimum period
RG Critical
The PAGCOR self-exclusion programme imposes a minimum six-month exclusion, extendable in 12-month increments and convertible to a permanent ban on request. A reinstatement application after the minimum period requires a written request and a counselling-touchpoint acknowledgement before the player can be removed from the register.
Requirements
Apply a minimum six-month self-exclusion with no early-termination route
Offer extension and permanent-ban options at the point of intake
Require a counselling acknowledgement before processing any reinstatement
Maintain a tamper-proof audit trail of every status change
PAGCOR RG Framework sec. 6.2
Reinstatement and post-exclusion cooling-off
RG Critical
After the minimum six-month self-exclusion period elapses, reinstatement is not automatic. The player must lodge a written reinstatement request, complete a counselling touchpoint with a PAGCOR-recognised RG provider, and observe a further 30-day reflection period before the RPR entry is lifted. Permanent self-exclusion is irrevocable in the online channel.
Requirements
Refuse any reinstatement until both the minimum exclusion period AND the 30-day reflection window have elapsed
Require evidence of the counselling touchpoint before lifting the RPR flag
Block reinstatement entirely for any player who selected the permanent online option
Log every reinstatement decision in the PAGCOR audit trail with the case officer's name
PAGCOR RG Framework sec. 7
Family-initiated exclusion petition
RG Critical
A spouse, parent, child of legal age, or sibling may petition PAGCOR to add a relative to the Restricted Persons Register where the petitioner can show that continued gambling is causing demonstrable family or financial harm. PAGCOR's CSR Group reviews the petition with supporting evidence — bank statements, payslips, sworn affidavits — and may exclude the subject for up to five years, subject to a right of reply.
Requirements
Direct family petitioners to the PAGCOR CSR Group with the prescribed petition form
Honour any provisional exclusion notice issued by PAGCOR pending full review
Apply the exclusion across all licensee venues and online channels on receipt of the PAGCOR order
Preserve the subject's right of reply by not disclosing petition contents at venue level
The five-year family-petition ceiling is the longest non-voluntary exclusion under PAGCOR rules; it is rarely applied without independent evidence of harm.
Entry restrictions & age controls 2
PD 1869 sec. 14(a)
Government and uniformed personnel ban
RG CriticalPlayer Rights
Section 14(a) of PD 1869 bars active government officials connected with gaming, members of the Armed Forces of the Philippines, the Philippine National Police and PAGCOR directors and employees from entering PAGCOR-licensed casinos at any time, including on personal leave. The prohibition is absolute and is enforced by ID matching at venue entry.
Requirements
Match every Filipino patron ID against AFP, PNP and PAGCOR employee lists where available
Refuse entry to any matched person and record the refusal
Brief floor staff on the absolute nature of this ban including on personal time
Self-report any breach to PAGCOR within 24 hours
PD 1869 sec. 14(c)
Age 21 floor for Filipino patrons
RG CriticalPlayer Rights
Section 14(c) of PD 1869 prohibits Filipino citizens under 21 years of age from entering PAGCOR-licensed casinos. The PIGO RegFramework extends the same age floor to all online account holders identifying as Filipino citizens or residents.
Requirements
Verify Filipino citizens are 21+ at every entry and online registration
Verify foreign nationals are 18+ at every entry
Refuse service and offer RG support material to any underage attempt
Maintain ID-check logs auditable by PAGCOR
Combined with PIGO's mandatory PhilSys or government-ID KYC, this makes underage online play structurally difficult.
In-product safer gambling 6
PAGCOR RG Framework sec. 8
Mandatory deposit and loss limits (PIGO)
RG Critical
PIGO licensees must offer every player the ability to set daily, weekly and monthly deposit and loss limits at registration and on demand. Reductions take effect immediately; increases are subject to a 24-hour cool-off before they apply.
Requirements
Prompt for deposit and loss limits at account registration
Apply limit reductions immediately and increases only after a 24-hour cool-off
Surface current limits inside the player dashboard at every session
Block deposits and wagers that would breach the active limit
PAGCOR RG Framework sec. 8.3
Wager and session-time limits
RG CriticalGame Design
Beyond deposit and loss caps, every PIGO product must let the player set a maximum single-wager amount and a maximum cumulative session duration. When the session-time limit is reached, the platform must terminate active play, settle open wagers and block re-entry for at least 15 minutes.
Requirements
Expose single-wager and session-duration limit fields in the player RG dashboard
Hard-terminate gameplay when the session limit is reached and settle open wagers
Enforce a minimum 15-minute lockout before the player can re-enter after a session-time cut
Apply tightening to limits immediately; loosening requires the standard 24-hour cool-off
PAGCOR RG Framework sec. 10
Reality checks and session-time prompts
RG CriticalGame Design
PIGO products must surface a reality-check prompt at intervals no longer than 60 minutes of continuous play, displaying elapsed session time, net position and access to the responsible-gambling tools. The player must actively dismiss the prompt to continue.
Requirements
Trigger a reality-check overlay at intervals of 60 minutes or less of continuous play
Display elapsed session time, net win/loss and links to limits, self-exclusion and support
Require active dismissal before play resumes
Log every reality-check event for PAGCOR audit
PAGCOR RG Framework sec. 11
Markers of harm and customer-interaction triggers
RG Critical
Licensees must maintain an automated markers-of-harm engine flagging accounts on triggers including unusually rapid deposit escalation, repeated failed deposits, late-night session concentration, chasing patterns after losses, and use of multiple payment instruments in a short window. A flagged account must receive a documented customer interaction within 72 hours.
Requirements
Operate an automated markers-of-harm rule set covering deposit velocity, failed deposits, late-night play, loss-chasing and instrument multiplicity
Initiate a documented customer-interaction touchpoint within 72 hours of any flag
Escalate repeat or unresolved flags to the RG team for limit reduction or referral to exclusion
Retain markers-of-harm logs and interaction records for at least five years for PAGCOR audit
PAGCOR has signalled that the absence of an effective markers-of-harm engine will be treated as a stand-alone RG breach during 2026 audits.
PAGCOR RG Framework sec. 12
Staff training and customer interaction
RG Critical
Every PAGCOR licensee must train customer-facing staff on markers of harm and require documented customer-interaction interventions when those markers appear. Training must be repeated annually and certified by an accredited responsible-gambling training provider.
Requirements
Complete RG training annually for all customer-facing staff
Document each customer interaction triggered by markers of harm
Maintain training certificates auditable by PAGCOR
Escalate repeated markers to the RG team for review and possible exclusion
PAGCOR RG Framework sec. 13
Default limits for new accounts
RG Critical
Every newly registered PIGO account is opened with a default daily deposit cap of PHP 25,000 and a default weekly cap of PHP 100,000. Players may raise the defaults only after an enhanced affordability touchpoint conducted by the licensee, with documented proof of disposable income retained on file.
Requirements
Open every PIGO account with PHP 25,000 daily and PHP 100,000 weekly default deposit caps
Conduct an enhanced affordability touchpoint before raising any default
Retain disposable-income evidence supporting the uplift for the life of the account plus five years
Apply the default caps immediately on any account reinstated after self-exclusion
Helplines & external support 2
PAGCOR RG Framework sec. 14
Mandatory helpline disclosure
RG Critical
Every PAGCOR-licensed venue and PIGO product surface must prominently display the PAGCOR Responsible Gaming hotline and the Department of Health National Center for Mental Health crisis line (NCMH 1553). Online surfaces must render the helpline in the same font weight as deposit and withdrawal calls-to-action.
Requirements
Display the PAGCOR RG hotline on every venue entrance, ATM, cage and table-game signage block
Surface the DOH NCMH 1553 crisis line on every online RG help page and inside every reality-check overlay
Match helpline typography weight to deposit and withdrawal CTAs in product
Refresh helpline displays whenever PAGCOR or DOH publishes a number change within 30 days
PAGCOR RG Framework sec. 15
In-venue RG signage and collateral
RG Critical
Every land-based casino must post bilingual (English and Filipino) responsible-gambling signage at all entrances, cashier cages and on every gaming table and slot bank, and must stock printed RG brochures at the customer-service desk. Signage must include the PAGCOR RG hotline, the NCMH 1553 number, and the self-exclusion intake instructions.
Requirements
Post bilingual RG signage at every entrance, cage, table and slot bank
Stock current printed RG brochures at the customer-service desk at all times
Include hotline numbers and self-exclusion intake instructions on every sign
Replace damaged or outdated signage within 7 days of detection
Junket & high-roller controls 2
PAGCOR Junket Rule sec. 4
Foreigner-only junket play and watchlist screening
RG CriticalPlayer Rights
Under the PAGCOR Junket Operator Rules, a licensed junket may bring in players only if they are foreign nationals or Filipino citizens with verified residence abroad for at least one year. Junket operators must screen every guest against the PAGCOR Restricted Persons Register, the AMLC sanctions list and the BI immigration watchlist before issuing markers.
Requirements
Verify foreign nationality or one-year-plus overseas residency before junket onboarding
Screen every junket guest against the RPR, AMLC sanctions list and BI watchlist
Refuse junket service to any RPR-listed person regardless of nationality
Submit the junket guest manifest to PAGCOR before each programme
PAGCOR Junket Rule sec. 7
Maximum marker and credit-extension caps
RG Critical
Junket operators must cap the aggregate marker credit extended to any single player at the amount cleared during fit-and-proper review and may not roll over an unpaid marker into a fresh programme. Default on a marker triggers an automatic referral to the licensee's RG team and a written PAGCOR notification within 72 hours.
Requirements
Cap aggregate marker credit at the pre-cleared programme amount per player
Refuse roll-over of any unpaid marker into a subsequent programme
Refer every marker default to the licensee RG team for harm assessment
Notify PAGCOR in writing within 72 hours of any marker default
Player disputes & complaints 2
PAGCOR Dispute Rule sec. 2
Internal complaint-handling window
Player Rights
A PAGCOR licensee must acknowledge any player complaint within 24 hours and issue a substantive written resolution within 15 calendar days. Where the complaint involves a withheld payout, the disputed amount must be ring-fenced and segregated from operating funds until resolution or PAGCOR escalation.
Requirements
Acknowledge every player complaint within 24 hours in writing
Issue a substantive written resolution within 15 calendar days
Ring-fence disputed payouts in a segregated holding account until resolution
Provide PAGCOR escalation instructions in every closing communication
PAGCOR Dispute Rule sec. 4
PAGCOR escalation and binding resolution
Player Rights
Where a player is dissatisfied with the licensee's resolution, the dispute may be escalated to the PAGCOR Gaming Licensing and Enforcement Department, which has authority to issue a binding determination after review of the complete dispute file. PAGCOR decisions are appealable to the PAGCOR Board and then to the Office of the President under PD 1869.
Requirements
Surrender the complete dispute file to PAGCOR on escalation request
Comply with PAGCOR binding determinations within 7 calendar days
Inform the complainant of the appeal route to the PAGCOR Board and the Office of the President
Preserve dispute file records for at least five years post-resolution
PAGCOR's authority to make a binding determination distinguishes the Philippines from many ASEAN markets where dispute escalation is purely advisory.
Marketing rules sit at the intersection of PAGCOR's commercial communications guidelines, MTRCB/DOH broadcast oversight, and the proposed Anti-Online Gambling Bill of 2025 which would ban celebrity endorsements, social-media advertising of online gambling and e-wallet funding. The political pressure point has been Filipino-language influencer content normalising e-sabong-style products.
23 standards23 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Engaging a celebrity or social-media influencer for gambling promotion in breach of the proposed Anti-Online Gambling Bill once passed
Failing to embed mandatory RG warnings in every Filipino-language ad placement
Affiliate channels operating without registration or commission-disclosure transparency
Commercial communications baseline 3
PAGCOR Ad Guidelines sec. 3
Mandatory RG warning and licensee mark
Bonus & AdsRG Critical
Every PAGCOR licensee advertisement, in any medium, must carry a clearly legible responsible-gambling warning and the PAGCOR licensee mark. Broadcast and digital placements must include the warning for the full duration of the spot, not solely on an end card.
Requirements
Embed a clearly legible RG warning on every print, broadcast and digital ad
Display the PAGCOR licensee mark on every placement
Run the warning for the full duration of broadcast spots, not only the end card
File representative samples on request during PAGCOR ad-compliance audits
PAGCOR Ad Guidelines sec. 5
Youth targeting prohibition
Bonus & AdsRG Critical
Gambling advertising in the Philippines may not target persons under 21, may not appear in media where more than 25 percent of the audience is under 21, and may not use imagery, voice talent or endorsers that would have particular appeal to minors.
Requirements
Avoid media buys where audience-under-21 share exceeds 25 percent
Reject creative concepts using talent with primary youth appeal
Maintain age-demographic verification on all media plans
Withdraw any placement found to breach the youth-audience cap within 24 hours
PAGCOR Ad Guidelines sec. 8
Bonus and promotion transparency
Bonus & Ads
Every bonus, free-bet or welcome offer must publish full terms including wagering requirements, time limits, eligible games and maximum cash-out, in a manner accessible at the point the offer is communicated. PAGCOR may direct removal of any offer found to be materially misleading.
Requirements
Publish full bonus terms at the point of promotion, not solely on a separate page
Disclose wagering requirements, time limits, eligible games and maximum cash-out
Withdraw any promotion PAGCOR directs as materially misleading
Retain a versioned archive of every promotion for at least two years
Affiliate & influencer controls 3
SB 2868 (proposed) sec. 6
Celebrity-endorsement and social-media ad ban (proposed)
Affiliate RulesBonus & Ads
Senate Bill 2868 and counterpart House Bills filed in 2025 (the Anti-Online Gambling Bill package) propose to prohibit celebrity, athlete and social-media influencer endorsements of online gambling, ban gambling advertising across social media platforms, and prohibit the funding of gambling accounts via e-wallets and credit cards. As of mid-2026 the package is pending consolidated committee approval.
Requirements
Track committee progress of SB 2868 and counterpart House Bills weekly
Run scenario plans for influencer pause and e-wallet funding cessation
Prepare licensee statements aligning with the political direction of travel
Document the bill's status in the regulatory risk register
Mark this standard as proposed until enactment; PAGCOR may pre-emptively issue circulars aligned with the bill's direction.
MTRCB Circular 2024-01
Broadcast ad classification (MTRCB)
Bonus & Ads
The Movie and Television Review and Classification Board requires all televised gambling advertising to carry an SPG (Strong Parental Guidance) or higher classification and bars placement in time slots before 9pm. PAGCOR advertising guidelines incorporate MTRCB classification by reference.
Requirements
Submit every televised gambling ad to MTRCB for classification
Place gambling ads only in time slots permitted for SPG or higher
Maintain MTRCB classification certificates for every active spot
Withdraw any spot whose classification is downgraded on review
PAGCOR Affiliate Rule 2-2022
Affiliate registration and licensee liability
Affiliate Rules
PAGCOR licensees are accountable for the conduct of every affiliate, marketing partner and tipster channel acting on their behalf. Affiliates must be registered with the licensee, contractually bound to PAGCOR advertising rules and removed within 24 hours of any material breach.
Requirements
Maintain a register of every active affiliate, tipster and marketing partner
Contractually bind affiliates to PAGCOR advertising rules with audit and termination rights
Investigate and terminate any affiliate in material breach within 24 hours
Report repeat-offender affiliates to PAGCOR for industry-wide blacklisting
Broadcast & time-of-day controls 2
PAGCOR Ad Guidelines sec. 4
Broadcast watershed restriction
Bonus & AdsRG Critical
Television and radio advertising of gambling products may not air between 06:00 and 22:00 on free-to-air channels and 06:00 and 21:00 on cable. Sports-betting promotions may not air within 30 minutes before, during, or 30 minutes after a live sporting event broadcast in the Philippines.
Requirements
Schedule TV and radio gambling spots only after 22:00 free-to-air and 21:00 cable
Avoid the 30-minute pre/post window around live Philippine sports broadcasts
Apply the watershed across replays, repeats and on-demand placements of broadcast inventory
Audit ad-trafficking instructions monthly against scheduled airings
MTRCB Circular 2024-02
MTRCB classification and pre-clearance for gambling spots
Bonus & Ads
Under MTRCB Circular 2024-02, every broadcast gambling advertisement must be pre-classified by the Movie and Television Review and Classification Board prior to airing. Spots are issued an SPG (Strong Parental Guidance) classification at minimum, which restricts placement to MTRCB-cleared time slots.
Requirements
Submit every broadcast gambling spot for MTRCB pre-classification before first airing
Carry the MTRCB classification card visibly at the start of each spot
Restrict placements to MTRCB-cleared time slots consistent with the SPG floor
Maintain MTRCB clearance documentation for at least three years
Prohibited content & creative 2
PAGCOR Ad Guidelines sec. 6
Prohibited creative content
Bonus & AdsRG Critical
PAGCOR-licensee advertising may not depict gambling as a path to financial security, professional success, social status or sexual or romantic appeal; may not show winning as a routine or expected outcome; and may not feature persons appearing to be under 25 even if the talent is older. False or unverifiable claims about RTP, jackpot frequency or win rates are prohibited outright.
Requirements
Reject any creative depicting gambling as a route to wealth, success, status or romantic appeal
Refuse storyboards that present winning as a routine outcome
Cast only talent visibly aged 25 or older for any on-screen role
Drop any RTP, jackpot or win-rate claim that cannot be substantiated from PAGCOR-approved data
PAGCOR Ad Guidelines sec. 7
Risk-free and guaranteed-win language ban
Bonus & Ads
Advertising and bonus promotion copy must not use the words "risk-free", "no-risk", "free bet" without immediate qualification, "guaranteed win", "sure thing" or any close translation in Filipino, Cebuano, Hiligaynon or other Philippine languages. The use of "free" in any bonus context requires the wagering requirement to appear at equal prominence.
Requirements
Strike risk-free, no-risk, guaranteed-win and sure-thing language from every placement and language version
Pair any "free bet" or "free spin" claim with the wagering requirement at equal font weight
Audit Filipino, Cebuano and Hiligaynon translations against the same prohibitions
Withdraw non-compliant placements within 24 hours of identification
Endorsement & talent restrictions 2
PAGCOR Ad Guidelines sec. 9
Celebrity and athlete endorsement controls
Affiliate RulesBonus & Ads
Endorsements by celebrities, professional athletes or persons of significant public profile must include a clear, audible disclosure that the endorser is a paid spokesperson. Active Philippine national-team athletes, PBA players and active members of regulated sports may not endorse betting products covering their own sport. PAGCOR may direct removal of any endorsement deemed to glamorise gambling.
Requirements
Disclose paid-spokesperson status audibly in every celebrity or athlete endorsement
Refuse engagements with active national-team or PBA athletes for products covering their own sport
File talent contracts with PAGCOR on request during compliance audits
Terminate any endorsement PAGCOR directs as glamorising gambling within 48 hours
PAGCOR Ad Guidelines sec. 10
Influencer and streamer rules
Affiliate RulesBonus & Ads
Social-media influencers, livestream personalities and content creators promoting a PIGO product must register with the licensee, carry the licensee's PAGCOR licence number in profile bio, label every promotional post with #ad or the platform-native paid-partnership tag, and may not stream gameplay before 22:00 Philippine time. PAGCOR holds the licensee accountable for every influencer post under its banner.
Requirements
Register every promoting influencer and streamer with the licensee before activation
Require PAGCOR licence number in influencer profile bio and #ad labelling on every promotional post
Block all promotional gameplay streams before 22:00 Philippine local time
Audit influencer content weekly and take down non-compliant posts within 24 hours
This is the area most directly targeted by the proposed Anti-Online Gambling Bill — preparing for an outright social-media ban is now standard scenario planning.
Digital, OOH & social channels 2
PAGCOR Ad Guidelines sec. 11
Digital and programmatic targeting controls
Bonus & AdsRG Critical
Digital advertising for PIGO products must use age-gating at the ad-server level (minimum 21+) and must exclude audience segments built from interests including video games marketed to minors, school content, anime targeting under-18s and any segment with a primary audience under 21. Geo-targeting must exclude IP ranges associated with schools, government offices and military bases.
Requirements
Enforce 21+ age-gating at the ad-server and DSP audience-segment level for every digital placement
Exclude audience segments primarily under 21 including minor-marketed gaming and anime
Geo-exclude IP ranges associated with schools, government offices and military installations
Audit ad-server logs monthly for impressions delivered against excluded segments
PAGCOR Ad Guidelines sec. 12
Out-of-home placement restrictions
Bonus & Ads
Billboards, transit panels and other OOH placements promoting gambling products may not be sited within 100 metres of a school, church, hospital or government-recognised youth facility. LGU permit conditions take precedence where stricter; PAGCOR may direct removal of any non-compliant placement at the licensee's cost.
Requirements
Apply a 100-metre exclusion radius around schools, churches, hospitals and youth facilities for all OOH
Defer to stricter LGU permit conditions where they apply
Maintain a geo-tagged inventory of every active OOH placement
Take down any placement PAGCOR directs as non-compliant at the licensee's cost
Affiliate & third-party marketers 2
PAGCOR Affiliate Rule 3-2022
Affiliate commission-structure disclosure
Affiliate Rules
Licensees must publish on a public-facing terms page the basis on which affiliate commissions are paid (revenue share, CPA or hybrid) and may not structure commissions to incentivise targeting of self-excluded or otherwise restricted players. Lifetime negative-carryover clauses are prohibited where they would create an incentive for the affiliate to obscure player harm.
Requirements
Publish affiliate commission basis (revshare / CPA / hybrid) on a licensee terms page
Prohibit commission structures that pay out on traffic sourced from RPR-listed or restricted users
Drop lifetime negative-carryover clauses that disincentivise affiliate harm reporting
Audit affiliate commission ledgers against the published structure quarterly
PAGCOR Affiliate Rule 4-2022
Tipster and prediction-channel controls
Affiliate RulesBonus & Ads
Tipster pages, prediction Telegram channels, YouTube channels and Facebook groups acting on behalf of a PAGCOR licensee may not present picks as guaranteed wins, may not solicit subscription fees gated on bet placement, and must carry the PAGCOR licence mark plus the RG warning on every pinned post or channel description.
Requirements
Audit affiliated tipster channels for guaranteed-win or sure-thing language weekly
Refuse partnership with any tipster gating subscription fees on bet placement
Require PAGCOR licence mark and RG warning in every channel description and pinned post
Terminate non-compliant channels within 7 days of identification
Bonus & promotion conduct 2
PAGCOR Ad Guidelines sec. 13
Welcome-offer wagering-requirement cap
Bonus & AdsRG Critical
Welcome bonus and matched-deposit offers from PIGO licensees may not impose wagering requirements above 35x the bonus amount, and may not require play on games with PAGCOR-certified RTP below 92 percent to clear the requirement. Bonus expiry must be at least 30 days from credit.
Requirements
Cap welcome-offer wagering requirements at 35x the bonus amount
Exclude sub-92% RTP titles from bonus-clearance eligibility
Set a minimum 30-day bonus expiry window from credit
Surface effective wagering, eligible games and expiry in the offer headline communication
PAGCOR Ad Guidelines sec. 14
Targeted-promotion suppression for at-risk players
Bonus & AdsRG Critical
Licensees must suppress all reactivation offers, deposit-bonus emails, free-bet SMS and push notifications to any player who is self-excluded, on the Restricted Persons Register, in an active cool-off, or flagged by the markers-of-harm engine. Suppression lists must be enforced across email, SMS, push, in-product and affiliate channels.
Requirements
Maintain a unified suppression list spanning RPR, self-excluded, cool-off and markers-flagged players
Enforce the suppression list across email, SMS, push, in-product and affiliate channels
Audit suppression performance monthly with a tolerance of zero leaked messages
Treat any suppression breach as a reportable RG incident to PAGCOR within 72 hours
Inter-agency coordination 2
ASC Code 2024
Ad Standards Council pre-clearance
Bonus & Ads
The Ad Standards Council Code applies to gambling advertising in parallel to PAGCOR rules; print, OOH and digital placements must clear ASC review prior to publication. ASC complaints lodged against gambling creative are referred to PAGCOR for parallel enforcement where licensee conduct is implicated.
Requirements
Submit print, OOH and digital gambling creative for ASC pre-clearance prior to publication
Maintain ASC clearance certificates on file for at least three years
Cooperate with parallel PAGCOR enforcement on any ASC complaint referral
Train creative agencies on the ASC Code as a baseline overlay to PAGCOR Ad Guidelines
PAGCOR-DOH MOA 2024
PAGCOR-DOH coordination on NCMH referrals
RG CriticalBonus & Ads
Under the 2024 PAGCOR-Department of Health Memorandum of Agreement, every PAGCOR licensee advertisement, in-product RG screen and venue signage must surface the DOH National Center for Mental Health crisis line 1553 and route inbound RG calls to the NCMH gambling-harm pathway when the caller consents.
Requirements
Display NCMH 1553 on every RG screen, ad placement and venue signage block
Operate a warm-transfer route to NCMH for inbound RG callers who consent
Train RG hotline staff on the NCMH gambling-harm referral pathway
Report quarterly referral volumes to PAGCOR CSR Group
Celebrity and influencer endorsement ban (proposed)
Affiliate RulesBonus & Ads
Senate Bill 686, filed in the 20th Congress as part of the Anti-Online Gambling legislative package, would prohibit any celebrity, athlete, social-media influencer or person of significant public profile from endorsing online gambling products in any medium. Counterpart House Bill 11231 carries the same restriction. The bills remain pending as of 2026.
Requirements
Build celebrity and influencer exit clauses into all active endorsement contracts
Maintain a continuity-of-marketing plan that excludes celebrity and influencer talent
Monitor 20th Congress passage of SB 686 / HB 11231 weekly
Brief the executive team quarterly on bill progression and contingency activation triggers
Proposed standard — included for scenario planning. If enacted, this would be the strictest endorsement ban in ASEAN.
SB 686 (proposed) sec. 7
Social media and e-wallet restrictions (proposed)
Bonus & AdsPlayer Rights
SB 686 would prohibit all paid advertising of online gambling products on social-media platforms accessible to Philippine users and would bar Philippine-licensed e-wallets (GCash, Maya, GrabPay) from processing gambling deposits. HB 11231 would empower the National Telecommunications Commission to block any non-compliant platform.
Requirements
Scenario-plan a full social-media advertising shutdown for online gambling products
Track NTC platform-blocking authority development in companion regulations
Maintain a 90-day implementation runbook against probable passage windows
Proposed standard — the e-wallet restriction would functionally collapse Philippine domestic online deposit funnels overnight.
HB 11231 (proposed) sec. 9
Criminal penalties for unlawful gambling marketing (proposed)
Bonus & AdsAffiliate Rules
House Bill 11231 would impose criminal penalties — fines up to PHP 5 million and imprisonment of up to six years — on persons who advertise, promote or solicit participation in online gambling outside the strict carve-outs of the bill. The penalties would apply jointly to licensees, affiliates, agencies and the talent featured.
Requirements
Map every active marketing surface against the proposed carve-outs to identify exposure
Add criminal-penalty notification clauses to affiliate, agency and talent contracts
Build a rapid takedown protocol triggered by passage of HB 11231
Maintain D&O and E&O coverage adequacy reviews against the proposed PHP 5 million maximum
7
Theme 7
Technical standards & game integrity
Technical certification is delegated to a slate of recognised testing laboratories. PAGCOR sets minimum requirements for RNG, game maths, change-control and live-dealer studios; lab attestations are a precondition for going live.
19 standards19 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Launching a game variant without re-certification of any maths or RNG change
Streaming live dealer content from an unapproved or out-of-country studio
Allowing platform changes to bypass PAGCOR change-control approval
RNG, game maths & change control 3
PAGCOR Tech Standard 2.1
RNG certification
Game Design
Every random number generator used in a PAGCOR-licensed product must be certified by a PAGCOR-recognised testing laboratory against international RNG standards including those used by GLI, BMM, eCOGRA and iTech Labs. Certification covers statistical randomness, unpredictability, non-repeatability and resistance to forecast attack.
Requirements
Source RNG components only with current testing-lab certification
Re-test the RNG on every material change to seed, algorithm or hardware
Maintain the certificate on the licensee compliance file
Block any product from launch until the certificate is on file
PAGCOR Tech Standard 4.3
RTP disclosure and game maths audit
Game DesignPlayer Rights
Every game launched on a PIGO product must publish its theoretical return-to-player percentage and submit the maths model to a recognised testing lab for audit. PAGCOR will reject any product where actual RTP materially deviates from the certified theoretical figure across a defined volume window.
Requirements
Publish the theoretical RTP for every game on the product
Submit the maths model to a recognised testing lab before launch
Monitor actual versus theoretical RTP on a rolling basis
Suspend any title with a material deviation pending investigation
PAGCOR Tech Standard 6.2
System change control
Game Design
Material changes to the gaming platform, RNG, payments engine, KYC integration or RG controls require PAGCOR notification and, depending on impact, prior approval and lab re-certification. Cosmetic-only changes are logged but do not require approval.
Requirements
Classify every change against the PAGCOR materiality matrix before deployment
Notify PAGCOR of all material changes and obtain approval before go-live
Re-certify with the testing lab where required by the matrix
Maintain a versioned change-control log auditable for at least five years
Live dealer & studio approval 2
PAGCOR Tech Standard 11.4
Information security baseline
Player Rights
PIGO licensees must implement an information-security programme aligned with ISO/IEC 27001 controls, including encryption of player data in transit and at rest, multi-factor authentication for administrative access, and an annual independent penetration test reported to PAGCOR.
Requirements
Adopt an ISO/IEC 27001-aligned information security programme
Encrypt player data in transit and at rest with current industry-standard algorithms
Enforce MFA on all administrative and privileged access
Commission an annual independent pen-test and lodge the report with PAGCOR
PAGCOR Tech Standard 9.1
Live dealer studio approval
Game Design
Live dealer content offered to PIGO players must originate from a PAGCOR-approved studio located inside the Philippines, staffed by accredited dealers and supervised by an on-site PAGCOR-approved studio manager. Cross-border streaming of live tables from non-Philippine studios is not permitted for PIGO play.
Requirements
Locate live dealer studios inside Philippine territory
Use only accredited dealers with current PAGCOR clearance
Maintain an on-site PAGCOR-approved studio manager during all stream hours
Block PIGO routing of live tables that originate from non-Philippine studios
Game and System Certification 4
PAGCOR Tech Standard 1.2
Recognised testing laboratories
Game Design
PAGCOR recognises a defined panel of independent testing laboratories for the certification of gaming platforms, RNGs and game content. Currently recognised labs include GLI (Gaming Laboratories International), BMM Testlabs, eCOGRA and iTech Labs. Every gaming system, RNG and individual game made available to Philippine players must carry a current certificate from a recognised lab.
Requirements
Use only PAGCOR-recognised testing labs for platform, RNG and game certification
Hold a current certificate per game version and platform release lodged with PAGCOR
Re-certify after every material change in code, math or platform architecture
Withdraw any game whose certification has lapsed or been revoked
Recognition status can change; check the PAGCOR Technical Services Department register before commissioning a lab.
PAGCOR Tech Standard 2.4
RNG certification and statistical tests
Game Design
Every random number generator used to determine game outcomes for Philippine players must be certified by a PAGCOR-recognised testing lab against a defined battery of statistical tests including chi-squared, serial correlation, runs, poker and gap tests. Certification is per RNG version; re-certification is required after any source-code change, seed-mechanism change or platform port.
Requirements
Submit every RNG version to a recognised lab for full statistical test-battery certification
Re-certify the RNG after any source-code, seed or platform change
Lodge the full certification report with PAGCOR before commercial launch
Document the entropy source and reseeding cadence in the technical operations manual
PAGCOR Tech Standard 3.1
Minimum theoretical return-to-player
Game DesignPlayer Rights
Slot, table and specialty games offered to Philippine players must carry a theoretical return-to-player of not less than 85 percent over the long-run, evidenced by the testing-lab math certification. Operators must publish or make available on request the certified theoretical RTP for every live game.
Requirements
Maintain a certified theoretical RTP of at least 85 percent for every live game
Surface the certified RTP to players on request or via in-game information
Withdraw any game whose math drift causes the certified RTP to fall below the floor
Re-certify after any pay-table change before re-deploying the game
PAGCOR Tech Standard 5.2
Game-launch certification filing
Game Design
Before any new game is made available to Philippine players, the licensee must file a game-launch package comprising the testing-lab certificate, the game math, the paytable, the help screens, the RG configuration and a screenshot pack. PAGCOR Technical Services has 15 working days to object; absent objection the game may launch.
Requirements
Bundle lab certificate, math, paytable, help screens, RG config and screenshots in every launch package
File at least 15 working days before intended launch
Hold launch if PAGCOR raises any non-conformance until cleared in writing
Maintain a chronological launch register lodged with PAGCOR at each audit
Change Control and Releases 2
PAGCOR Tech Standard 7.1
System change-control procedure
Player Rights
Material changes to the gaming platform, RNG, wallet, account or reporting subsystems must follow a documented change-control procedure including impact assessment, regression testing, lab re-certification where applicable, and PAGCOR notification before promotion to production. Emergency hotfixes may be promoted under a defer-and-document exception with PAGCOR notification within 24 hours.
Requirements
Run every material change through a documented impact-assessment and regression-test process
Notify PAGCOR Technical Services in writing before promoting material changes to production
Trigger lab re-certification for any change touching outcome determination, math, RNG or wallet
Notify PAGCOR within 24 hours of any emergency hotfix and back-fill formal change documentation
PAGCOR Tech Standard 7.4
Version and build attestation
Player Rights
Each gaming platform release in production must carry a tamper-evident build attestation matching the lab-certified hash. PAGCOR inspectors may compare the production hash to the certified hash at any time; any mismatch is treated as an uncertified deployment and grounds for immediate suspension of the affected service.
Requirements
Generate and store a tamper-evident build hash for every certified release
Make the production hash and certificate available to PAGCOR inspectors on demand
Halt deployment of any build whose hash does not match the lab-certified value
Investigate and report any hash mismatch to PAGCOR within 24 hours
Infrastructure and Resilience 2
PAGCOR Tech Standard 8.2
Disaster recovery and RTO targets
Player Rights
PIGO and PAGCOR e-Games platforms must maintain a documented disaster-recovery plan with a recovery-time objective of no more than four hours for player-facing wagering services and no more than 24 hours for full reporting and back-office functions. The plan must be tested at least annually with a written report lodged with PAGCOR.
Requirements
Maintain a DR plan with RTO of no more than four hours for wagering services
Test the DR plan at least annually under realistic failure scenarios
Lodge the annual DR test report with PAGCOR within 30 days of completion
Update the plan after any material change in architecture or any actual incident
PAGCOR Tech Standard 8.5
Data retention and log integrity
Player Rights
Gaming transaction logs, player account events, geo-location records and surveillance feeds must be retained in tamper-evident form for not less than five years. Logs must be cryptographically signed at write time and protected against retrospective alteration; deletion or modification is prohibited within the retention period.
Requirements
Retain transaction, account, geo-location and surveillance logs for at least five years
Apply cryptographic signing or equivalent tamper-evidence at write time
Block deletion or modification of logs within the retention period
Provide PAGCOR with audit-time access to the full retained log set
Information Security 2
PAGCOR Tech Standard 10.1
Information security management system
Player Rights
Every PIGO and PAGCOR-licensed online operator must implement an information security management system aligned to ISO/IEC 27001 controls, with PAGCOR-acceptable independent assurance at least annually. The ISMS must cover identity and access management, cryptography, network security, secure development and incident response.
Requirements
Implement an ISMS aligned to ISO/IEC 27001 controls across the gaming environment
Obtain annual independent assurance acceptable to PAGCOR
Cover IAM, cryptography, network security, secure development and incident response
Remediate audit findings within agreed timelines and report progress to PAGCOR
PAGCOR Tech Standard 10.3
Penetration testing cadence
Player Rights
PIGO platforms must undergo full external penetration testing at least annually by an independent CREST-equivalent assessor, with targeted re-testing after any material architectural change or critical-severity finding. Reports and remediation evidence must be lodged with PAGCOR within 30 days of test completion.
Requirements
Commission annual external penetration tests by an independent CREST-equivalent firm
Re-test after any material architectural change or critical-severity finding
Lodge full report and remediation evidence with PAGCOR within 30 days
Close critical findings within 30 days and high findings within 90 days of report receipt
Incident Reporting 2
PAGCOR Tech Standard 12.1
Incident severity tiers and notification deadlines
Player Rights
Technical incidents affecting a PIGO platform are classified by severity. Tier-1 incidents (loss of wager integrity, exposure of player data, prolonged service outage) require notification to PAGCOR within two hours. Tier-2 (material degradation, security breach without confirmed data loss) within 24 hours. Tier-3 (operational anomalies) within 5 working days via the monthly incident report.
Requirements
Operate a documented incident severity matrix mapped to PAGCOR tiers 1-3
Notify PAGCOR of Tier-1 incidents within two hours of detection
Notify Tier-2 incidents within 24 hours and Tier-3 within the monthly report cycle
File a post-incident root-cause analysis for every Tier-1 and Tier-2 event
PAGCOR Tech Standard 12.4
Game malfunction handling and player restitution
Game DesignPlayer Rights
A confirmed game malfunction voids all affected plays and outcomes. Players must be restored to their pre-malfunction position; wagers must be returned and any erroneous winnings reversed. PAGCOR must be notified within 24 hours and the affected game suspended pending root-cause analysis and lab re-validation.
Requirements
Suspend the affected game immediately on detection of a malfunction
Restore affected players to their pre-malfunction account position
Notify PAGCOR within 24 hours with preliminary impact assessment
Re-enable the game only after root-cause analysis and lab re-validation
Live Dealer and Studio 2
PAGCOR Tech Standard 13.1
Live dealer studio approval
Game DesignPlayer Rights
Live dealer content streamed to Philippine PIGO players must originate from a PAGCOR-approved studio located inside the Philippines. Studio approval covers physical security, CCTV coverage of every gaming table, dealer training and certification, table equipment certification and resilient network egress.
Requirements
Stream live dealer content only from PAGCOR-approved studios located in the Philippines
Maintain full CCTV coverage of every gaming table with synchronised game data
Certify dealers under a PAGCOR-recognised training programme
Certify table equipment (shoes, wheels, RFID chips) under the same testing-lab regime as RNG products
PAGCOR Tech Standard 13.3
Studio CCTV recording and retention
Player Rights
Live dealer studios must record every gaming table continuously with audio and video synchronised to the game-event log. Recordings must be retained for at least 90 days for routine inspection and at least five years for any table-round subject to a complaint, investigation or audit.
Requirements
Record every live dealer table continuously with synchronised audio, video and game log
Retain routine CCTV for at least 90 days
Retain CCTV linked to any complaint or investigation for at least five years
Provide PAGCOR with on-demand access to any retained recording
8
Theme 8
Player accounts, KYC & funds protection
PIGO account rules mandate one verified account per player, government-ID KYC linked to PhilSys or comparable IDs, segregated player funds and withdrawal only to the originating funding source. Cash play limits dovetail with the AMLA threshold.
15 standards15 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Allowing multi-account abuse or shared device exploits
Withdrawing funds to a destination different from the originating source
Mixing player funds with operating funds in a single corporate account
Account integrity & KYC 2
PIGO RegFramework rule 9.1
One verified account per player
Player Rights
Each natural person may hold no more than one active PIGO account per licensee, identified by verified government ID. Operators must run device-fingerprint and identity-deduplication checks at registration and on an ongoing basis.
Requirements
Run identity-deduplication at registration against verified ID
Run device-fingerprint checks at registration and ongoing
Close any duplicate account on detection and reconcile balances
Report repeat-attempt fraud patterns to PAGCOR
PIGO RegFramework rule 9.4
Government-ID KYC
Player Rights
PIGO KYC accepts PhilSys National ID, SSS, GSIS, Philippine Passport, Driver's Licence and Unified Multi-Purpose ID, validated against authoritative data sources where available. Foreign nationals registering from inside the Philippines must present a passport plus proof of lawful presence.
Requirements
Accept only the prescribed list of government-issued IDs for Filipino KYC
Validate IDs against authoritative data sources where APIs are available
Require passport plus proof of lawful presence for foreign nationals
Block registration on ID validation failure
Funds protection & payments 3
PIGO RegFramework rule 11.2
Segregated player funds
Player Rights
Player deposit balances must be held in a dedicated bank account segregated from licensee operating funds, with a maintained reserve sufficient to satisfy all outstanding player balances at any point in time. PAGCOR may direct an independent attestation of segregation at any time.
Requirements
Maintain a dedicated segregated bank account for player deposit balances
Reconcile balances daily against outstanding player liabilities
Maintain a reserve at least equal to total outstanding player balances
Produce independent segregation attestations on PAGCOR demand
PIGO RegFramework rule 11.5
Withdrawal to source account
Player Rights
Withdrawals must be paid only to the same funding source used for the originating deposit. Where the source is unavailable, the player must complete additional verification before an alternative payout destination is approved.
Requirements
Pay withdrawals only to the originating deposit source
Require additional KYC when the source is unavailable and an alternative payout is requested
Document every alternative-payout decision
Block any third-party payout request as standard
PIGO RegFramework rule 11.7
Cash play limits aligned to AMLC threshold
RG CriticalPlayer Rights
PIGO deposit and wager controls must enforce hard caps that align with the AMLC PHP 5 million covered-transaction threshold, including aggregation across cash-in events within a defined look-back window. Cumulative breaches trigger automatic STR escalation.
Requirements
Enforce hard caps aligned to the AMLC PHP 5 million threshold
Aggregate cash-in events across a defined look-back window
Auto-trigger STR escalation on cumulative threshold breach
Document threshold logic in the AML control narrative
Player Account Lifecycle 3
PIGO RegFramework rule 8.1
Single account per player
RG CriticalPlayer Rights
A PIGO player may hold only one account per licensee. Duplicate accounts identified through PhilSys ID, government ID number, device fingerprint or biometric match must be closed within 24 hours, with consolidated balance returned to the player via the verified withdrawal channel.
Requirements
Detect duplicate accounts via PhilSys, government ID, device fingerprint and biometric match
Close duplicates within 24 hours of confirmation
Consolidate balances and return to the player via the verified withdrawal channel
Maintain an auditable duplicate-detection log for PAGCOR review
PIGO RegFramework rule 8.3
Account verification using PhilSys or government ID
RG CriticalPlayer Rights
Before a PIGO account may place its first wager, the licensee must verify the player's identity, age (21+), Philippine residency and address using PhilSys National ID where available, or two accepted government-issued IDs in the alternative. Unverified accounts may be funded but not used for wagering, and unverified balances must be returned if verification is not completed within 30 days.
Requirements
Verify identity, age 21+, residency and address before the first wager
Accept PhilSys National ID as primary or two government-issued IDs in the alternative
Block wagering on any unverified account
Return unverified balances to source within 30 days of failed verification
PIGO RegFramework rule 8.7
Dormant account handling
Player Rights
A PIGO account with no log-in or wager activity for 12 consecutive months is treated as dormant. The licensee must attempt at least three documented contacts and then return the balance to the player's verified withdrawal channel; balances of unreachable players are escheated to PAGCOR after a further 12 months in line with the dormant-funds rule.
Requirements
Flag accounts dormant after 12 consecutive months without log-in or wager
Attempt at least three documented player contacts before any escheat
Return balances to the verified withdrawal channel where reachable
Escheat unclaimed dormant balances to PAGCOR after a further 12 months
Funding and Withdrawals 3
PIGO RegFramework rule 10.1
Permitted account funding channels
RG CriticalPlayer Rights
PIGO accounts may be funded only from payment channels held in the player's own verified name: Philippine bank accounts, BSP-licensed e-money wallets, debit cards and other PAGCOR-approved methods. Cash deposits, cryptocurrency and third-party wallets are prohibited. The funding-source name must match the verified KYC name; mismatches must be rejected and reviewed.
Requirements
Accept funding only from channels held in the player's own verified name
Block cash, cryptocurrency and third-party wallet funding
Reject funding instruments whose name does not match the verified KYC record
Maintain a payments-method register lodged with PAGCOR and updated on change
PIGO RegFramework rule 10.4
Withdrawal to source account only
RG CriticalPlayer Rights
Withdrawals from a PIGO account must be returned to the same verified channel from which funds were deposited (closed-loop), with any net winnings paid to the player's primary verified bank account or e-money wallet. Cash withdrawals and withdrawals to third-party instruments are prohibited.
Requirements
Return deposits via the same closed-loop channel they were funded from
Pay net winnings only to a verified primary bank account or e-money wallet in the player's name
Block all cash withdrawals and all third-party payouts
Document AML decisioning for any withdrawal materially exceeding deposit patterns
PIGO RegFramework rule 10.7
Customer fund segregation
Player Rights
Player wallet balances must be held in a segregated account at a BSP-licensed bank, distinct from the licensee's operating funds and not available to operational creditors in the event of insolvency. The segregated balance must equal or exceed aggregate player liability at end of each business day, with monthly attestation lodged with PAGCOR.
Requirements
Hold player wallet funds in a segregated BSP-licensed bank account
Reconcile segregated balance to aggregate player liability at end of every business day
Top up any shortfall on the next business day
Lodge monthly segregation attestation, signed by the CFO and AMLCO, with PAGCOR
Player Limits and Session Controls 3
PAGCOR RG Framework sec. 9
Bonus wagering cap and forfeiture rules
Bonus & AdsRG Critical
Bonus and free-bet wagering requirements on PIGO products may not exceed a multiple of the bonus amount prescribed by PAGCOR, with forfeiture rules clearly disclosed at the point of acceptance. Any unmet wagering requirement may not extinguish player deposits — only the unwagered bonus portion may be forfeited.
Requirements
Cap bonus wagering requirements at the PAGCOR-prescribed multiple
Disclose forfeiture rules clearly at the moment the bonus is accepted
Protect player deposits from forfeiture for unmet wagering requirements
Maintain a versioned archive of every bonus T&Cs for at least two years
PIGO RegFramework rule 12.1
Default deposit limit at registration
RG Critical
PIGO licensees must apply a default monthly deposit limit at account registration unless the player actively elects a different value, with the default set at a level PAGCOR may prescribe and update. Any election above the default requires explicit acknowledgement of the RG implications and is subject to the 24-hour cool-off on increases under the RG Framework.
Requirements
Apply a PAGCOR-prescribed default monthly deposit limit at registration
Require an explicit RG acknowledgement for any election above the default
Apply the 24-hour cool-off on any subsequent increase
Surface the active limit and the time-since-last-change at every deposit attempt
PIGO RegFramework rule 12.4
Session time cap and forced break
RG CriticalGame Design
After three continuous hours of play in a single session, the PIGO platform must enforce a mandatory break of at least 15 minutes during which the player cannot place a wager. The forced-break event must be logged and surfaced inside the player's activity history.
Requirements
Enforce a mandatory 15-minute break after three continuous hours of play
Block wager submission during the forced break and surface the break clearly
Log every forced-break event for PAGCOR audit
Display forced-break occurrences in the player's activity history
Reporting and Audit 1
PAGCOR Audit Reg sec. 5
Monthly and annual reporting cadence
Player Rights
PIGO licensees must file monthly operational returns covering GGR, active players, deposits, withdrawals, bonus expense and complaint statistics, and an annual independently-audited financial and compliance report. Monthly returns are due by the 15th of the following month; the annual report is due within 120 days of fiscal year-end.
Requirements
File monthly operational returns by the 15th of the following month
Cover GGR, active players, deposits, withdrawals, bonus expense and complaints in every return
Lodge an independently-audited annual financial and compliance report within 120 days of FYE
Retain underlying records for at least five years for PAGCOR re-audit
9
Theme 9
Land-based & ancillary categories
Beyond casinos and online, PAGCOR licenses e-Games (PeGS) cafes, e-Bingo halls and specialty games and accredits MICE venue categories. The integrated-resort regime in Entertainment City and Clark is governed by individual Casino Licence Conditions sitting under the Charter.
9 standards9 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Operating an e-Games or e-Bingo product on inappropriate licensing scope
Co-locating gambling with public-access retail in breach of distance rules from schools and churches
Misclassifying a venue under MICE to avoid full casino-grade compliance
Integrated resort & casino licensing 1
PAGCOR Casino Licence Condition 1
Integrated resort casino licence conditions
Player Rights
Integrated resort casinos in Entertainment City and Clark operate under bespoke Casino Licence Conditions issued by PAGCOR, covering investment commitments, non-gaming-to-gaming ratio, junket operator accreditation, surveillance standards and revenue-share calculation.
Requirements
Meet the investment commitment milestones on the agreed schedule
Maintain the non-gaming-to-gaming ratio prescribed by the licence
Use only PAGCOR-accredited junket operators
Submit revenue-share calculations on the monthly cycle
e-Games, e-Bingo & specialty 3
PAGCOR Specialty Games Rule 1
Specialty games classification
RG Critical
Specialty games include traditional Filipino games of chance and other non-casino products approved by PAGCOR on a case-by-case basis. Online sabong (e-sabong) was previously permitted under this category but was prohibited by President Duterte in 2022 and remains prohibited.
Requirements
Apply for case-by-case specialty-games approval before any launch
Treat e-sabong as prohibited and refuse any application or accreditation
Maintain a register of approved specialty products
Withdraw any product on PAGCOR specialty-class revocation
PBBM/Duterte order banning e-sabong remains in force; enforcement actions continued in 2024-2025 against residual online cockfighting platforms.
PAGCOR e-Bingo Rule 2
e-Bingo hall licensing
Game Design
Electronic bingo halls are licensed by PAGCOR as a distinct product class, with caps on the number of terminals, mandatory shift-based supervision and an audit trail of every drawn card and prize payout. Co-location with PeGS is permitted only under a combined venue licence.
Requirements
Hold a distinct e-Bingo product licence per hall
Comply with PAGCOR terminal caps and supervision rules
Maintain an auditable trail of every drawn card and prize payout
Apply for a combined venue licence where co-located with PeGS
PAGCOR e-Games Rule 3
PAGCOR e-Games (PeGS) cafe licensing
RG Critical
PAGCOR Electronic Gaming Sites (PeGS) are licensed remote-betting venues offering electronic table games and slots delivered from a PAGCOR-controlled central system. PeGS operate under venue-level licences with strict distance rules from schools, churches and government buildings.
Requirements
Hold a venue-level PeGS licence per location
Comply with statutory distance rules from schools, churches and government buildings
Connect only to the PAGCOR-controlled central system for game content
Restrict entry to age 21+ for Filipino patrons
Land-based Casino Operations 2
PAGCOR IR Licence Condition 3
Chip and cash handling at integrated resorts
Player Rights
Integrated resort casino licensees must operate chip issuance, redemption and cash-cage handling under documented dual-control procedures with full CCTV coverage. Every cage transaction at or above the AMLA covered-transaction threshold must be linked to a verified patron record before chips are issued or cash is paid out.
Requirements
Operate cage and table chip handling under documented dual-control procedures
Maintain CCTV coverage of every cage transaction with retention aligned to PAGCOR audit cycles
Link every threshold transaction to a verified patron record before completion
Reconcile cage inventory to the gaming system at end of every shift
PAGCOR IR Licence Condition 5
Surveillance room and recording standards
Player Rights
Every PAGCOR-licensed integrated resort must operate a dedicated surveillance room with continuous live monitoring of all gaming tables, slot floors, cages, count rooms, entrances and exits. Recordings must be retained for at least 30 days, extended to five years for any incident or PAGCOR-directed hold.
Requirements
Operate a 24/7 surveillance room covering all gaming, cage and count areas
Retain routine recordings for at least 30 days
Extend retention to five years for any incident or PAGCOR hold
Restrict surveillance access to vetted staff with logged entry/exit
e-Games and e-Bingo Venues 2
PAGCOR e-Games Manual sec. 4
PeGS venue and terminal standards
RG CriticalPlayer Rights
PAGCOR e-Games (PeGS) cafes must comply with venue siting rules including minimum distances from schools and places of worship, certified gaming terminals with tamper-evident seals, supervised access controls, age verification at entry and CCTV across the floor. Terminal software must match the lab-certified build hash at all times.
Requirements
Comply with PAGCOR minimum distance rules from schools and places of worship
Operate only certified gaming terminals with tamper-evident seals intact
Verify patron age at every entry and refuse Filipinos under 21
Maintain floor CCTV with retention aligned to PAGCOR audit cycles
PAGCOR e-Bingo Manual sec. 6
e-Bingo network and prize-pool standards
Game DesignPlayer Rights
Networked e-Bingo halls must connect to a PAGCOR-approved central system that arbitrates prize-pool contributions, jackpot triggers and per-card draw outcomes. Per-card prize-pool contributions, current jackpot values and recent winners must be displayed in-hall and reconciled to the central system daily.
Requirements
Connect every e-Bingo hall to a PAGCOR-approved central system
Display contribution rates, jackpot values and recent winners visibly in-hall
Reconcile hall activity to the central system daily
Pay jackpots only after central-system verification and KYC of the winner
Cashless Gaming 1
PAGCOR Cashless Reg sec. 2
Electronic wallet and TITO standards
RG CriticalPlayer Rights
Cashless gaming products including patron e-wallets, ticket-in-ticket-out (TITO) and chip-cashout solutions must be certified by a PAGCOR-recognised lab, integrate with the casino management system in real time, and apply AMLA covered-transaction monitoring across the cashless flow. Anonymous prepaid instruments are prohibited.
Requirements
Certify every cashless solution (e-wallet, TITO, chip-cashout) under PAGCOR-recognised labs
Integrate cashless transactions with the CMS in real time for AMLA monitoring
Block anonymous prepaid instruments and require KYC linkage on issuance
Reconcile cashless instruments daily and report unreconciled values to PAGCOR within 24 hours
10
Theme 10
Enforcement & sanctions
Illegal gambling is a criminal offence under PD 1602 and RA 9287; PAGCOR maintains a parallel administrative sanction ladder covering warnings, fines, suspension and revocation. Inter-agency enforcement against unlicensed online operators, e-sabong remnants and POGO run-off has intensified through 2024-2025.
29 standards19 player-flagged
66%
player-flagged
Regulatory risks this theme addresses
Criminal exposure under PD 1602 for participation in illegal gambling
Criminal exposure under RA 9287 for illegal numbers games including jueteng, masiao and last two
Administrative penalties scaling to licence revocation for serious AML, RG or technical breaches
Illegal gambling statutes 2
PD 1602 sec. 1
Illegal gambling penalties
Player Rights
Presidential Decree 1602 of 1978 imposes graduated criminal penalties for participation in illegal gambling, increasing for maintainers, operators and protectors of unlicensed games. Penalties scale from arresto menor to prisión correccional and substantial fines.
Requirements
Treat any unlicensed gambling activity inside the Philippines as criminal under PD 1602
Refer suspected illegal gambling to PNP and PAGCOR enforcement
Document the line between PAGCOR-licensed activity and conduct potentially capturable under PD 1602
Maintain staff training on PD 1602 exposure for venue and platform staff
RA 9287 sec. 3
Illegal numbers games (jueteng, masiao, last two)
Player Rights
Republic Act 9287 of 2004 increased the penalties for illegal numbers games including jueteng, masiao and the last two, with escalating penalties for collectors, coordinators, financiers and government protectors. The Act remains the principal anti-illegal-lottery statute alongside PD 1602.
Requirements
Recognise jueteng, masiao and last two as criminal offences under RA 9287
Refuse any business relationship that could constitute coordination or financing under the Act
Train enforcement liaison staff on RA 9287 escalation pathways
Maintain records demonstrating the licensed product is outside RA 9287's perimeter
PAGCOR administrative sanctions 6
PAGCOR Sanction Schedule sec. 2
Administrative sanction ladder
Player Rights
PAGCOR's administrative sanction schedule escalates from written warning through monetary fine, partial suspension of operations, full suspension of licence, and revocation. Aggravating factors include AML failures, RG breaches affecting minors or self-excluded persons, and repeat technical-control failures.
Requirements
Maintain a sanctions-history register and brief the board quarterly
Self-report material breaches promptly to limit aggravating treatment
Treat any AML failure or under-21 admission as a high-aggravation event
Maintain contingency plans for partial-suspension scenarios
PAGCOR Sanction Schedule sec. 3
Fine ladder — first, second and third violation tiers
Player Rights
The PAGCOR Sanction Schedule sets a tiered fine ladder applied to PIGO, land-based and e-Bingo licensees. First violations of a documented compliance standard attract administrative fines from PHP 100,000 to PHP 500,000; second violations from PHP 500,000 to PHP 2 million; third and subsequent violations from PHP 2 million up to PHP 10 million plus possible suspension. RG-critical, AML and geo-fence breaches are escalated to the upper band on first offence.
Requirements
Treat RG, AML and geo-fence breaches as upper-band exposure on first occurrence
Track first-violation findings carefully — second-tier escalation is automatic on repeat
Self-report material breaches early to mitigate fine multiplier under PAGCOR's cooperation policy
Budget remediation work to avoid third-tier suspension exposure
PAGCOR Sanction Schedule sec. 5
Suspension tiers — product, site and licence-wide
Player Rights
Beyond monetary penalties, PAGCOR may impose graduated operational suspensions: product-class suspension (e.g. e-Casino paused while sports betting continues), site-level suspension (a specific PIGO operations centre taken offline) and full licence-wide suspension. Each tier requires written findings, a hearing opportunity and a defined remediation roadmap before reinstatement.
Requirements
Map every product, site and licence-wide suspension trigger before launch to avoid surprise enforcement
Exercise the hearing right and submit a remediation roadmap to limit suspension duration
Communicate suspensions transparently to affected players including return of funds
Track reinstatement conditions and evidence requirements throughout the suspension period
PAGCOR Sanction Schedule sec. 7
Revocation grounds and consequences
Player Rights
PAGCOR may revoke a licence on grounds including a conviction under RA 12312, RA 10175 or the AMLA; a finding of repeated material RG or geo-fence breach; a determination that the fit-and-proper test is no longer met by any UBO or key officer; or a finding of fraud in the application. Revocation triggers automatic forfeiture of the operating bond, return of player funds within 30 days, and a five-year bar on reapplication by the same controlling persons.
Requirements
Recognise conviction-based revocation as an automatic consequence — there is no discretion to retain the licence
Maintain a current operating bond sufficient to cover known revocation triggers
Pre-position player-funds return logistics within the 30-day statutory window
Track the five-year bar against any group restructuring or successor-application plans
PAGCOR Enforcement Bulletin 2025-03
Unlicensed online gambling site blocking
Player Rights
PAGCOR coordinates with the National Telecommunications Commission and the Department of Information and Communications Technology to issue DNS-level blocking orders against unlicensed online gambling sites accessible to Philippine residents. Operators of unlicensed sites may also face PD 1602 referral.
Requirements
Treat any unlicensed online gambling targeted at Philippine residents as PAGCOR enforcement priority
Report unlicensed sites identified during competitive monitoring to PAGCOR
Cooperate with NTC and DICT blocking workflow where requested
Track blocking enforcement actions as a regulatory-risk indicator
PBBM e-Sabong Order 2022
Online cockfighting (e-sabong) prohibition
RG CriticalAffiliate Rules
By presidential directive in 2022, online sabong operations were suspended and have since been treated as prohibited. Inter-agency enforcement through 2024-2025 has continued against residual platforms, social-media-only e-sabong promoters and informal cash collection rings linked to historical operators.
Requirements
Refuse any application, accreditation or commercial engagement linked to e-sabong
Cooperate with PNP, NBI and DICT in domain takedown actions
Report any approach by historical e-sabong operators to PAGCOR enforcement
Treat 'sabong' branding as a high-risk affiliate keyword
PD 1869 — Penal provisions 3
PD 1869 sec. 19
Criminal penalties for unauthorised gambling
Section 19 of PD 1869 criminalises operating, maintaining or participating in any game of chance not authorised by PAGCOR or by special law, carrying imprisonment from one to six years and a fine on top of any forfeitures. The provision applies independently of PD 1602 and gives PAGCOR a direct charter-level basis to refer enforcement matters to the DOJ.
Requirements
Treat any unlicensed game of chance as a criminal offence under PD 1869 sec. 19 as well as PD 1602
Refer unauthorised operations to the DOJ with the PAGCOR sec. 19 charging package
Preserve evidence sufficient to support charter-level prosecution alongside PD 1602 counts
Cooperate with PNP and NBI on parallel raids against unlicensed gambling sites
PD 1869 sec. 20
Aiding and abetting unauthorised gambling
Affiliate Rules
Section 20 of PD 1869 extends criminal liability to persons who knowingly aid, abet, finance, lease premises to, or otherwise facilitate unauthorised gambling. The provision reaches landlords, payment facilitators and marketing partners whose conduct enables an unlicensed operation regardless of whether they directly take wagers.
Requirements
Refuse to lease, finance or process payments for any unauthorised gambling operation
Conduct enhanced due diligence on tenants and payment counterparties in gambling-adjacent sectors
Terminate any affiliate or marketing arrangement that channels users to unlicensed sites
Self-report any suspected aiding-and-abetting exposure to PAGCOR and AMLC
PD 1869 sec. 21
Forfeiture of equipment and proceeds
Section 21 of PD 1869 authorises the forfeiture of gambling equipment, paraphernalia and the proceeds of unauthorised gambling to the government upon conviction. The forfeiture remedy operates alongside PD 1602 and the AMLA's civil-forfeiture regime under RA 9160 as amended.
Requirements
Recognise that conviction under PD 1869 triggers automatic forfeiture of equipment and proceeds
Preserve chain-of-custody on seized devices, terminals and servers for PAGCOR-led enforcement
Coordinate civil forfeiture under the AMLA where the proceeds analysis fits
Treat seized assets as state property pending disposition by court order
RA 9287 — Anti-Illegal Numbers Games 5
RA 9287 sec. 2
Statutory definitions of illegal numbers games
Section 2 of RA 9287 defines the illegal numbers games jueteng, masiao and last two, together with the operational roles of bettor, collector or cabo, coordinator, maintainer or manager, financier or capitalist, and protector or coddler. The granular role definitions are what allow the Act to scale penalties by participation tier and to reach financiers and protectors as well as street-level collectors.
Requirements
Apply the RA 9287 role definitions when characterising suspected illegal-lottery activity
Distinguish bettors from collectors, coordinators, maintainers, financiers and protectors for charging purposes
Recognise jueteng, masiao and last two as distinct statutory game forms
Reference RA 9287 sec. 2 definitions in any cooperation with PNP or NBI
RA 9287 sec. 4
Possession of illegal-numbers paraphernalia
Section 4 of RA 9287 creates a presumption of involvement in illegal numbers games for persons found in possession of tally sheets, lists of bettors, payout records and other paraphernalia associated with jueteng, masiao or last two. The presumption shifts the evidentiary burden and is a key prosecutorial tool given the cash-based, decentralised nature of the trade.
Requirements
Recognise possession of illegal-numbers paraphernalia as a self-standing offence with rebuttable presumption
Preserve seized tally sheets, ledgers and payout records as primary evidence
Cooperate with PNP raids targeting collector and coordinator inventory
Train compliance staff to distinguish licensed bingo and lottery paraphernalia from illegal-numbers items
RA 9287 sec. 5
Government employee and official liability
Section 5 of RA 9287 imposes elevated penalties on any public officer or employee found to have engaged in, financed, coddled or protected illegal numbers games, including absolute perpetual disqualification from public office. The provision targets the historical pattern of local-government protection that has shielded jueteng networks.
Requirements
Recognise public-officer protection of illegal numbers games as a criminal offence with disqualification
Cooperate with Ombudsman and DILG investigations of LGU-level protection
Refuse any informal arrangement with public officials touching illegal-gambling tolerance
Self-report attempted solicitation of protection payments by public officials
RA 9287 sec. 6
Informer reward and witness protection
Section 6 of RA 9287 grants informers and prosecution witnesses a cash reward from a percentage of fines collected and admits them to the Witness Protection Programme of the Department of Justice. The combined reward-plus-protection mechanism is designed to break the local-protection problem by incentivising disclosure from within the operation.
Requirements
Recognise the informer-reward and WPP regime when supporting enforcement referrals
Route confidential disclosures through DOJ-authorised intake channels
Maintain whistleblower-style internal channels that map cleanly to the DOJ WPP
Document any informer-related risk in safeguarding plans
RA 9287 sec. 7
Prosecution and coordination roles
Section 7 of RA 9287 designates the Philippine National Police, the National Bureau of Investigation and the DOJ as the lead agencies for enforcement, with PAGCOR providing technical and licensing intelligence. The provision codifies the inter-agency model that EO 13 later strengthened across the broader illegal-gambling perimeter.
Requirements
Coordinate enforcement intelligence through PNP, NBI, DOJ and PAGCOR channels
Maintain PAGCOR-side technical and licensing data to support cross-agency casework
Reference RA 9287 sec. 7 and EO 13 jointly when documenting enforcement cooperation
Track DILG and Ombudsman parallel cases involving local-government actors
PD 1602 — Anti-illegal-gambling penalties 3
PD 1602 sec. 1(b)
Maintainer and conductor liability
PD 1602 imposes substantially higher penalties on maintainers, conductors or bankers of illegal gambling than on ordinary bettors, escalating from arresto mayor to prisión correccional in its maximum period plus heavier fines. The tiered structure is mirrored by RA 9287 and recurs across modern enforcement against unlicensed online sites.
Requirements
Recognise that maintainers, conductors and bankers face significantly higher PD 1602 penalties than ordinary bettors
Apply the maintainer/conductor characterisation to operators of unlicensed online sites where appropriate
Cooperate with prosecution packaging that distinguishes operational tiers
Reference PD 1602 sec. 1(b) alongside RA 9287 sec. 3 for analogous tiering
PD 1602 sec. 2
Public-officer aggravated liability
Section 2 of PD 1602 imposes the maximum penalty plus permanent disqualification on any public officer found to participate in or protect illegal gambling. The provision predates RA 9287's analogous officer-liability rule by 26 years and remains the general anti-protection clause for any form of illegal gambling, including unlicensed online play.
Requirements
Treat public-officer involvement in illegal gambling as carrying maximum penalty plus permanent disqualification
Refer suspected protection arrangements involving public officials to the Ombudsman
Apply PD 1602 sec. 2 to officer protection of any unlicensed gambling form, not only numbers games
Document attempted solicitation by public officers and self-report
PD 1602 sec. 3
Premises owner and lessor liability
Section 3 of PD 1602 imposes criminal liability on the owner, lessor or occupant of any premises knowingly used for illegal gambling, regardless of whether the owner directly participates in the wagering. The reach to landlords is what makes commercial-property due diligence material for any tenant operating in or adjacent to the gambling sector.
Requirements
Conduct enhanced due diligence on tenants whose intended use is gambling-adjacent
Include eviction and termination rights for illegal-gambling use in every commercial lease
Investigate and cure on notice of suspected illegal-gambling use at owned premises
Maintain documentary support that the owner had no knowledge once made aware
Section 4(b)(2) of the Cybercrime Prevention Act of 2012 criminalises the unauthorised input, alteration or deletion of computer data resulting in inauthentic data with intent to cause damage or procure economic benefit. Unlicensed online gambling operations targeting Philippine residents are routinely charged under this provision as well as under RA 9287 / PD 1602, because their rigged or unlicensed back-end software falls within the fraud definition.
Requirements
Recognise computer-related fraud as a parallel charge to illegal-gambling statutes for unlicensed online operators
Cooperate with PNP-ACG and NBI-CCD evidence-preservation requests on platform back-ends
Maintain RNG and platform audit trails sufficient to rebut a fraud finding in legitimate operations
Preserve server logs in line with RA 10175 sec. 13 traffic-data retention obligations
RA 10175 sec. 6
Cybercrime penalty uplift — one degree higher
Player Rights
Section 6 of RA 10175 provides that all crimes defined and penalised under the Revised Penal Code and special laws, if committed by, through and with the use of information and communications technology, shall be punished one degree higher than provided in the underlying statute. Applied to illegal gambling (PD 1602, RA 9287, and RA 12312), the uplift raises minimum penalties and removes bail in many cases.
Requirements
Recognise that any illegal-gambling charge committed online attracts the one-degree uplift
Apply the uplift to defence-exposure modelling — bailability often changes at the higher band
Coordinate with prosecution on charge stacking (underlying statute + RA 10175 sec. 6) to anticipate sentencing exposure
Brief directors and key personnel on personal exposure under the uplifted band
Section 6 was upheld by the Supreme Court in Disini v. Secretary of Justice (G.R. No. 203335, 2014) as constitutional in respect of the penalty uplift.
RA 10175 sec. 19
Content restriction and ISP-level blocking architecture
Player Rights
Section 19 of RA 10175 — as narrowed by Disini v. Secretary of Justice (2014) — preserves a judicial route to restrict access to computer data found prima facie in violation of the Act. In practice, PAGCOR, the DICT and the NTC operate a tiered blocking architecture for illegal gambling sites: PAGCOR identifies targets, DICT issues blocking advisories, and NTC directs licensed ISPs to implement DNS- and IP-level blocking within 48 hours.
Requirements
Cooperate as a licensed ISP with NTC blocking directives within the 48-hour window
Maintain a publicly traceable abuse contact for PAGCOR and DICT enforcement notices
Recognise that judicial review under Disini sets the constitutional ceiling on take-down speed
Preserve logs of blocking-directive compliance for NTC audit
This is the Philippine equivalent of Brazil's ANATEL gambling-site blocking regime and Spain's DGOJ takedown architecture.
DICT-NTC Memo Circular 2024-05
DICT-NTC joint protocol — illegal-gambling site blocking
Player Rights
The DICT and NTC joint memorandum circular operationalises Section 19 for the gambling vertical: PAGCOR submits a referral packet (URL, IP, supporting investigation file) to DICT; DICT issues a blocking advisory within five working days; NTC orders all licensed ISPs and mobile operators to implement DNS, IP and where possible SNI-level blocking within 48 hours of receipt; ISPs file a compliance report within seven days. Repeat-offender domains are added to a permanent blocklist.
Requirements
Submit blocking referrals through PAGCOR for any unlicensed competitor or counterfeit-brand domain
Implement and report DNS, IP and SNI-level blocking within the 48-hour and seven-day windows as an ISP
Maintain the permanent blocklist register synchronised with NTC updates
Coordinate with PAGCOR and the DOJ on cross-border domain-takedown requests
Investigative units 2
NBI-CCD Charter
NBI Cybercrime Division — investigative mandate
Player Rights
The National Bureau of Investigation Cybercrime Division (NBI-CCD) handles high-complexity cybercrime investigations including illegal online gambling, offshore-gaming successor operations, large-scale fraud and trafficking-in-persons overlay cases. NBI-CCD operates the Philippines' digital forensics laboratory accredited under ISO/IEC 17025, supports international mutual legal assistance requests, and is the principal Philippine point of contact for INTERPOL's cybercrime directorate.
Requirements
Cooperate with NBI-CCD on cross-border investigations including INTERPOL-channelled requests
Preserve evidence to ISO/IEC 17025-compatible standards to support NBI-CCD forensic chain of custody
Respond to NBI-CCD mutual legal assistance information requests on regulator-channel basis
Recognise NBI-CCD's lead on residual POGO/IGL successor-operation casework
PNP-ACG Charter
PNP Anti-Cybercrime Group — investigative mandate
Player Rights
The Philippine National Police Anti-Cybercrime Group (PNP-ACG) is the primary law-enforcement unit for cybercrime, including illegal online gambling, computer-related fraud and online trafficking-in-persons. PNP-ACG operates regional cybercrime field units, executes search warrants for computer data under the Cybercrime Warrants Rules (A.M. No. 17-11-03-SC), and coordinates with NBI Cybercrime Division and PAGCOR Enforcement.
Requirements
Respond promptly to PNP-ACG cybercrime warrants for search, seizure and disclosure of computer data
Designate a 24/7 compliance contact for cybercrime warrant service
Cooperate with regional PNP-ACG field units in addition to national headquarters
Supreme Court jurisprudence 4
G.R. No. 203335 (Disini vs DOJ, 2014)
Disini v. Secretary of Justice (2014) — Cybercrime Act constitutionality
Player Rights
In G.R. No. 203335 (11 February 2014) the Supreme Court upheld most provisions of RA 10175 against constitutional challenge, including the Section 6 penalty uplift (one degree higher for ICT-mediated offences) and the data-preservation regime. The Court struck down the unilateral DOJ take-down power in Section 19 as a prior restraint, requiring judicial authorisation for content blocking — a ruling that shapes the DICT-NTC blocking architecture applied to illegal gambling sites today.
Requirements
Apply the constitutionally narrowed Section 19 framework — judicial authorisation route only for content take-down
Recognise the Section 6 penalty uplift as constitutionally settled and operative
Use Disini as authority when challenging over-broad executive take-down attempts
Track post-Disini operationalisation via DICT-NTC joint protocols on illegal-gambling blocking
G.R. No. 212530 (Bloomberry vs BIR, 2016)
Bloomberry Resorts v. BIR (2016) — 5% franchise tax extends to PAGCOR licensees
Player Rights
In G.R. No. 212530 (10 August 2016) the Supreme Court held that integrated-resort casino licensees of PAGCOR — Bloomberry's Solaire was the petitioner — enjoy the same 5 percent franchise tax 'in lieu of all other taxes' treatment on gaming income as PAGCOR itself. Imposing regular corporate income tax on a licensee's gaming revenue would impair the contractual franchise rights granted under the PAGCOR Charter and RA 9487.
Requirements
Apply the 5% franchise tax 'in lieu' treatment to PAGCOR-licensed integrated-resort gaming revenue
Distinguish licensee gaming revenue from licensee non-gaming revenue for tax purposes
Reference Bloomberry as primary authority in any BIR challenge to the licensee franchise-tax position
Recognise the impairment-of-contract reasoning as constraining BIR forward-looking rule changes
G.R. No. 215427 (PAGCOR vs BIR, 2014)
PAGCOR v. BIR (2014) — 5% franchise tax 'in lieu of all other taxes'
Player Rights
In G.R. No. 215427 (10 December 2014) the Supreme Court held that PAGCOR's income from its gaming operations is subject only to the 5 percent franchise tax under Section 13(2) of PD 1869, which is 'in lieu of all other taxes' on gaming income — notwithstanding the partial repeal of PAGCOR's income-tax exemption by RA 9337. Income from non-gaming related operations (leases, rentals, ancillary services) remains subject to corporate income tax.
Requirements
Apply the 5% franchise tax 'in lieu of all other taxes' to PAGCOR gaming income only
Segregate gaming and non-gaming revenue streams to evidence the bifurcated tax treatment
Recognise that the in-lieu clause did not survive RA 11590 for POGO operators, nor RA 12312 (which repealed RA 11590)
Use the 2014 ruling as foundational authority for tax-planning on PAGCOR-licensed land-based operations
The ruling is the foundational authority for gaming-tax treatment in the Philippines and is regularly cited by PAGCOR licensees in BIR audit defence.
G.R. No. 252965 (Saint Wealth vs BIR, 2022)
Saint Wealth v. BIR (2022) — POGO income tax and VAT pre-RA 11590
Player Rights
In G.R. Nos. 252965 and 254102 (consolidated, 19 December 2022) the Supreme Court ruled on the tax status of POGO licensees and service providers prior to RA 11590, holding that POGOs were not exempt from regular income tax and VAT under the PAGCOR Charter because their operations and customers lay outside Philippine territory and so were not the gaming income contemplated by the franchise. The ruling crystallised significant pre-2021 BIR exposure for the legacy POGO industry.
Requirements
Recognise the Saint Wealth ruling as the basis for pre-RA 11590 POGO tax assessments still in collection
Distinguish pre-RA 11590, RA 11590-era and post-RA 12312 (repeal) periods in residual tax-defence work
Use the ruling's territorial-nexus reasoning to anticipate parallel argumentation in successor enforcement
Track BIR collection activity premised on the Saint Wealth liability bucket through 2026
Excluded from this dataset: any constitutional challenge to EO 74 or RA 12312 — as of 2026-05-30 no Supreme Court merits decision has issued. To be added when a ruling is published.
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