This framework is for B2B Providers (Gaming Affiliates and Support Service Providers) who supply systems/games to a Gaming System Administrator (GSA), the actual operator. As a developer building games, you would most likely be a Game Content Provider (GCP) or Game Aggregator (GA) — not the operator itself. To run a full online casino, you'd also need to either become an accredited GSA (separate framework) or partner with one.
You cannot legally just "build and launch" — every system, every game, every parameter change requires prior PAGCOR approval.
- Operating an online casino only if you are PAGCOR-accredited and SEC-registered as a Philippine corporation
- Offering these PAGCOR-approved game categories: Traditional Bingo, Electronic Bingo, Electronic Casino Games, Sports Betting, Specialty Games, Online Poker, Numeric Games
- Accepting players who are 21 years or older and are Philippine residents
- Live-streamed games — but only from a PAGCOR-permitted live studio (Permit to Hold / PTH required)
- Using third-party game content from foreign developers — but the foreign entity must either get accredited directly or appoint a local exclusive distributor
- E-wallets, online banking, over-the-counter payments via BSP-registered providers
- AI-powered eKYC (biometric ID, liveness detection)
- Accepting bets from outside the Philippines — the EGS must geo-block foreign players
- Credit card funding of player accounts
- Cryptocurrency for deposits or withdrawals
- Allowing anyone under 21 to register
- Allowing these banned categories to play: government officials/employees, AFP members, PNP members, Gaming Employment License holders, and persons in PAGCOR's National Database of Restricted Persons (NDRP)
- Launching any game, system, or parameter change without prior EGLD approval (via EG Form No. 9)
- Using any B2B provider that isn't PAGCOR-accredited
- Marketing partnerships with influencers connected to illegal gambling sites
- Modifying RTP, RNG, or GGR-affecting parameters without re-approval
- Selling/transferring your accreditation or shares within 6 months of approval (without written EGLD consent)
- Co-locating with or partnering with entities engaged in "illegal or dubious activity"
- Multiple accounts per player per platform (one account per player per EGS/OGP)
Payments flow through accredited Payment Channels (PCs), which are themselves a separately accredited B2B category:
- PCs must be BSP-registered (Bangko Sentral ng Pilipinas) and AMLC-compliant (Anti-Money Laundering Council)
- Allowed types: money transfer services, e-wallets, payment gateway providers, Operators of Payment System (OPS), Electronic Money Issuers (EMI)
- PC must redirect prospective players to the GSA's player registration portal before any deposit
- PC must provide APIs for integration with your gaming platform and mobile apps
- PC must implement encryption and fraud detection
- PAGCOR explicitly disclaims liability for any payment processing costs
- A full KYC verification must be completed before a player's first withdrawal or within 3 days of signup, whichever comes first
PAGCOR's involvement is pervasive — basically every layer of the operation:
Entry barriers
- SEC registration required; foreign entities need a local representative corporation
- Probity checks on every director, key officer, and beneficial owner (criminal, financial, integrity background checks by a third-party probity checker — you pay for it)
- Application fees: PHP 250,000 (most categories, 2 years) up to PHP 500,000 (Independent Game Testing Lab)
- Performance Cash Deposit of PHP 1 Million per accreditation type, posted before operations begin (forfeitable for violations)
- PHP 1 Million per year Permit to Hold fee per live studio site
System & game-level control
- Every game requires individual approval via EG Form No. 9 before launch
- RTP percentages are mandated by law:
- Slots: 90% to <97%
- eBingo: 88% to <97%
- Traditional Bingo: 60% to 97%
- Arcade/skill: <99%
- RNG specialty/numeric: 60% to 97%
- RNG must be certified by an accredited Independent Game Testing Lab (ISO/IEC 17025 or 17065)
- Must integrate via API with PAGCOR's third-party auditing system for revenue monitoring
- All player data, transactions, and reports must be available to PAGCOR on demand
Ongoing oversight
- Yearly submission of GIS, Mayor's Permit, Personal Disclosure Statements (every May 31)
- Any ownership/board change must be reported within 30 days
- Original Certificate of Accreditation must be physically posted at the business premises
- Ocular site inspections by a PAGCOR Inspection Team before approval
- Live walkthrough testing of your EGS before Notice to Commence is issued
- Compliance with Data Privacy Act (RA 10173) and AMLC rules
Player-side mandates
- KYC must collect: full legal name, DOB, contact, place of birth, addresses, nationality, work, income source, photo, government ID, and selfie-with-ID
- Players must be assigned to one of the 5 nearest gaming venues to their address
- Complaint tickets must be acted on within 72 hours
- Mandatory 24/7 customer service
- Mandatory responsible gaming disclosures in all marketing
Penalty regime
- Suspension or revocation for: bankruptcy, conviction of officers, materially false applications, bringing PAGCOR's image into disrepute, public interest concerns
- Performance Cash Deposit can be forfeited
- Blacklisting for misrepresentation
- Decide your role: GCP (you build games), GA (you aggregate others' games), or GSA (you operate the casino). Each is a different framework.
- Form a Philippine corporation registered with SEC, BIR, and the local LGU.
- Budget at minimum: PHP 250K application + PHP 1M cash deposit + probity checker fees + IGTL certification fees + legal counsel + studio/office buildout if doing live games.
- Partner with an accredited GSA if you don't want to operate yourself — sell your games to them.
- Build your tech stack with these non-negotiables: geo-blocking for non-PH players, RTP within mandated ranges, RNG with IGTL certification, eKYC, AMLC transaction monitoring, PAGCOR auditing API integration, no crypto/credit card rails.
- Get a Philippine gaming lawyer before spending a peso on development — this summary is high-level; the actual frameworks (this one + the GSA framework + Offenses & Penalties framework + Probity Checking Framework + Marketing Framework) interact in complex ways.