Gaming Law 2025 Comparisons

PAGCOR Focuses on E-Gaming Growth

PAGCOR has modernised the country’s gaming landscape since 2023, prioritising the rapid expansion of the online gaming (e-Gaming) sector. This sector, which encompasses e-games, e-bingo, specialty games, numeric games and sports betting has significantly contributed to the growth of Gross Gaming Revenues (GGR), which reached PHP372 billion in 2024 and had already reached PHP309 billion by the third quarter of 2025, with Q4 data still to come, demonstrating strong continued growth.

To maintain this growth trajectory, PAGCOR has introduced updated licensing requirements and strengthened compliance standards for operators and service providers. Under the Regulatory Framework for the Accreditation of Gaming Affiliates (GAs) and Support Service Providers (SSPs), Revision No 1, effective 2 October 2025, all Business to Business (B2B) entities including Game Content Providers (GCPs), Game Aggregators, payment gateways, marketing or promotional services (MPS), independent game testing laboratories (IGTLs), and other third-party service providers are required to obtain local accreditation. A transition period is in place until 31 March 2026, after which only accredited B2B providers will be permitted to operate.

In line with the above, the regulatory framework provides that if the GA does not secure its own accreditation, it may appoint an already accredited GA or Gaming System Administrator (GSA) to be its exclusive distributor for its services in the Philippines. Each GA or GSA is allowed to be an exclusive distributor up to a maximum of five distributorships.

PAGCOR has also issued a memorandum announcing the implementation of a Minimum Guaranteed Fee (MGF) for all GSAs, effective 1 April 2026. This reform aims to address gaps in the current fee structure and uphold principles of fairness, accountability, and fiscal responsibility by ensuring all accredited GSAs contribute equitably to national revenue while promoting transparent operations.

Developments in e-Gaming and Land-Based Casinos Driven by New Technology and Changing Tastes

PAGCOR is driving a tech-led transformation of both e-Gaming and land-based gaming. These include:

• the introduction of regulations that allow land-based casinos to offer virtual gaming;
• numeric and specialty game categories;
• the accreditation of GSAs for e-Gaming platforms;
• the upgrading of slot machine technology and game content offerings; and
• the promotion of cashless payment payments via GCash, Maya, GrabPay, ShopeePay, DiskarTech, and PayMongo.

Collectively, these measures enhance player convenience, encourage responsible gaming, and align local operators with global digital standards.

Privatisation and Shift Towards a Purely Regulatory Role

PAGCOR is government-owned and controlled corporation established under Presidential Decree No 1869 (the “PAGCOR Charter”), which continues to balance its dual role as both operator and regulator. However, under the leadership of Chairman and CEO Alejandro H. Tengco, PAGCOR is pursuing full privatisation of its 40 government-operated casinos to focus exclusively on its regulatory mandate. Originally targeted in 2025, however, privatisation is now expected to take place closer to 2028, pending amendments to the PAGCOR Charter.

Enhanced Anti-Money Laundering (AML), Data Privacy and Responsible Gaming Oversight

To address global compliance standards and remove the Philippines from the Financial Action Task Force (FATF) “grey list”, PAGCOR has intensified collaboration with BSP. Casinos and e-Gaming operators are classified as covered institutions under the Anti-Money Laundering Act (AMLA) and must report all transactions exceeding PHP5 million. PAGCOR’s internal AML Supervision Department now enforces probity checks, risk-based supervision, and stricter junket monitoring protocols. Additionally, in response to the October 2025 National Privacy Commission (NPC) advisory on data breaches, PAGCOR reminded all its operators and licensees to ensure full compliance with the Data Privacy Act of 2012 (DPA) and to strengthen cybersecurity and data protection controls.

Expanding Casino Development and Adjusted Licence Fees

The Philippines’ integrated resorts (IRs) sector, while still a key contributor to tourism and employment, is currently facing significant headwinds that challenge the previously optimistic outlook. Recent industry data shows that although IRs generated roughly PHP93 billion in gaming revenue in the first half of 2025, the sector suffered a 10.6% quarter-on-quarter decline in Q2, reflecting weaker VIP activity, shifting regulatory conditions, adverse weather disruptions, and a softening rebound in international tourism. Analysts also note that the IR segment’s share of total gaming revenue has slipped as mass-market growth struggles to fully offset the downturn in high-roller play. Other proposed IRs in Boracay, Las Piñas and Cebu face similar market uncertainties, as rising competition across Asia and tightening policies on junkets and illicit online gambling dampen investor appetite. To increase revenues, IRs have ventured into the e-Gaming sector, with some IRs entering into agreements with e-Gaming operators and providers to run or enhance their online offerings. Any such agreement will need to be approved by PAGCOR, especially if it will result in the use of a different online gaming platform by the IR. In spite of such arrangement, it should be noted that all regulatory obligations and responsibilities will still fall on the IR as the licensed entity.

Stronger Enforcement Measures Aim to Dismantle Illegal Gambling Networks

PAGCOR, alongside the Philippine government, National Bureau of Investigation (NBI) and Philippine National Police (PNP), is intensifying efforts against illegal gambling, noting that over 60% of online gambling sites accessed locally are unlicensed and foreign-operated. PAGCOR supports regulated online gambling, emphasising licensed platforms’ contribution to state revenue, consumer protection, and deterrence of illegal operators. Co-ordination with the Department of Information and Communications Technology (DICT) and the Cybercrime Investigation and Coordinating Center (CICC) further strengthen enforcement and legal frameworks.

Gambling activities in the Philippines are illegal unless expressly authorised by law. Under the Revised Penal Code, gambling is defined as any game or scheme whose outcome depends wholly or chiefly on chance, involving wagers of money or items of value, or the use of mechanical or other contrivances to determine winners or losers. In 2017, Executive Order No 13 (EO13) expanded “illegal gambling” to include participation direct or indirect in any game not authorised by the government agency empowered to license it or conducted in violation of prescribed terms and conditions.

PAGCOR, as the principal gaming regulator, holds broad discretion to determine which gambling activities may be licensed under its charter and implementing regulations, including innovative or technology-driven game types. Through guidelines, approvals and rulings, PAGCOR clarifies the scope of licensable gambling, considering policy, technological developments and public welfare. Consequently, any unlicensed activity with gambling elements is prohibited, and participants may face criminal liability. All entities engaged in gambling or related businesses must be licensed or accredited by PAGCOR, or by special economic zone authorities such as Cagayan Zone Authority (CEZA) and Aurora Pacific Economic Zone (APECO), in which case gaming is limited to the zone’s jurisdiction. Therefore, if gaming or gambling activities are performed outside CEZA or APECO, they will need to be approved by PAGCOR.

Lotteries

Fantasy sports and poker clubs

Fantasy sports betting in the Philippines remains illegal unless explicitly licensed and regulated by the PAGCOR. Any fantasy sports platform involving wagering or betting without PAGCOR authorisation is considered illegal gambling under current laws. Recently, PAGCOR has intensified its oversight of poker operations with the release of new regulatory guidelines, including specific rules for Bad Beat Jackpot schemes. These updates apply to both land-based poker clubs and online poker platforms, as well as integrated resorts hosting poker tournaments.

These reforms aim to curb illegal poker operations, protect players from exploitative schemes, and ensure fair play across all gaming channels. Operators found violating these rules may face licence suspension or revocation, along with potential legal action.

Social gaming is generally allowed, as long as such games do not fall under the definition of “gambling”

Criminal laws require that all elements of a crime be present, so, theoretically, all the elements of illegal gambling will need to be proven before a person is convicted of such violation. Social games are permitted when played for home or parlour entertainment, not in habitual gambling venues, and without disguised betting. Contests or games without wagering are also allowed, though some may require registration with the DTI depending on their conduct and consumer impact.

Prediction Markets

At present, there is no specific legal or regulatory framework governing prediction markets in the Philippines. Under existing law, real-money prediction markets would likely be characterised as a form of gambling and would therefore fall within PAGCOR’s regulatory jurisdiction. There is also no mechanism under current securities or commodities laws to treat event-based contracts as regulated financial instruments. In practice, this means that prediction markets involving real monetary stakes face significant legal constraints, while play-money or purely academic forecasting platforms may fall outside gambling regulation.

Land-Based Casinos

A land-based casino licence, whether provisional or full, authorises operators to conduct only those gaming activities expressly covered by the licence. For table games, licensees may offer standard casino games such as:

• baccarat;
• blackjack;
• roulette;
• pontoon;
• casino war;
• craps;
• stud poker;
• big and small;
• money wheel;
• pai-gow;
• pula-puti; and
• poker.

Introduction of new games requires PAGCOR’s prior written approval, including approval of rules, table layouts and related operational elements. Licensees must comply with the applicable Casino Regulatory Manuals (CRMs), which vary depending on the casino’s location or classification (eg, Entertainment City, economic zones or greenfield sites).

Land-based casinos may operate electronic gaming machines (EGMs), including slot machines, provided these are sourced from PAGCOR-accredited suppliers and pass certification under the Supplier Regulatory Manual. PAGCOR’s Technical Standards for EGMs (PTS-EGM Version 1.1) continue to apply in 2025, ensuring technical integrity, security and fairness.

PAGCOR has also issued updated guidelines governing poker operations and tournaments. Beyond poker offered as a table game within casinos, licensed gaming sites may operate poker rooms, and PAGCOR regulates poker tournaments conducted onsite, offsite or within IRs.

PAGCOR Charter

As a rule, pursuant to the Revised Penal Code, all forms of gambling are illegal. The only forms of gambling allowed are those authorised by law. The PAGCOR Charter gives PAGCOR its franchise to maintain and operate gambling casinos, whether land-based or those that are conducted online or through electronic means. All persons primarily engaged in the business of gambling, together with their allied businesses, shall register with and secure approval from PAGCOR. The conduct of gambling activities outside the authority granted by PAGCOR is punishable under the Revised Penal Code and other criminal statutes.

PAGCOR Rules

The legal and regulatory framework governing gambling primarily consists of rules and regulations promulgated by PAGCOR (the “PAGCOR Rules”). It is noted that PAGCOR has the authority to change and amend these PAGCOR Rules in the exercise of its powers.

Licensed Land-Based Casinos

PAGCOR issued the CRM to unify and streamline the rules for all licensed land-based casinos. The CRM consolidates previous manuals into a single framework covering key operational areas, including:

• casino layout and design;
• internal controls;
• surveillance;
• responsible gaming;
• compliance procedures; and
• reporting requirements.

e-Gaming Licensing

Rules and regulations concerning e-Gaming licensing are primarily promulgated by PAGCOR’s Electronic Gaming Licensing Department (EGLD). These regulations are published on the PAGCOR website. This chapter of the guide refers to the rules governing e-Games collectively as the “e-Gaming Regulations”.

In practice, PAGCOR regularly issues updates, amendments and clarifications to the PAGCOR Rules, which are made available online, while minor revisions are often communicated directly to licensees, accredited suppliers and service providers by the relevant governing department. In addition, PAGCOR routinely releases memoranda and notices to its licensees and regulated entities, which may supplement or amend existing regulations. Given the frequency of these issuances and the practical impact they may have, it is recommended that local counsel be consulted for important or sensitive matters to ensure that the applicable regulatory requirements are current.

Special Economic Zones

Other than PAGCOR, authorities regulating certain special economic zones in the Philippines may also host and license gaming entities whose activities and gaming equipment (including computer servers) will generally be limited within such economic zone. These authorities are the CEZA, the APECO, and the Authority of the Freeport Area of Bataan (AFAB).

Philippine Charity Sweepstakes Office (PCSO)

Republic Act No 1169 established the PCSO and authorised it to hold and conduct lotteries and other similar activities as determined by its Board of Directors and with the approval of the President of the Philippines. PCSO also conducts Small Town Lottery (STL). As of November 2025, PCSO officially launched the web-based E-Lotto app, allowing bettors to buy tickets online, verify their accounts using valid IDs, and participate in all major lotto games. This initiative is part of PCSO’s push to modernise operations and promote convenience and security for lotto players.

Local Government Units

In the Philippines, local government units (LGUs) have elected executives and legislative bodies empowered to regulate activities within their jurisdiction. LGUs may impose specific requirements for business permits or no-objection letters for land-based casinos or e-Gaming venues. Some LGUs have enacted outright bans on gambling. Potential operators are advised to review local ordinances and consult counsel to determine whether their intended location permits gaming operations.

AMLA and Its Implementing Rules and Regulations

Casinos, including e-Gaming and ship-based casinos, with respect to their casino cash transactions related to their gaming operations, are designated as covered persons under the AMLA and its implementing rules and regulations.

Tax Code and Tax Laws

The taxation of casinos and PAGCOR licensees in the Philippines is governed by the National Internal Revenue Code (NIRC or “Tax Code”) and specific legislation like Republic Act No 11590.

Anti-POGO Act of 2025

The Anti-POGO Act of 2025 permanently bans all Philippine Offshore Gaming Operators (POGOs) and related activities, declaring unlawful any offshore gaming or sports betting targeting foreign players from within the Philippines. The law mandates revocation of existing licences, permits and accreditations for POGOs and associated service and content providers by 31 December 2024, and cancels work permits and visas for foreign personnel involved in such operations. Offshore gaming is designated as a predicate offence under the AMLA, while the BIR is tasked with auditing POGO entities to ensure settlement of outstanding taxes.

Anti-Online Gambling Bill

Senate Bill No 1281 proposes a complete ban on online gambling in the Philippines, including placing, receiving or transmitting wagers via the internet. The bill targets social harms such as addiction, crime and moral decline. Individuals placing online bets may face up to six months’ imprisonment or fines amounting to PHP500,000, while corporate officers of online gambling entities may be liable for up to five years’ imprisonment and similar fines. The bill also seeks to revoke government agencies’ authority, including PAGCOR, to license or regulate online gambling. It is currently under Senate deliberation.

Reduced Licence Fees for Online and Land-Based Operators

Effective 1 January 2025, PAGCOR reduced licence fees to enhance competitiveness and encourage regulatory compliance. Land-based casinos now pay 30% instead of 35%, while IRs with e-Gaming are subject to a 25% fee. PAGCOR also revised e-Bingo revenue-sharing arrangements following supplier renegotiations to improve operator profitability and transparency.

AML Enforcement, Probity and Supervision

The e-Gaming Regulations enhance AML, probity, and operational standards for all PAGCOR-regulated entities. Casinos and e-Gaming operators remain covered persons under the AMLA and must implement customer due diligence and enhanced due diligence, submit Covered Transaction Reports for a transaction in cash amounting to PHP500,000, or other equivalent monetary instruments exceeding casino cash transactions of ₱5 million or more, among others, and file Suspicious Transaction Reports, as required. Fit-and-proper assessments are mandated for licensees, key officers and significant shareholders, with non-compliance risking denial, suspension or revocation of licences.

While the AMLC enforces the AMLA, PAGCOR provides regulatory guidance, issuing orders and memoranda on compliance obligations, KYC procedures, and reporting requirements. PAGCOR is expected to strengthen its supervisory role and co-ordinate with the BSP to ensure adherence to AML standards.

Rules on Digital Assets

The legal framework for cryptocurrencies in the Philippines continues to evolve as both the BSP and SEC work to balance different objectives of stakeholders. The BSP categorises cryptocurrencies as a type of virtual asset but does not recognise them as legal tender in the Philippines. Thus, while they can be exchanged for fiat currency, they are not accepted as official currency for transactions within the country. There are discussions on allowing crypto as a form of currency for gaming; however, at present, there are no formal rules or guidelines on this matter.

Gambling is described under the Revised Penal Code as “any other game of scheme the result of which depends wholly or chiefly upon chance or hazard; or wherein wagers consisting of money, articles of value or representative of value are made; or in the exploitation or use of any other mechanical invention or contrivance to determine by chance the loser or winner of money or any object or representative of value”.

EO13 expands “illegal gambling” to include online games conducted without government authorisation or in violation of prescribed licensing terms, regardless of whether outcomes depend on skill, chance, or both.

The PAGCOR Charter does not expressly define “land-based gambling”. Under the current Regulatory Framework, it refers to gaming activities conducted in licensed physical venues such as casinos, bingo halls and gaming arcades where players participate on-site under PAGCOR supervision.

Following the Remote Gaming Framework, licensed land-based casinos and e-Gaming sites may extend operations online through approved remote gaming systems. These hybrid operations retain their land-based licence but must use B2B-accredited system providers, provide real-time back-office access to PAGCOR’s Compliance Monitoring and Enforcement Department (CMED-EG), and comply with enhanced AML, data privacy and responsible gaming standards under the 2025 Compliance Memoranda. In practice, land-based gambling now includes:

• traditional on-site gaming in physical PAGCOR-licensed venues; and
• authorised remote or digital extensions of such operations, linked to a valid land-based licence.

Online gaming is synonymous with “electronic gaming” or “e-Gaming” under PAGCOR Rules. PAGCOR defines “electronic games” as virtual games of chance (ie, casino games), and mixed games of chance and skills. Also, it defines e-Gaming as the conduct of electronic games and taking of wagers through any computer or communication device connected to the internet or the use of internet-based technology and other communication devices that are necessary for gaming operations.

Penalties for Those Engaged in “Illegal Gambling”

Both individual gamblers or players as well as the persons or entities hosting illegal gaming within the Philippines shall be liable under applicable laws. Sanctions may include:

• fines;
• suspension or revocation of business permits;
• closure of establishments;
• forfeiture of assets; and
• imprisonment.

Pursuant to the Revised Penal Code, violations are punishable by imprisonment of four to eight years per count. Enforcement is handled by law enforcement agencies, including the NBI and PNP, who are authorised to conduct raids, issue warrants of arrest, and file cases before criminal courts.

Penalties for Violations Committed by Licensed Gaming Entities

PAGCOR may impose sanctions on licensed operators, GSAs and accredited B2B providers for violations such as the following:

• exceeding authorised scope;
• failing to remit fees or submit reports;
• breaching AMLA, DPA or responsible gaming rules; or
• obstructing regulatory access.

Penalties include:

• fines;
• licence or accreditation suspension or revocation;
• forfeiture of Performance Cash Deposits (PCDs); and
• blacklisting.

Serious or repeated violations may incur fines up to PHP300,000 per offence. Criminal offences, including fraud, money laundering or cybercrime, may be referred to the Department of Justice (DOJ) or Anti-Money Laundering Council (AMLC) for prosecution.

Under the Revised Penal Code and Republic Act No 9287, any person who participates in any illegal numbers game (ie, gambling not regulated or allowed by PAGCOR or any other authorised agency) shall suffer the penalty of imprisonment if such person acts as a bettor.

The key regulatory authorities that apply to the Philippine gambling sector are the following.

• Executive Department exercises overarching control over gambling regulation, with the President empowered to issue relevant Executive Orders.
• PAGCOR regulates all gambling activities within the Philippines.
• PCSO oversees lotteries, STLs and numbers games.
• Special Economic Zone Authorities such as CEZA, APECO and AFAB may license gaming entities within their zones, limiting their operations to the zone.
• Games and Amusements Board regulates professional sports and amusement games, including betting on horseracing, to prevent illegal gambling.
• AMLC implements the AMLA and supervises casinos as covered persons.
• LGUs issue business permits and regulate gaming entities within their jurisdictions.
• DOJ and law enforcement agencies enforce laws against illegal gambling and related criminal activities.

The Philippines regulates gaming through a hybrid prescriptive and management-based system, prohibiting all gambling unless explicitly authorised. PAGCOR enforces licensing, technical, reporting, advertising and remittance requirements, with non-compliance subject to fines, suspension or revocation, as licences are privileges rather than rights.

Recent reforms, including the B2B Accreditation and Probity Checking Frameworks, hold operators, GSAs and IRs accountable for vendor compliance and require risk-based “fit and proper” assessments of applicants and key personnel. Prospective participants are advised to consult PAGCOR or local counsel before engaging in gaming-related activities.

New Licensing or Accreditation Requirements

Accreditation now formally includes GAs, such as GCPs (including Data/Content Streaming Providers (DCSPs)) and Game Aggregators, as well as SSPs like payment channels, Know-Your-Customer (KYC)/membership systems, MPS, customer service, and IGTLs.

Foreign providers servicing Philippine licensees are expected to establish a local presence or registration, including SEC registration, tax compliance with the Bureau of International Revenue (BIR), and local officers and offices, alongside PAGCOR accreditation. As discussed above, these requirements form part of PAGCOR’s broader shift towards a transparent and integrity-driven supply chain, under which operators including GSAs, IRs and other licensees may engage only duly accredited B2B providers.

As mentioned earlier, a foreign-based GA that does not secure its own accreditation may appoint an already accredited GA or GSA to be its exclusive distributor for its services in the Philippines. Each GA or GSA is allowed to be an exclusive distributor up to a maximum of five distributorships. Notably, under this arrangement, all obligations to PAGCOR will fall under the already accredited GA or GSA, as, technically, the foreign-based GA is not accredited or regulated by PAGCOR.

In general, PAGCOR offers the following licences:

• Licences for Land-Based Casinos;
• Licences for IRs;
• Licences for Operators of a PAGCOR-Licensed Gaming Venues;
• Licences for Remote Gaming or Online Casinos; and
• Accreditation for Gaming System Administrators (GSAs).

PAGCOR also offers accreditation to the following entities:

• Suppliers for Land-Based Casinos;
• GAs;
• GCPs , including DCSPs;
• Game Aggregators;
• SSPs;
• Payment Gateway Solutions or Payment Channels;
• KYC or Membership System Providers;
• MPS;
• Customer Service Providers; and
• IGTLs.

PAGCOR also provides ancillary and special accreditations: SCBPOs are for business process outsourcing facilities providing non-wagering gaming support services (eg, information technology, back-office, and customer relations).

PAGCOR has lifted the moratorium on new land-based casino IR licences, with applications now evaluated on a case-by-case basis, primarily considering financial capacity, technical capability, and regulatory compliance readiness.

In contrast, the issuance of new online or e-gaming operator licences and related accreditations remains subject to a moratorium. PAGCOR has indicated that this moratorium on new e-gaming accreditations may be revisited following the implementation of minimum guaranteed revenue (MGR) requirements, which are expected to result in the voluntary surrender or revocation of licences by operators unable to meet the enhanced financial thresholds.

With respect to B2B providers, accreditations for land-based gaming support services remain open, while B2B accreditations supporting online or e-gaming operations are currently affected by the moratorium. Prospective applicants are strongly advised to consult legal counsel to ensure proper licence classification and to remain updated on evolving regulatory requirements, as PAGCOR continues to administer a transparent and consultative licensing framework.

Land-based casino and IRs licences are typically granted provisionally at the start of operations and converted into long-term licences for up to 20 years upon full compliance with PAGCOR’s regulatory conditions. Gaming Venue Operator Licences are valid for one year initially, renewable for two years upon satisfactory evaluation.

Licences generally follow a two-year cycle, subject to renewal based on compliance. As an incentive, GAs and SSPs that have completed their applications and paid the corresponding fees before 31 December 2025 will be issued an initial three-year accreditation.

Initial Application Process

An application starts with a letter of intent addressed to PAGCOR’s Chairman and CEO. A complete list of requirements (depending on the licence or accreditation required) is accompanied by complete documentation in accordance with the latest guidelines issued by the relevant department. It is recommended that a potential applicant consult local counsel to secure the most recent application requirements as these are updated periodically.

Basic requirements that will accompany the initial submission are as follows.

• Charter documents showing the establishment of an entity in the Philippines with the required ownership and capitalisation.
• Company overview and profile, including an organisational chart and business plan.
• Sworn statements and affidavits relating to the ability of the applicant to engage in the business, non-affiliation, and certification as to the lack of disqualification.
• Requirements under the AMLA and DPA.
• Proof of identity and probity disclosures of shareholders and directors, and key officers.
• Independent system testing certifications for gaming machines, platforms and software from PAGCOR-accredited testing laboratories.
• Other requirements to be determined by PAGCOR.

PAGCOR may request additional documentation or clarifications. Following submission, the regulator conducts due diligence and probity checks including background investigations, site inspections, and interviews of key personnel to confirm integrity, technical capacity and compliance readiness before granting a provisional or full licence.

All applications for licensees will require the approval of the PAGCOR Board of Directors.

Requirements for Officers, Directors and Personnel

PAGCOR requires the officers and directors of the entity engaged in gaming to undergo probity or background checks to ensure they are qualified persons of integrity who have the capability to engage in the business of gaming. As part of the application, PAGCOR’s third-party probity checker may ask its officers and directors to disclose the following information:

• personal and identification details (addresses, identification numbers, etc);
• complete history of directorships, beneficial ownership and business affiliations;
• financial standing and solvency declarations;
• criminal, administrative or civil records (local and international);
• conflicts of interest and government relationships; and
• adverse media or reputational issues.

In addition, certain employees, especially gaming floor staff, compliance officers and technical personnel, must complete PAGCOR-accredited training and obtain a Gaming Employment Licence (GEL) before deployment.

Applications for Accreditation

In general, an applicant seeking to secure an accreditation (and not a licence as an operator), including B2B providers, will be subject to different requirements and slightly less rigid approval processes compared to Business to Consumer (B2C) operators.

Applicants are advised to consult PAGCOR at least six months prior to their intended operations to allow adequate time for documentation, probity checks and system testing, with larger IR projects potentially requiring longer timelines. Depending on system complexity, laboratory testing and integration, e-Gaming and B2B applications typically take two to three months. Establishing a local presence requires an additional four to six weeks for SEC registration, BIR compliance and local permits. Early engagement with local counsel is recommended to address set-up matters, including banking and local clearances.

Applicants are advised to consult PAGCOR or legal counsel to determine licence-related costs, which vary by activity. Total costs may include:

• entity set-up and local establishment expenses (SEC fees, permits, employee benefits);
• capitalisation requirements;
• cash bonds;
• PAGCOR application fees;
• registration fees for games or platforms;
• employee training; and
• customs duties for equipment.

It is recommended that the applicant consult PAGCOR or legal counsel to determine annual fees that will be paid by the licensee or accredited provider. In determining the relevant annual fees, the licensee should consider the following:

• yearly registration fees for games or platforms;
• any revenue-sharing or minimum fees based on GGR or winnings (these tend to change depending on the year of operation);
• annual licence fees; and
• national and local taxes.

As mentioned above, PAGCOR announced the implementation of an MGF for all GSAs, effective 1 April 2026. The MGF will be implemented in two tranches. During the first tranche from 1 April 2026 to 30 September 2026, GSAs operating eCasino games must pay PHP9 million monthly based on a minimum GGR of PHP30 million, while those without eCasino Games pay PHP3 million monthly based on PHP15 million minimum GGR. From 1 October 2026 onwards, these fees increase to PHP10.5 million and PHP4 million respectively, with corresponding minimum GGR thresholds of PHP35 million and PHP20 million. GSAs will be assessed whichever is higher between the prescribed MGF or their applicable percentage-based licence fee or PAGCOR share. The memorandum further sets out the regulations such as the issuance of a final warning and comprehensive evaluation that may result in accreditation cancellation, given the GSA’s failure to meet the prescribed minimum GGR for five cumulative months.

Types of Authorisations and Licences

The GEL remains the principal authorisation issued by PAGCOR, granting an individual the privilege to be employed as a gaming employee within the Philippine jurisdiction. It is a pre-employment and continuing requirement for employment in any gaming establishment in the country and should form part of the employee’s handbook. No operator or licensee shall hire and keep an individual employed without a valid GEL.

Application Process

Probity checking requirements

All directors, key officers, shareholders and senior managers of PAGCOR-licensed or accredited entities must undergo mandatory probity and background checks administered or verified by a PAGCOR-appointed third-party probity checker. This ensures only fit, proper and financially sound individuals participate in the industry.

Applicants are required to submit a PDS together with supporting documents covering:

• personal identification and residency details;
• employment and directorship history;
• financial records and tax compliance;
• litigation or criminal background; and
• conflict-of-interest or government affiliation disclosures.

Probity clearance is also triggered by any change in ownership, board composition or adverse information. The average processing period is 30 to 45 working days, depending on document completeness. Fees are minimal for GEL applications (below USD100) but may include additional costs for external probity verification.

GEL for employees

Prior to hiring and/or signing of an employment contract, the employer must ensure that personnel who are directly involved in gaming operations possess a valid GEL. It is recommended that local counsel is consulted to determine what functions require a GEL.

Ongoing Annual Fees

Minimal fees are charged by PAGCOR for the application for a GEL (less than USD100).

Ongoing Requirements

Licensees and GEL holders must maintain good moral character, physical fitness, and compliance with PAGCOR regulations, labour laws and AMLC requirements. Renewal requires a clean employment record, updated medical and drug-test results, and an unrevoked probity clearance. Operators must maintain an updated employee GEL register available for inspection by the EGLD or CMED.

Personal Sanctions

PAGCOR may suspend or revoke a GEL or corporate approval for violations of the GEL Manual, including:

• falsification of documents;
• breach of PAGCOR Rules;
• conviction or dismissal for just cause;
• failure of drug testing;
• medical unfitness; or
• adverse probity findings.

Non-cooperation or misrepresentation during background checks also constitutes a ground for cancellation.

Casino Venues

A land-based casino or gaming venue must be located in an area where gambling is not prohibited. PAGCOR Rules set specific location restrictions generally barring sites near schools, places of worship and similar sensitive areas, unless an exemption applies. The venue determines the regulatory framework and applicable CRM (eg, greenfield sites, ecozones, Entertainment City), which include requirements on layout, hotel-to-gaming floor ratios, and other site standards.

Applicants should also be aware of LGU requirements and limitations when looking at premises for operations. Most LGUs have their own set of rules that govern the conduct of gaming operations, with some LGUs implementing a total ban on any gaming activities within their jurisdiction.

Permits to Hold (Warehouses, Showrooms, Data/Content Streaming Sites)

In general, possession or storage of gaming equipment without PAGCOR approval is prohibited. Entities operating warehouses, showrooms or live data/content streaming sites must secure a Permit to Hold (PTH) for each facility. PTHs are valid for one year and renewable, while Supplier Showroom Permits allow controlled demonstrations for five years with annual renewal. GCPs and DCSPs must hold both accreditation and a PTH. When in doubt about whether items qualify as gaming equipment, consultation with local counsel is recommended.

Remote Gaming Venues: Enhanced AML and KYC Requirements

Land-based casinos are allowed to conduct remote gaming through remote gaming venues. PAGCOR issues guidelines and memoranda requiring stricter customer due diligence and KYC processes, particularly for junket operations conducted either by casinos or registered junket operators. These enhanced requirements continue to apply beyond 2025.

A B2C licensee, or “operator”, is an entity duly licensed by PAGCOR to offer games of chance to Philippine-based players. e-Gaming operations encompass all wagering conducted through computers, terminals, gaming devices or internet-based platforms, including:

• e-games;
• e-bingo;
• slot-type games;
• table simulations;
• specialty games;
• sports betting; and
• remote gaming by PAGCOR-licensed land-based casinos.

Operators must integrate with PAGCOR’s centralised monitoring system, provide real-time data access for audit and compliance, and fully comply with AML, data privacy and responsible gaming rules. They may engage only PAGCOR-accredited B2B providers under the B2B Accreditation Framework.

While new operator applications remain subject to PAGCOR’s moratorium, renewals and system modifications are reviewed under updated regulatory standards. Overall, B2C licensing is anchored on transparency, operational integrity and risk-based compliance.

The B2B Accreditation Regulatory Framework requires all entities providing products or services that support licensed gaming operations to obtain PAGCOR accreditation before transacting with any licensee. This system replaces the former supplier registration model and establishes a unified, compliance-driven structure that increases transparency and regulatory oversight across the gaming supply chain. Accreditation covers three primary categories.

• Accreditation of GAs (GCPs/DCSPs/Game Aggregators) – Entities involved in game integration, development, hosting or live data/content streaming for licensed operators.
• Accreditation of SSPs – Providers of technical and operational services such as payment channels, e-wallets, KYC/membership systems, customer support, IGTLs and MPS.
• SCBPOs – Firms servicing licensed offshore operators for non-betting functions such as marketing and customer relations, with at least 90% Filipino employees.

Foreign providers must establish a local presence or appoint an accredited representative, including SEC registration, tax compliance, and PAGCOR accreditation. The framework mandates probity checks, AML compliance, and real-time system access, making accreditation a compulsory compliance gateway for all supporting entities in the Philippine e-Gaming sector.

All GAs and SSPs performing MPS for PAGCOR-accredited GSAs must secure accreditation. Under PAGCOR, MPS refers to services that create and manage marketing and promotional activities aimed at boosting player engagement, retention, spending and loyalty. MPSs may develop and implement gaming promotions, assist with digital marketing and paid advertising, and integrate social media or influencer-based campaigns, provided these do not involve influencers connected to illegal gambling sites.

All marketing and promotional activities must target only the domestic market, exclude foreign players, and comply with PAGCOR’s ethical and responsible gaming standards. Non-accredited entities or those violating these rules may face blacklisting or administrative sanctions. Legal guidance is recommended given that certain marketing activities specifically require accreditation.

PAGCOR permits certain forms of “white-label” arrangements whereby licensed operators may engage duly accredited GSAs or DCSPs to develop, host, operate or maintain online gaming platforms, subject to prior PAGCOR approval of each platform. A single PAGCOR licensee may operate multiple brands under one licence; however, every platform must be independently registered and integrated with PAGCOR to enable real-time monitoring and regulatory oversight. All systems must be hosted and operated within the Philippines and may offer only PAGCOR-approved games and content.

White-label arrangements do not transfer or dilute regulatory responsibility. Full liability, compliance obligations, customer relationships and accountability to PAGCOR remain at all times with the licensed operator or PAGCOR licensee. In addition, entities providing white-label services are now required to secure PAGCOR accreditation, either as a GSA or as an authorised aggregator, and must undergo technical certification, probity checks and system audits prior to launch.

PAGCOR imposes strict technical measures for e-Gaming platforms to protect consumers, ensure system integrity and prevent access by unlicensed operators. Key requirements include the following.

• All e-Gaming service providers must implement robust cybersecurity controls certified by a PAGCOR-accredited IGTL. These certifications must confirm compliance with IP blocking, encryption, data protection, and system resilience standards.
• Every gaming system must be integrated with PAGCOR’s third-party audit and real-time monitoring platform for oversight of transactions, GGR reporting and player protection.
• Systems must automatically restrict player registration and betting from outside the Philippines. Geo-fencing, IP blocking and account verification protocols are mandatory to ensure compliance with local jurisdictional limits.
• Operators or providers found non-compliant with technical or cybersecurity standards face monetary fines, suspension or licence revocation.

These measures apply specifically to e-Gaming and online gaming systems, reinforcing PAGCOR’s commitment to data security, consumer protection and transparent digital operations.

Expanded Technical and Operational Standards

PAGCOR introduces comprehensive and enhanced standards governing both the technical and operational standards for both land-based and e-Gaming systems. Key features of the framework include the following.

• All Random Number Generators (RNGs), bingo systems and electronic game terminals are now subject to evaluation and certification by PAGCOR and duly accredited IGTLs, ensuring integrity and fairness across gaming platforms.
• The framework prescribes minimum bet values for electronic casino (“eCasino”), e-Bingo, sports betting and numeric games, all of which must adhere to PAGCOR’s established thresholds.
• Bingo equipment and paraphernalia must strictly comply with the technical specifications set out in framework.
• Licensees are required to implement robust responsible gaming measures, including but not limited to:
1. transparency of Return to Player (RTP) rates;
2. player self-exclusion mechanisms; and
3. mandatory player protection systems.

Player Exclusion Programme

This programme remains a key component of the agency’s Responsible Gaming initiative. Players who exhibit signs of problem gambling or whose families believe they are at risk may request voluntary or family-initiated exclusion through PAGCOR’s updated portal or via on-site submission at licensed venues.

Casino operators may also file exclusion requests against players involved in fraud, cheating, theft, money laundering or other integrity-related offences. All exclusions are recorded in the enhanced National Database of Restricted Persons (NDRP), operational since 15 January 2024, which now automatically synchronises with both land-based and e-Gaming systems to prevent registration or access by barred individuals.

In addition to those listed in the exclusion database, the following individuals remain prohibited from gambling in any PAGCOR-regulated facility or platform:

• persons under 21 years old;
• government officials and employees of national and local agencies;
• members of the armed forces of the Philippines and PNP;
• casino employees and related gaming personnel; and
• loan sharks and moneylenders operating within or near gaming venues.

PAGCOR Code of Practice for Responsible Gaming

PAGCOR’s Revised Code of Practice for Responsible Gaming (the “Code”) sets the minimum compliance standards for all licensed and accredited entities. The Code requires all operators of both land-based and e-Gaming to embed responsible gambling tools, awareness programmes and support mechanisms in their operations.

The Code discusses rules on the following aspects of responsible gaming:

• game fairness and awareness programme;
• marketing and communications compliance, prohibiting misleading or aggressive advertising;
• mandatory responsible gaming visibility across websites, applications and venues (signage, helplines, digital notices);
• employee training in responsible gambling identification and referral procedures;
• dedicated player support channels, including PAGCOR’s 24/7 Responsible Gaming hotline, email and live chat assistance;
• implementation of exclusion mechanisms across all licensees; and
• penalties and sanctions for non-compliance.

Each operator must maintain a Responsible Gaming Compliance Officer, file annual Responsible Gaming Implementation Reports, and align with the rules of PAGCOR.

Responsible Gaming Guidelines (Specific for E-Gaming Platforms)

Online or e-Gaming is required to provide the following means in the conduct of its games:

• upon player log-in, displaying brief infographics or videos on responsible gaming reminders, including the prohibition against playing in public spaces;
• providing persistent notices on prohibited players, such as minors and individuals listed in the NDRP;
• requiring acceptance of the platform’s terms of use (TOU) for every session, with the latest TOU submitted to PAGCOR before implementation;
• suspending or cancelling accounts, and potentially forfeiting funds, for TOU violations, with forfeited funds included in GGR; and
• enforcing time and spending limits, with periodic reminders to encourage breaks and review of spending history.

Forthcoming Changes

PAGCOR continues to strengthen responsible gaming measures across land-based and e-Gaming platforms, leveraging technology and management tools. Chairman Alejandro Tengco, in various public speeches, has indicated that PAGCOR is currently looking at different AI tools that will enhance RG and player protection programmes.

There is no response for this jurisdiction.

Under the AMLA, casinos including land-based, ship-based and internet-based operations are designated as covered institutions required to report transactions exceeding PHP5 million (or equivalent) to the AMLC. Offshore gaming operators and their service providers are similarly covered.

The Casino Implementing Rules and Regulations (CIRR) of Republic Act No 10927, effective 4 November 2017, establish compliance principles including good corporate governance, customer due diligence (CDD), risk management and employee training. Casinos must verify and record the true identity of customers, intermediaries and beneficial owners, prohibiting anonymous or fictitious accounts and requiring face-to-face verification for withdrawals or transfers.

PAGCOR supplements the CIRR with guidelines and directives through its PAGCOR Anti-Money Laundering Supervision and Enforcement Department (PASED) department, overseeing licensees’ AML compliance and ensuring adherence to regulatory standards.

Casinos, as “covered persons” under the AMLA, are required to comply with AMLA provisions, the CIRR and related guidelines issued by the AMLC, PAGCOR and other regulatory authorities. Licensees are advised to seek legal guidance for detailed compliance requirements. At a minimum, casinos must maintain CDD records and transaction data for at least five years, report covered and suspicious transactions to the AMLC within five working days (or up to 15 days if prescribed), and register with the AMLC’s electronic reporting system.

Casinos are prohibited from:

• conducting cash conversion transactions unrelated to gaming, including wire transfers or cheque cashing;
• accepting cash whose source or ownership cannot be verified within seven days; and
• allowing casino chips to be used outside the issuing casino, including for betting or exchange into cash.

Probity Checking Framework

PAGCOR has fully implemented a Probity Checking Framework introducing mandatory, risk-based due diligence for all GSAs, GAs and SSPs. Probity checks now apply to all new and renewal applications, ownership or board changes, and any event that raises integrity or financial concerns. The process, administered by the PASED and the Investigation and Verification Department (IVD), requires independent third-party verification of criminal, financial and reputational background. Costs are shouldered by the applicant. Failure to maintain probity standards or report changes within 30 days may lead to suspension or revocation of accreditation.

AML and Compliance Obligations

Accredited GAs and SSPs must comply with the AMLA under PASED supervision. Non-compliance is subject to fines and penalties.

PAGCOR regulates all gaming marketing and advertising, with oversight from the Gaming Licensing and Development Department (GLDD), EGLD and CMED-EG. The Code sets ethical standards, and all promotional materials require prior PAGCOR approval. Through a Memorandum of Understanding with the Ad Standards Council (ASC), gambling advertisements across media are subject to ASC pre-screening, with PAGCOR retaining final authority to modify, suspend or remove non-compliant materials. The Consumer Act may also apply to protect gaming customers. Such activities require prior PACGOR approval and generally include:

• membership or loyalty programmes;
• sponsorships;
• any contest, lucky or raffle draw or tournament; and
• announcements and/or advertisements.

The Consumer Act defines advertising as any mass-media material promoting a product or service, while PAGCOR adopts an even broader definition encompassing all communications intended to drive registration, gameplay or brand awareness across print, broadcast, digital and outdoor platforms. All marketing initiatives, including loyalty programmes, sponsorships, contests, raffles and other public-facing promotions, require prior PAGCOR approval. Advertising materials for TV, radio, print or digital release must be submitted through a Request for Advertising Approval Form at least 15 business days before implementation. All activities must be co-ordinated with CMED-EG and comply with PAGCOR’s Responsible Gaming standards.

All marketing and advertising activities related to gaming are subject to strict regulation to uphold responsible, ethical, and socially responsible practices. Only non-gaming advertisements that promote Responsible Gaming are permitted for billboard or out-of-home (OOH) placements, and these must include the following:

• prohibition of under 21 years old logo;
• responsible gaming slogan must be displayed – “Gambling can be addictive. Know when to stop.”;
• PACGOR logo; and
• Responsible Gaming email: ResponsibleGaming@pagcor.ph.

Land-based operators may use print, broadcast, digital, SMS and in-venue materials, provided advertisements depict gambling solely as entertainment and avoid misleading claims regarding odds or winnings. Billboards and OOH advertising are limited to Responsible Gaming campaigns and must observe a 200-metre buffer from schools, churches and other sensitive locations.

e-Gaming operators and service providers may conduct promotional activities such as loyalty programmes, sponsorships, contests, raffles, tournaments, and announcements subject to PAGCOR standards and prior approval. All activities must be co-ordinated with CMED-EG for monitoring, and any misleading or non-compliant material is subject to sanction.

PAGCOR Directive on OOH Advertising

PAGCOR issued a formal directive mandating the removal of all gambling-related billboard and OOH advertisements, with a compliance deadline of 15 August 2025. Only Responsible Gaming materials are now authorised for outdoor display. This directive introduces stricter pre-approval requirements, alongside enhanced co-ordination with the ASC for content screening and clearance.

Responsible Gaming Guidelines

PAGCOR has also announced the forthcoming release of comprehensive Responsible Gaming Guidelines by 2026, which will formalise standards on advertising tone, target audience limitations, and the ethical use of digital influencers and brand ambassadors.

All gambling-related advertising is subject to strict content and placement rules to ensure responsible messaging and prevent exposure to minors and vulnerable groups. Ads may not do any of the following:

• feature or appeal to persons under 21;
• depict gambling as glamorous or financially beneficial; or
• include exploitative, sexual, violent or gambling-themed imagery.

OOH and billboard advertising is limited solely to Responsible Gaming campaigns, which must display the PAGCOR logo, the “21 Years Old and Above” notice, and the RG tagline: “Gambling can be addictive. Know when to stop.” These materials must also maintain a 200-metre buffer from schools, churches and similar locations.

Across all media, advertising must present gambling strictly as leisure and comply with PAGCOR and ASC pre-screening requirements.

Any violation of PAGCOR’s advertising and marketing regulations is subject to administrative penalties. Sanctions include monetary fines, suspension of promotional privileges, and, for serious or repeated breaches, revocation of accreditation or licence.

PAGCOR may also order the immediate withdrawal of offending materials. Operators and accredited MPSs are jointly liable for any violations arising from their campaigns.

Changes in control among PAGCOR licensees and accredited entities generally require prior regulatory approval, and parties should be cautious of claims suggesting otherwise. GAs, SSPs and other accredited entities must report any change in ownership, control or key management to the EGLD within 30 days.

Newly accredited entities are prohibited from transferring ownership interests within six months unless PAGCOR grants written approval for serious and justifiable reasons. Substantial ownership changes trigger additional probity checks by an independent assessor designated by the EGLD.

Required submissions include an updated General Information Sheet (GIS), Personal Disclosure Sheet (PDS) for new directors or shareholders, and a notarised beneficial ownership declaration. Publicly listed companies must also comply with the SEC and PSE’s 5% and 10% disclosure thresholds for changes in beneficial ownership.

Any change in ownership or control of a PAGCOR-licensed or accredited entity requires prior approval from the PAGCOR Board and must be reported within 15 days. This includes acquisitions resulting in more than 50% ownership or voting control, changes in directors, and modifications in ultimate beneficial ownership or management.

New licensees are barred from transferring shares within the first two years unless PAGCOR authorises the transfer. Incoming directors or shareholders must submit updated GIS and PDS filings.

Non-compliance may result in administrative sanctions, suspension or forfeiture of the PDC, and Certificates of Accreditation or PTHs are non-transferable absent prior Board approval and full compliance with current requirements.

PAGCOR rules do not distinguish between passive and active shareholders; any ownership change that meets statutory or regulatory thresholds may require prior PAGCOR approval, and all changes must be properly disclosed. Regardless of their level of involvement, shareholders must pass probity screening and be free from adverse regulatory or criminal links.

As a matter of best practice, licensees and accredited entities should notify PAGCOR of all ownership changes to ensure full compliance and prevent regulatory complications.

Enforcement differs between players involved in illegal gambling and operators conducting unauthorised or non-compliant activities. Players in illicit gambling are penalised as “bettors” under the Revised Penal Code and related penal statutes, alongside personnel, agents, financiers, property owners, and individuals possessing unapproved gambling paraphernalia; violations require criminal prosecution and may result in imprisonment and fines.

In contrast, licensed operators are subject to PAGCOR’s regulatory regime, which empowers the agency to:

• impose administrative fines;
• issue notices to explain or cease-and-desist orders; and
• suspend or revoke licences or PCDs.

The PAGCOR Board retains ultimate authority over all sanctions and licence forfeitures.

See 11.1 Powers.

PAGCOR mandates that all accredited entities maintain a PCD of PHP1 million per entity or game offering, which may be forfeited to cover unpaid fines or penalties.

Administrative fines are calibrated based on the frequency and gravity of violations and may include daily penalties for non-compliance or failure to file annual documents (eg, GIS, PDS). PAGCOR also imposes reissuance fees of PHP20,000 per certificate and extension fees of PHP1,000 per day for delayed renewals.

PAGCOR operates under a statutory franchise that grants both regulatory authority and economic privileges, including a preferential tax treatment for certain activities. A central issue for PAGCOR is determining the extent to which the 5% franchise tax applies and identifying which income streams and services properly fall within its scope. This becomes particularly complex when operations involve both gaming and non-gaming components, or when conducted within special economic zones governed by their own tax incentive regimes.

Income From Operations Under PAGCOR’s Franchise or Gaming Operations

PAGCOR is subject to a preferential tax regime that imposes a 5% franchise tax on its gross revenue or earnings derived from gaming operations conducted under its legislative franchise. This franchise tax is expressly stated to be in lieu of all other national and local taxes, of any kind or form, income or otherwise, including fees, charges or levies. Accordingly, it substitutes for the regular corporate income tax (RCIT), which is currently 25% under the CREATE Act, as well as the 12% value added tax (VAT) and other applicable taxes.

Importantly, this tax privilege is not exclusive to PAGCOR, but also extends to its licensees and contractees, as consistently affirmed by regulatory issuances. Accordingly, operators duly accredited by PAGCOR are subject only to the 5% franchise tax on income derived from activities expressly authorised under their accreditation, pursuant to PAGCOR’s legislative franchise.

Such income is therefore exempt from RCIT, VAT, local business taxes, and all other forms of national or local taxation, provided that the operations are within the authorised scope of gaming activities covered by its accreditation.

This preferential tax treatment applies uniformly to both PAGCOR’s own earnings and the income of its accredited or contracted operators, so long as the revenue is derived from activities that fall squarely within the ambit of its franchise or its accreditation.

Income From Other Related Services or Non-Gaming Operations

By contrast, income earned by PAGCOR or its licensees from other related services or “non-gaming operations” is not subject to the 5% franchise tax. Instead, it falls under the regular tax regime of the NIRC, as such income is explicitly excluded from the scope of earnings covered by the franchise tax. These revenues are treated as distinct income streams and are therefore subject to the RCIT, as well as other applicable taxes, including VAT.

This category of non-gaming income includes, but is not limited to, revenues from services that are incidental or ancillary to gaming operations, such as food and beverage sales, hotel accommodations, entertainment shows, leasing of commercial spaces, parking services, and other related offerings.

While these services may operate alongside or complement a gaming business, they do not qualify as part of PAGCOR’s franchised gaming activities and are accordingly taxed under the standard framework. As such, they are subject to 25% RCIT and 12% VAT, along with any applicable local taxes or regulatory charges.

This distinction underscores the importance for PAGCOR-accredited operators to maintain proper revenue classification, ensuring that the appropriate tax treatment is consistently applied based on the actual nature of each income stream.

Tax Treatment of PAGCOR’s Licensees Located in Ecozones or Freeports

Special rules apply to PAGCOR licensees operating within economic zones or freeports under the jurisdiction of an Investment Promotion Agency (IPA), such as PEZA, CEZA and AFAB. For these licensees, the tax treatment is tiered depending on the nature of income and the scope of registered activity with the IPA.

Income derived from gaming operations remains subject to the 5% franchise tax and is not entitled to any tax incentives under the IPA regime. This is consistent with the principle that the PAGCOR franchise governs the taxation of gaming operations, irrespective of geographic location, and such income is expressly excluded from enjoying tax holidays or special corporate income tax (SCIT) incentives available under the IPA’s charter or the CREATE Act.

Income derived from non-gaming operations that are duly registered with the IPA may qualify for preferential treatment. If the licensee is subject to the 5% SCIT regime, then such income shall be exempt from RCIT and VAT. If the licensee is under an income tax holiday (ITH), the income from the registered non-gaming activity shall be exempt from income tax during the holiday period but remains subject to VAT.

Lastly, income from non-gaming operations that are not covered by the licensee’s registered activity with the IPA is fully subject to regular tax rules. This means such unregistered income shall be subject to RCIT, VAT and other applicable national and local taxes.

The tax treatment of PAGCOR licensees within ecozones thus hinges on:

• the nature of the activity;
• gaming versus non-gaming; and
• the specific coverage of the licensee’s registration with the IPA.

Legal and tax counsel must therefore ensure that clients operating in such zones maintain clear records, comply with registration requirements, and apply proper tax segregation across income categories.

Taxes and Duties for B2B Suppliers and Contractees of PAGCOR Licensees and Casinos

As a general rule, business-to-business (B2B) suppliers, service providers, and other contractees of PAGCOR licensees or casinos are not entitled to avail of the 5% tax on gross gaming revenue imposed in lieu of all other taxes, which applies only to PAGCOR licensees and certain business-to-consumer (B2C) gaming operators expressly covered by law or regulation. Instead, B2B providers are ordinarily subject to the regular national and local tax regime, including income tax, withholding taxes, and other applicable duties, based on their taxpayer classification (eg, resident, non-resident or foreign corporation). Providers of digital goods should also check compliance with the Digital Transactions Tax.

Given the fact-specific nature of tax treatment, B2B providers are advised to consult with qualified legal or tax counsel to determine whether they may qualify for any statutory or treaty-based exemption, preferential rate or derivative tax benefit arising from the tax status of their contracting PAGCOR licensee or casino operator.

Recent Changes

While not strictly a tax, PAGCOR, in a memorandum issued last November 2025, announced that all GSAs generating a total GGR of PHP100 million in a month shall be required to incorporate and register a foundation. The foundation will serve as the corporate social responsibility arm of the GSA, with the primary objective of contributing to programmes and initiatives related to education, environment, cultural heritage, health/wellness and sports development.