How to Secure a Philippines Gaming License: PAGCOR, PIGO, and Post-POGO Compliance (2026)

Four main licensing tracks exist for gaming operators in the Philippines. The correct track depends on the business model, ownership structure, and whether the operation is B2C or B2B.

PAGCOR Gaming License: What It Covers and Who Issues It

PAGCOR (Philippine Amusement and Gaming Corporation) is the national gaming regulator and the issuing authority for all major gaming licenses in the Philippines. A PAGCOR license authorizes operators to run land-based casinos, electronic gaming machines in licensed venues, e-bingo halls, online sports betting platforms, and licensed gaming cafes. PAGCOR sets technical standards, game certification requirements, AML obligations, and Player Protection rules for all licensees.

Annual renewal is mandatory. PAGCOR conducts compliance audits and may revoke or suspend licenses for regulatory violations. Foreign operators seeking a PAGCOR license must comply with the 40.01% foreign equity cap at the corporate level before the application is filed.

PIGO License (Philippine Inland Gaming Operator)

The PIGO (Philippine Inland Gaming Operator) license is the domestic replacement for the now-prohibited POGO model. It authorizes the operation of domestic online gaming platforms serving Philippine-resident players. PIGO is the primary licensing track for operators who previously operated as POGOs and now seek a compliant domestic route to market.

Key PIGO requirements:

• Application fee: USD 40,000 to USD 50,000;
• Paid-up capital: approximately USD 440,000 (PHP 25 million equivalent at current rates; confirm current BSP exchange rate at time of application);
• Foreign equity: maximum 40.01%;
• Processing timeline: 13 to 18 weeks from complete submission;
• Technical system certification required before launch;
• AML compliance program and Player Protection protocol required at filing.

PAGCOR evaluates the applicant’s business plan, financial standing, technical infrastructure, and regulatory history. Conditional approval precedes full license grant. LegalBison coordinates the full submission package and manages communications with PAGCOR throughout the process.

Small Town Lottery (STL) Franchise Assistance

The Small Town Lottery (STL) is a lottery product operated under PCSO (Philippine Charity Sweepstakes Office) franchise, distinct from the PAGCOR licensing track. STL franchises are subject to a 100% Filipino ownership requirement: no foreign equity is permitted at any level. Required paid-up capital is PHP 25,000,000. STL operations are limited to specific geographic areas defined by the PCSO franchise grant.

LegalBison assists Filipino-owned operators with PCSO franchise applications, corporate setup, and compliance documentation. Foreign investors cannot hold equity in an STL franchisee but may provide management services or technology platforms through separate commercial arrangements, subject to PCSO approval.

B2B Supplier and Platform Accreditation

Under Republic Act 12312 (the Anti-POGO Act of 2025), game studios, platform vendors, payment processors, and KYC service providers are strictly prohibited from serving offshore gaming operators. The law explicitly bans individuals or entities from acting as “POGO gaming content providers” or “POGO accredited service providers”. 

Consequently, PAGCOR’s authority to issue accreditations, licenses, or permits to any third-party content and service providers for offshore gaming has been permanently revoked. 

LegalBison advises B2B suppliers on classification, accreditation documentation, and commercial contract structuring to ensure the supplier relationship is clearly defined within the Philippine regulatory framework.

A PAGCOR or PIGO license cannot be issued to a foreign entity. The applicant must be a Philippine-registered corporation that meets the equity, capital, and compliance requirements before the licensing process begins. Corporate setup and regulatory compliance build-out run in parallel, not in sequence.

SEC Registration and Foreign Ownership Structuring

Philippine law limits foreign equity in gaming companies to 40.01%. At least 59.99% of issued shares must be held by Philippine nationals. This cap applies regardless of license type and cannot be circumvented through nominee arrangements or trust structures. PAGCOR and the SEC conduct ownership verification as part of the licensing process.

Standard minimum paid-up capital for foreign-owned Philippine corporations is USD 200,000. This can be reduced to USD 100,000 for companies that qualify under employment or technology export incentive frameworks. LegalBison assesses eligibility for the reduced capital requirement during the feasibility stage and structures the entity to meet that threshold.

For operators considering Philippines as part of a broader Asia-Pacific corporate structure, see LegalBison’s company registration in Asia overview.

BSP Payment Compliance and OGTA Integration

The Bangko Sentral ng Pilipinas (BSP) issued a circular in 2025 establishing the Online Gaming Transaction Account (OGTA) framework for all licensed Philippine gaming operators. The OGTA rules govern how operators collect and disburse player funds. Non-compliance blocks an operator’s ability to process deposits or withdrawals legally.

Key 2025 BSP OGTA requirements:

• Facial biometric verification at OGTA registration;
• Six-hour daily limit on gaming activity per OGTA;
• Transfer caps on single-transaction and daily cumulative amounts;
• Mandatory BSP-compliant payment service provider (PSP) integration;
• Real-time transaction reporting to AMLC (Anti-Money Laundering Council).

LegalBison identifies compliant PSPs with active OGTA capability and manages the technical and contractual integration between the operator and the payment infrastructure. Operators applying for PIGO licenses must demonstrate BSP-compliant payment arrangements at the application stage.

For operators requiring gaming-specific banking support, see LegalBison’s high-risk business bank account and Asia business bank account services.

AML/KYC and Data Privacy Compliance Manuals

PAGCOR requires all licensees to submit a gaming-specific AML/CTF compliance manual aligned with FATF standards and AMLC (Anti-Money Laundering Council of the Philippines) guidelines. A generic AML policy is not acceptable. The manual must address gaming-specific risk scenarios: chip walking, smurfing, third-party funding of gaming accounts, and high-value player monitoring.

PIGO filing requirements also cover:

• Player Protection protocol covering responsible gambling, self-exclusion mechanics, and deposit limit enforcement;
• Data Privacy policy compliant with the Philippine Data Privacy Act (RA 10173) and PASED (Philippine Authority for Security for Data) requirements;
• KYC procedures that satisfy both PAGCOR technical standards and BSP OGTA identity verification requirements;

LegalBison’s compliance team drafts all three documents to PAGCOR specifications. Operators who submit AML programs that fail PAGCOR’s review face delayed approvals and mandatory re-submission. Pre-filing compliance review by LegalBison’s team is standard on all PIGO applications.