Philippines urged to legislate online gaming protections amid lingering threat of sudden industry ban
Philippine gaming law specialist Arden Consult has urged the government to introduce dedicated legislation governing online gaming, warning that the industry’s current regulatory foundations leave it vulnerable to a sudden ban of the kind imposed in India and Brazil.
The call comes in a paper published by Arden Founder and CEO Tonet Quiogue through global legal platform Legal 500, which identifies the lack of a dedicated statute as the most significant remaining gap in the country’s online gaming regulatory framework. While acknowledging that reforms introduced over the past year have been substantial, Quiogue warns that “they can still be reversed.”
At present, the regulatory framework relies primarily on PAGCOR’s charter, Presidential Decree No. 1869, as amended by Republic Act No. 9487, together with regulatory updates made by PAGCOR itself.
“These issuances have improved the market, but they can be revised, deferred or challenged, and the charter was not written with online gaming in mind,” Tonet observes. “A statute should set out which online activities may be licensed and by whom, the criteria for a license and the basis for fees and taxes. It should also define offenses that cover not only illegal operators but also those who knowingly process payments for them, advertise them or recruit players for them.
“The same law should give the regulator clear enforcement powers, including the power to order the blocking of illegal sites, to direct banks and e-wallets to stop processing illegal gaming payments, and to work with the Anti-Money Laundering Council on tracing funds. Website blocking alone has limited effect, as illegal operators can move to new domains. Payment channels are harder for them to replace.”
The Philippine legal export notes that setting predictable and stable rules makes them easier to implement, while published timelines, consultation drafts and a consistent fee policy would support channelization of players towards licensed sites.
Tonet acknowledges that PAGCOR helped avoid calls by some politicians in 2025 for a total ban on online gaming by introducing stricter regulations such as full know-your-customer (KYC) verification before a player can fund an account, setting the minimum playing age at 21, removing gambling advertisements from billboards and primetime broadcasts, and mandatory self-exclusion tools.
However, “A ban can be announced quickly,” she says. “Regulation takes longer and requires continuing engagement between government and industry. The Philippines chose regulation, and PAGCOR has implemented that choice despite considerable political pressure.
“What is needed now is a law that puts the framework on a firm legal footing, keeps the licensed market competitive, and gives the regulator the enforcement powers it needs. If Congress passes such a law, the Philippines can serve as a model for other emerging markets in the region.”
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The Backstory
Regulation has carried the market this far
The push for a dedicated Philippine online gaming law comes after a year in which regulators moved faster than Congress to keep the sector legal, supervised and politically defensible. PAGCOR has used its existing charter powers to tighten the market through know-your-customer rules, advertising restrictions, supplier accreditation, minimum fee requirements and new technical controls. Those steps helped blunt calls for a full prohibition in 2025, but they also exposed the limits of a framework built largely on regulatory issuances rather than a statute designed for internet gambling.
The core issue is durability. PAGCOR’s charter, Presidential Decree No. 1869 as amended by Republic Act No. 9487, gave the regulator broad authority over gaming. It was not written for mobile wallets, offshore websites, affiliate marketing, live-streamed casino tables or cross-border suppliers. That gap has become more significant as the Philippines has shifted from a market dominated by unlicensed offshore gambling to one where licensed operators now account for a larger share of recorded play. The policy question is no longer whether online gambling can be supervised. It is whether supervision can survive a change in political mood, a court challenge or an abrupt executive decision.
Channelization became the central policy bet
PAGCOR’s recent strategy has relied on channelization: making the licensed market viable enough to draw players away from illegal sites while raising compliance standards inside the regulated sector. The regulator cut fees, tightened onboarding, required KYC before funding accounts and began accrediting more of the supply chain. The approach reflected a practical calculation. If licensed operators are too expensive or too constrained to compete, players do not stop gambling; they move to operators that pay no tax, observe no age checks and ignore self-exclusion systems.
That tension is visible in the debate over gambling advertising. A related analysis of the proposed Gambling Advertising Prohibition Act warned that a total advertising ban could hand market share back to illegal online operators by silencing licensed brands while offshore sites continue to recruit through social media, messaging channels and influencers. The article cited data from Italy, Belgium, France, the Netherlands and the United Kingdom showing that strict or total advertising bans can weaken legal operators unless enforcement also reaches illegal platforms, payment channels and intermediaries.
The Philippine experience gives that debate immediate stakes. Licensed e-games revenue climbed sharply in 2023 through 2025 as more play moved into supervised platforms. At the same time, PAGCOR and other agencies referred thousands of illegal sites for blocking and pursued illicit payment merchants. That enforcement record depends partly on revenue from the legal sector. If regulation shrinks the licensed market without materially reducing demand, the state loses both visibility and funding.
New rules have raised compliance costs
The current call for legislation also follows a series of PAGCOR measures that have made online gaming licenses more demanding and less speculative. The regulator introduced a Minimum Guaranteed Fee for licensed operators, sought to address revenue underreporting and forced dormant or weakly capitalized license holders to reassess their position. Arden Consult has warned potential buyers that acquiring a PAGCOR-accredited company is not a shortcut to market entry because regulatory approval, operational control and compliance history remain central to the value of any deal.
That warning was outlined in a report on how purchasing PAGCOR-accredited igaming companies is more complicated than it appears. The report said a moratorium on new Gaming System Administrator applications and the MGF regime have encouraged consolidation, but buyers inherit liabilities as well as licenses. Unpaid fees, penalties, tax exposure, player-fund obligations, contracts with unaccredited suppliers and anti-money laundering weaknesses can remain with the company. More importantly, a certificate of accreditation remains subject to PAGCOR’s continuing authority.
Those developments support the argument for a statute. A clear law could define licensing rights, ownership approvals, fees, operator duties, player protections and enforcement tools in one place. It could also reduce the market’s dependence on regulatory notices that may be amended or suspended. For investors, that would improve predictability. For policymakers, it would make it easier to distinguish compliant capital from speculative license trading.
The supply chain is being pulled into view
PAGCOR’s reforms have not been limited to consumer-facing operators. The regulator has moved to bring suppliers, studios and support services into formal oversight. Its framework for data streaming providers created a regulated route for Philippine live-dealer studios to stream gameplay feeds to foreign-licensed operators. The rules cover accreditation, fees, workforce requirements and ongoing compliance, while limiting providers to infrastructure and content services rather than direct wagering activity.
That framework, described in detail when PAGCOR released new rules for live-dealer studios and streaming, is part of the same regulatory logic now driving the legislative debate. PAGCOR is trying to prevent gaming support services from becoming a back door for unauthorized operations. By requiring Philippine incorporation, local staffing thresholds and continuous oversight, it is seeking to preserve jobs and export services without recreating the risks associated with the former POGO model.
The supplier question matters because online gambling is not a single licensed entity. It is a network of operators, payment firms, game providers, affiliates, data vendors, customer-service teams and hosting arrangements. A statute could make clear which activities require accreditation, what conduct is prohibited and when third parties become liable for enabling illegal gambling. Without that clarity, enforcement often reaches the licensed operator first while offshore suppliers and promoters remain harder to sanction.
Player protection is becoming more technical
The Philippine debate also reflects a broader shift in gaming regulation: consumer protection is increasingly tied to data, payments and technology. KYC requirements, wallet controls, self-exclusion databases, real-time monitoring and responsible-gaming alerts all depend on systems that must be audited and enforced. That makes a purely charter-based framework harder to sustain as gambling products become more personalized and automated.
Other jurisdictions are moving in the same direction. The Malta Gaming Authority recently published a voluntary framework for responsible artificial intelligence use in gaming, covering player profiling, anti-money laundering, fraud prevention, customer service, payments and responsible gambling. The charter does not impose new legal obligations, but it shows how regulators are beginning to treat AI governance, transparency and human oversight as part of gambling supervision.
For the Philippines, the lesson is that online gaming rules need to be specific enough to cover technology as it is actually used. A law could require operators to maintain responsible-gaming tools, protect player data, submit systems for testing and prevent algorithms or promotions from targeting vulnerable users. It could also authorize PAGCOR to coordinate with banks, e-wallets, internet providers and the Anti-Money Laundering Council when illegal operators evade ordinary site blocking.
The stakes are legal certainty and political survival
The current article sits at the intersection of two pressures. On one side, PAGCOR has shown that tighter regulation can move gambling into the legal market and create tools to protect players. On the other, the absence of a dedicated statute leaves the system vulnerable to reversal. A ban can be announced quickly, while regulation requires procedures, budgets, technical capacity and sustained cooperation with industry.
That is why the call for legislation is not simply an industry plea for stability. It is also an enforcement argument. A statute could define illegal online gambling, criminalize payment processing and advertising for unlicensed sites, authorize faster blocking and give regulators clearer powers to trace funds. It could also codify age limits, KYC, self-exclusion, advertising standards and supplier accreditation, making them harder to dilute or challenge.
The Philippines has already chosen a regulated-market path in practice. The unresolved question is whether Congress will convert that practice into law before the next prohibition campaign tests it.
