Total Philippines gambling ad ban seen handing market back to illegal operators, data from five countries show

In a special article, CiG’s expert contributor Tonet Quiogue outlines the repercussions of gambling advertising bans, the methods being deployed to avoid gambling harm in the Philippines and what the data show about how regulatory efforts have been effective in managing the balancing act of active industry and public safeguards.

Market data, the experience of foreign regulators, and the government’s own enforcement record all point to the same risk in a Senate bill that would ban all gambling advertising: the measure could reverse three years of gains against illegal online gambling and push Filipino players to offshore operators outside Philippine law.

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Senator Francis “Chiz” Escudero filed Senate Bill No. 2347, the Gambling Advertising Prohibition Act (GAPA), on 26 July 2026. The bill prohibits gambling advertising and sponsorship in all media: broadcast, print, outdoor, websites, applications and social media. It also bans celebrity and influencer endorsements and gaming sponsorship of sports and cultural events. Licensed operators may advertise only inside their own premises and on their own websites and apps. Penalties reach Php500,000 (US$8,103)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$8,100), three years in prison, license revocation, liability for corporate officers and deportation for foreign nationals. Operators get one year to comply.

Every country that has enacted a total gambling advertising ban, starting with Italy in 2018, ended up with a larger illegal market. Italy is now unwinding its ban. A prohibition binds only licensed operators; the offshore sites that already advertise illegally to Filipinos keep their channels and inherit the audience. And the ban would cut licensed gaming revenue and PAGCOR remittances, the same funds that pay for the government’s campaign against illegal sites.

Legislators also have an alternative already on the table. Senate Bill No. 57, the Online Gambling Regulatory Act filed by Senator Sherwin Gatchalian in July 2025, is pending in committee. It looks at the industry as a whole: operators, payments, player protections and advertising in one framework, rather than banning one piece of it. Industry groups say the advertising rules GAPA seeks, plus an outright ban on advertising by illegal operators, can be written into that bill with enforcement teeth.

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Escudero says the measure follows the Tobacco Regulation Act of 2003 (Republic Act No. 9211): “It’s about time that we regulate the gambling industry the same way we regulated tobacco two decades ago.”

Nobody disputes the objective of protecting minors and vulnerable players, and the licensed industry has publicly backed stricter advertising rules. The question the data raises is whether a total ban advances that objective or sets it back.

Three years of migration from illegal to legal play

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Independent estimates describe the same trajectory from different methods. In 2022, industry estimates placed the offshore market at nearly four times the size of the licensed one. In August 2025, PAGCOR Chairman Alejandro H. Tengco told the House that more than 60% of online gambling remained illegal. By December 2025, monitoring figures from Yield Sec, which Tengco cited, put licensed operators above 50% for the first time, and Blask, a demand-side analytics firm, estimated the legal share at about 58% by March 2026. The estimates differ in method, but they point the same way: most Filipino online wagers now run through licensed platforms, and the share is rising.

The shift did not happen by accident. Regulators call it “channelization”: moving players from illegal sites to licensed ones. PAGCOR engineered it. The regulator cut e-games license fees from over 50% of gaming revenue to 30%, required KYC-verified payments and real-time wager monitoring, accredited the full supply chain from operators to marketing affiliates and escalated enforcement against illegal sites. Licensed e-games revenue more than tripled, from Php58.16 billion (US$943 million)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$942 million) in 2023 to Php201.12 billion (US$3.3 billion)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$3.26 billion) in 2025, and online overtook land-based casinos for the first time. Read against those estimates, the tripling mostly reflects existing wagers moving from illegal platforms to legal ones, not a threefold increase in gambling. What tripled was not the vice but the State’s visibility into it.

The Casino Plus fine: what regulation can reach, and what it cannot

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A July 2026 episode illustrates both sides of the debate. Actress Ivana Alawi, a brand ambassador of the licensed platform Casino Plus, gave away 100 high-end phones worth more than Php4 million (US$64,824)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$64,770). To join, users had to like the platform’s Facebook page. PAGCOR acted within days. It fined the operator Php1 million (US$16,206)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift for running the promotion without prior approval, ordered it stopped and warned that a repeat could bring suspension or cancellation of the license.

“We already implemented that; they paid PHP1 million (US$16,206)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift, and we instructed them to stop the said promotion,” Tengco said.

The episode shows the kind of celebrity promotion that alarms legislators. It also shows enforcement that works only on licensed operators. The license gave PAGCOR something to act on: it collected a fine, the operator obeyed the stop order and the franchise can be revoked. If any of the more than 1,000 illegal sites the CICC has identified had run the same giveaway, none of those tools would apply. PAGCOR cannot fine, suspend or sanction an unlicensed operator; it can only refer sites for blocking while mirror domains multiply. Illegal operators already run the same kind of promotions through influencers, to audiences that include the young and the financially vulnerable. They ask no permission, pay no fines and hold no license to lose. A total advertising ban will not stop these promotions. It will make them the only ones left.

A total ban puts legal and illegal on the same level, in the one arena where the illegal side adapts fastest

A license carries heavy obligations: a 30% fee on gaming revenue, KYC checks on every player, real-time monitoring, pre-screened advertising, capped promotions. In exchange it gives one commercial advantage: the right to build a brand lawfully, in public. GAPA removes the advantage and keeps every obligation. Industry executives now ask a blunt question: if a licensed operator can no longer market, what is the license for? A permit that costs 30% of revenue and gives no right to reach customers is a burden, not a franchise.

The levelling is not a stalemate, because the two sides adapt at different speeds. Illegal operators change domains faster than blocklists update, shift into group chats and private messages, and recruit new influencers as fast as old ones are exposed. Roland Cinco, CEO of Digirockstars, which runs performance marketing and affiliate programs for licensed operators in the Philippines, says the creator market is already repricing.

“Creators are pricing the ban in,” he said. “They are not leaving the category; they are quoting higher rates to the illegal market for it. The reasoning they give is that association with gaming now carries more risk to their own brand, so the rate goes up.

“The creator market does not go quiet if this passes. It gets more expensive. And the buyers who can absorb a risk premium are the ones paying no license fee and no compliance.”

A licensed operator cannot adapt around the law it operates under. When both sides are silenced on paper, the side that ignores paper wins. Licensed operators lose players, licensed gaming revenue contracts, and the government’s share contracts with it, while the same wagers continue offshore and produce nothing for the State.

What the tobacco ad ban achieved

The tobacco precedent is more qualified than commonly assumed. The Tobacco Regulation Act removed cigarette advertising from television, radio, cinema and billboards, and it could do that because every cigarette advertiser in the country was a Philippine-registered business. Even so, the ban suppressed marketing; it did not silence it. In 2009, the year after the full prohibition took effect, 74.3% of Filipino adults said they had noticed cigarette marketing in the past 30 days; in 2021 the figure was still 46.7%. Smoking fell from 29.7% of adults in 2009 to 19.5% in 2021, a decline credited mainly to the price increases of the 2012 sin-tax law. And vapes, the one nicotine product marketed the way online casinos are, still reach Filipino youth through social media despite the statutory ban.

The economics literature explains why. Saffer and Chaloupka studied advertising bans in 22 OECD countries and found that bans reduce consumption only when they close every channel at once; partial bans achieve little, because marketing money moves to the channels that stay open. A gambling advertising ban is partial by nature. About 80% of gambling marketing is digital and the biggest advertisers reaching Filipinos are offshore operators who already break the law by advertising: the CICC has identified more than 1,000 illegal sites and over 100 influencers promoting them. GAPA binds only advertisers inside Philippine jurisdiction. One industry analysis calls it “a partial ban wearing a total ban’s clothes: total for the licensed sector, partial for the market.”

Unlike cigarettes, the legal and illegal products differ

Two more differences separate the markets. Every cigarette, legal or smuggled, carries the same health risk, so a tobacco ad ban costs consumers no safety information. Legal and illegal gambling differ on every dimension a regulator measures, and in a regulated market, advertising is how players find the supervised product. Gaming lawyers put it this way: “the advertisement is the warning label: it is how a player tells the supervised platform from the trap dressed to look like one.” And where cigarettes still required an in-person purchase after the ad ban, an online gambling promotion links straight to registration and deposit. “The ad is the doorway.” The ad and the product arrive on the same screen, one tap apart.

International rules reflect the distinction. Tobacco is harmful at any dose and sits under a binding global treaty, the WHO Framework Convention on Tobacco Control, which drives consumption toward zero. Gambling has no such treaty. The World Health Organization estimates gambling disorder at 1.2% of adults and tells states to “closely monitor and effectively regulate gambling operations, products and activities.”

What a license gives the player: the right to be refused

Licensed platforms must verify a player’s age and identity before any wager, use independently certified games, run under PAGCOR monitoring, offer deposit and loss limits, display the National Problem Gambling Helpline, and answer to PAGCOR when a player disputes a withheld payout. The system’s most distinctive feature is the right to be banned. Under PAGCOR’s exclusion programs, any person can bar themselves from gambling for six months, one year or five years. A spouse, a parent or a child of legal age can petition to exclude a problem gambler in the family, without the gambler’s consent. Every name enters the National Database of Restricted Persons (NDRP), and all PAGCOR-regulated venues and platforms must enforce it. A parent who fears a child is losing control, or a spouse watching the savings drain, has a legal remedy, but only against the licensed market. No illegal site consults the NDRP, honors a family petition, or refuses anyone. These protections reach only as far as the licensed market extends. That is what channelization measures.

Five countries have run the experiment

Italy went first. Its 2018 Dignity Decree imposed a total advertising and sponsorship ban, the same design as GAPA. Eight years later, Italy’s illegal online market is estimated at €20 billion (US$23 billion)1 EUR = 1.1655 USD
2026-08-25Powered by CMG CurrenShift (US$23.3 billion) a year, larger than the legal market’s €11.47 billion (US$13.4 billion)1 EUR = 1.1655 USD
2026-08-25Powered by CMG CurrenShift (US$13.4 billion). A 2022 parliamentary inquiry found underage and illegal gambling kept growing after the ban, the Italian football federation calls the measure “largely ineffective,” and the Italian Senate and media regulator AGCOM are now softening it.

Belgium went near-total in July 2023: within three months, players on illegal sites rose 6% and deposits rose 4%, and illegal operators targeting Belgium grew 4.4-fold that year. France never licensed online casino; its illegal sites now count 5.4 million players, more than the regulated sector’s 3.5 million, at an estimated €1.2 billion (US$1.4 billion)1 EUR = 1.1655 USD
2026-08-25Powered by CMG CurrenShift (US$1.40 billion) a year in lost taxes. The Netherlands banned untargeted advertising and capped deposits; channelization by revenue fell to 49% in the first half of 2025. The United Kingdom shows the other path: it permits gambling advertising under strict content, placement and targeting rules and keeps about 98% of online play inside the licensed market. Countries that silence their legal markets get bigger illegal ones. Countries that let the legal market be seen, under hard rules, get smaller ones.

Who stands to absorb displaced players

The operators positioned to absorb displaced players are documented. PAGCOR monitoring has linked detected illegal gambling sites to former POGO networks, and the PAOCC and PNP still run operations against successor groups of the scam compounds shut down in 2024. These sites register users with a phone number or e-mail, set no deposit or loss limits, run uncertified games, and pay no Philippine tax. France measured what happens to players on such sites: 62% showed excessive or pathological gambling, 70% suffered data theft, phishing or fraud, and 90% received unsolicited gambling advertising.

None of the Philippine market’s protections follows a displaced player. Deposit limits, age checks and monitoring apply only to licensed platforms, and so does the NDRP. Illegal operators can market to every name on the exclusion list. Industry lawyers warn that “to an illegal operator, the self-exclusion list is not a barrier; it is a prospect database.” A shift from licensed to unlicensed play moves the most vulnerable players first, because they are the ones the licensed market currently restricts.

Harsher than the tobacco law it cites

GAPA is presented as a copy of the tobacco law. Side by side, the two differ on four points. Timing: the Tobacco Regulation Act gave the industry five years to phase out advertising; GAPA gives one. The remaining channel: the tobacco law permanently allowed ads inside stores that sell cigarettes; GAPA’s only remaining channel is the operator’s own website, which reaches only people who already know the brand. Standards: the tobacco law used numbers a company can measure, with print ads allowed at 75% adult readership and sponsorships at 75% adult attendance; GAPA uses a judgment call, whether something is “likely to appeal to persons below 21,” and makes getting that judgment wrong a crime. Penalties: the tobacco law’s fines ran from Php100,000 (US$1,621)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift to Php400,000 (US$6,482)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$1,620 to US$6,475); GAPA’s run from Php200,000 (US$3,241)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift to php500,000 (US$8,103)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$32,390 to US$8,100) and add license revocation and deportation.

There is also a gap in who the penalties reach. Imprisonment, officer liability and deportation apply only to people in the Philippines: licensed operators, local broadcasters, local ad agencies, and the foreign executives of accredited suppliers with offices here. None of it touches the offshore operators doing most of the illegal advertising, and the bill contains no provision aimed at them: no penalty for promoting an unlicensed site, no liability for platforms paid to carry illegal ads, no faster site-blocking, no added enforcement funding.

The stakes: revenue, remittances and the enforcement budget

The licensed market already operates under heavy new restrictions: e-wallet de-linking that cut licensed online transactions by about half, billboard removal, ad pre-screening, bans on credit-card and cryptocurrency betting, and capped rebates. PAGCOR revenue from eGames grantees fell 41.85% in the first half of 2026. A total ad ban on top of this would stop licensed operators from acquiring new players while illegal recruitment continues, slide channelization back toward its old levels, and shrink the PAGCOR remittances that fund enforcement: Php30.16 billion (US$489 million)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$488 million) went to nation-building in the first half of 2026, and the campaign behind it has referred 13,399 illegal sites, blocked 12,562, granted Php50 million (US$810,300)1 PHP = 0.0162 USD
2026-08-25Powered by CMG CurrenShift (US$809,650) million) to the NBI, and cut off more than 3,200 illicit payment merchants. One measurement caution: if licensed revenue falls after a ban, that shows less recorded gambling, not less gambling. Italy’s numbers show a legal market can shrink while the illegal one grows.

An alternative is already pending

Senate Bill No. 57 remains pending in committee and can house the advertising rules GAPA seeks. An advertising chapter built on the tobacco-law design would set content standards that bar any appeal to minors or vulnerable groups, placement rules and watershed hours, measurable audience thresholds in place of guesswork, and mandatory responsible-gaming messaging with the national helpline in every advertisement. Two more provisions would strike at the actual source of harm: mandatory accreditation and responsible-gaming training for every influencer, celebrity and affiliate who promotes gaming, and an absolute, criminally enforced ban on advertising by unlicensed operators, with liability for platforms and intermediaries paid to carry it. Industry groups support both. “On TikTok and Google, a gaming advertiser has to be certified and show a license before the account can run,” Cinco said. “Other networks have no equivalent check.” A position paper submitted to Congress during the 2025 prohibition debate framed the choice in terms that apply equally here: “A blanket ban would forfeit the control and transparency that come with regulation, and hand over the market to unscrupulous illegal operators who evade taxes, ignore rules, and offer no consumer protections.”

Regulated advertising also has an affirmative use: it is the State’s cheapest education channel. Rules can require each licensed ad to display the operator’s license number and point players to PAGCOR’s Guarantee portal, where anyone can check a brand and URL against the official registry. Used this way, the industry’s own marketing budgets teach the public to tell a licensed platform from an illegal one, at no cost to government. Every legal ad is a lesson in telling the licensed from the lawless. The State should write the curriculum, not cancel the class.

Three years forward, and the road back

PAGCOR built a turnaround few markets have managed: in three years it converted an online gaming market that was overwhelmingly illegal into one where, for the first time, most play is supervised. It cut license fees to make legality viable, accredited the supply chain down to the marketing affiliates, drew internationally regulated suppliers into Philippine-registered operations, launched a 24/7 helpline, and referred more than 13,000 illegal sites for blocking. Tengco summarized the approach at ICE Barcelona in January: “The greatest threat to both regulators and licensed operators is not higher standards. It is the continued presence of illegal and unregulated actors that undermines trust and distorts competition.”

The data above describe the road back, because the Philippines has been there. As recently as 2022, the offshore market was estimated at nearly four times the size of the licensed one, and those wagers ran through operators that verified no ages, honored no self-exclusions, paid no taxes and answered to no one. Industry stakeholders say they are ready to put the channelization data, independent market estimates and enforcement record before legislators as the bill moves through committee. On the evidence, the choice before the Senate is not between more gambling and less. It is between gambling the State can see and gambling it cannot.

Dig Deeper

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The Backstory

Regulators chose channelization before prohibition

The debate over a total gambling advertising ban in the Philippines sits on top of a broader regulatory shift that began after the pandemic pushed more betting online. PAGCOR, the Philippine gaming regulator, responded by trying to move players and operators from offshore and illegal sites into a supervised domestic market. The policy aim was channelization: make the licensed market viable enough that users would choose it, then raise standards once it had scale.

That sequence explains why the current proposal is contentious. The advertising bill would restrict the legal industry’s ability to reach consumers just as regulators are trying to keep those consumers inside a licensed system. Supporters see a public-health measure aimed at minors and vulnerable players. Critics argue it would weaken the one part of the market PAGCOR can police while leaving offshore operators free to keep marketing through social media, messaging apps and mirror domains.

PAGCOR Chairman Alejandro Tengco has repeatedly drawn that distinction. In remarks covered in his rejection of calls for a total e-gaming ban, Tengco said the regulator favors stricter regulation, not prohibition, warning that bans would cut government revenue, cost jobs and leave consumers exposed to illegal operators. His position has become the institutional counterweight to proposals that would sharply limit, or eliminate, licensed online gambling activity.

Fee cuts built the legal market, then the bar rose

PAGCOR’s approach first lowered the cost of legality. Electronic gaming license fees, which had been above 50% of gaming revenue, were reduced to 35% in 2024 and then to 30% in 2025, with lower rates for some operators linked to land-based venues. The rationale was commercial as much as regulatory: operators and players needed a reason to move into the licensed system before PAGCOR could credibly impose tougher controls.

That strategy helped electronic gaming become the largest component of Philippine gaming revenue in 2025. But the next phase was more restrictive. A white paper by Arden Consult, described in an analysis of the first-half 2026 decline in online gaming revenue, characterized the drop as part of a longer reset rather than a simple deterioration. PAGCOR tightened advertising rules, strengthened player verification, required accreditation across parts of the B2B supply chain and escalated action against illegal sites and payment channels.

The resulting fall in reported revenue created a political opening for critics of online gambling. PAGCOR’s revenue from eGames, eBingo and bingo grantees dropped 41.9% year on year in the first half of 2026 to Php18.6 billion. Arden’s argument was that the headline number did not necessarily mean policy had failed. It could also reflect the cost of building a cleaner market, especially after e-wallet de-linking, stronger know-your-customer rules and tougher marketing controls made legal platforms less frictionless than they had been.

Minimum fees turned licenses into obligations

The regulatory reset also changed the economics of holding a PAGCOR accreditation. The new Minimum Guaranteed Fee, which took effect in 2026, made dormant or low-volume licenses more expensive. Operators with electronic casino games face a Php9 million monthly minimum fee based on a Php30 million monthly gross gaming revenue benchmark. Operators without electronic casino games face a lower minimum tied to a Php15 million benchmark, with increases scheduled for 2027.

That policy is pushing consolidation. Arden Consult warned that investors looking at the market should not assume a PAGCOR-accredited company is a simple license play. In a report on the risks of buying PAGCOR-accredited iGaming companies, the firm said buyers inherit the corporation’s regulatory history, liabilities, unpaid fees, player-fund obligations, tax exposure and compliance record. PAGCOR approval remains required for changes in ownership or control.

That matters for the advertising fight because it shows where policy has been heading. PAGCOR is trying to ensure that licenses are held by operators with capital, compliance systems, responsible-gaming technology and transparent governance. A total advertising ban would arrive after those costs have increased. For licensed companies, the practical concern is that the state would preserve the burdens of accreditation while removing the commercial ability to build a visible brand.

That asymmetry is central to industry objections. Illegal sites pay no minimum fee, submit no platform architecture for review, comply with no player-protection rules and face no meaningful penalty if they market to Filipino users from offshore. A stricter licensed market can work if enforcement and channelization keep pace. It becomes fragile if legal operators are made less usable or less visible than illegal competitors.

Political pressure grew alongside enforcement

The advertising ban also reflects a broader political response to public concern over online gambling’s growth. Malacañang has said President Ferdinand Marcos Jr. is weighing the advantages and risks of a total online gambling ban. In comments from the presidential palace, Press Officer Claire Castro said the administration was studying the economic and public impact, including the risk that banning legal sites could drive more activity to illegal platforms.

That caution mirrors the regulator’s own concern. The Philippines already shut down Philippine offshore gaming operators, or POGOs, after years of controversy linking parts of the sector to fraud, criminal syndicates and scam compounds. But the end of POGOs did not end online gambling demand or offshore targeting of Filipino users. Instead, authorities have continued to block illegal domains, pursue payment channels and pressure platforms that facilitate unlawful play.

Advertising became an early target. PAGCOR banned billboard advertising by online gambling companies and barred gambling advertisements during prime-time television hours. Lawmakers also called for stronger scrutiny of gambling promotions. Those actions created a middle path: legal marketing could remain, but under tighter limits on placement, content and audience exposure.

The new bill would go further. By banning gambling advertising and sponsorship across broadcast, print, outdoor, digital media, apps, social media, celebrity endorsements and sports or cultural sponsorships, it would effectively remove licensed operators from public-facing promotion. The policy question is whether that protects consumers or simply erases the visible distinction between licensed platforms and illegal substitutes.

B2B oversight shows the same regulatory logic

PAGCOR’s recent treatment of suppliers shows that the regulator is not only focused on front-end operators. It has been extending oversight into the infrastructure that supports online gaming, including systems providers, marketing services, aggregators and live-dealer streaming businesses. That broader perimeter is intended to prevent illegal or unauthorized activity from hiding behind technology and service providers.

The most recent example is PAGCOR’s framework for data streaming providers, covered in its new rules for live-dealer studios streaming to foreign-licensed operators. The framework formalizes a Philippine live-studio model that may serve operators licensed abroad while remaining under PAGCOR supervision. It requires accreditation, compliance standards, fees, workforce rules and restrictions on dealing directly with end users.

Arden Consult compared the framework to the Special Class BPO regime: local facilities, local workers and foreign-licensed clients, all under continuing scrutiny. The distinction from the former POGO structure is important. A data streaming provider does not operate games or take bets. It supplies content and infrastructure to operators that must be licensed elsewhere.

This supplier-level regulation is relevant to the advertising debate because it shows a policy preference for traceability rather than disappearance. PAGCOR has been building rules to identify who operates, who supplies, who markets and who handles player access. A total ad ban moves in the opposite direction if it pushes promotion into informal affiliate networks, private chats and offshore influencer arrangements that are harder to identify and punish.

The stakes are fiscal, political and consumer-facing

The central trade-off is not whether the Philippines should regulate online gambling. That question has effectively been answered by PAGCOR’s recent actions. The fight is over the form of regulation: a strict but visible legal market, or a prohibition-style advertising regime that may reduce the appearance of gambling while leaving demand and illegal supply intact.

For the government, the fiscal stakes are substantial. E-gaming has become a major contributor to PAGCOR income and remittances used for public programs and enforcement. A sharp contraction in licensed revenue would reduce the funds available to police illegal operators, block sites and support investigations. If players migrate offshore, the state loses visibility, tax revenue and leverage over consumer protections.

For consumers, the distinction is practical. Licensed platforms can be required to verify age and identity, enforce exclusion lists, display responsible-gaming messages, submit games and systems for testing, honor dispute processes and comply with payment rules. Illegal operators can ignore those obligations while offering faster onboarding, looser limits and aggressive promotions.

That is why the advertising bill has become a test of the Philippines’ broader online gambling strategy. PAGCOR spent the past three years trying to pull activity into the regulated perimeter, then raising standards once the market was inside it. A total advertising ban would test whether that perimeter can hold when licensed operators lose much of their ability to be seen.