The Legality of Online Casino Sites in the Philippines A comprehensive legal guide (updated June 2025)

1 | Overview

The Philippines is one of very few Asian jurisdictions that expressly licenses, regulates, taxes, and hosts online-casino operations—both for overseas customers (the well-known POGO industry) and, on a more limited basis, for domestic players (PIGO and government-run platforms). The patchwork dates back to the 1970s PAGCOR charter but has grown to involve multiple economic-zone authorities, two major tax statutes, the Anti-Money Laundering Council (AMLC), and recent congressional inquiries. Key take-away: Operating or marketing an online casino to anyone in (or from) the Philippines without a Philippine licence is illegal; operating with the appropriate licence is lawful but heavily conditioned by statute, regulation, and policy.

2 | Constitutional & Statutory Foundations

Instrument	Core effect on online gambling
1973 PD 1067-A / PD 1869 (PAGCOR Charter)	Grants the Philippine Amusement and Gaming Corporation (PAGCOR) a 25-year (renewable) franchise “to operate, authorize and license games of chance” — now construed to include remote/online formats.
RA 9487 (2007)	Extends PAGCOR’s franchise to 2033 and affirms its right to regulate—not merely operate—“other forms of gaming” including internet-based variants.
RA 7922 (1995) (CEZA Law)	Creates the Cagayan Special Economic Zone and Freeport; empowers CEZA to issue “interactive gaming” licences for offshore-facing casinos.
RA 10927 (2017)	Amends the Anti-Money Laundering Act so all casino operators (land-based or online) are covered persons, subject to KYC, STR and CTR obligations.
RA 11590 (2021)	Creates a special 5 % tax on gross gaming revenue of POGOs, plus a 25 % withholding tax on foreign employees’ salaries, codifying an earlier DOF-BIR tax regime.
Executive Orders & PAGCOR Regulations (2016–2024)	Establish POGO (Philippine Offshore Gaming Operator) and PIGO (Philippine Inland Gaming Operator) frameworks, technical standards, audit rules, and advertising limits.
Presidential Directives (2022)	Permanently bans e-sabong (online cockfighting); orders a compliance sweep of POGO licensees after criminal-activity probes.

Note: The 1987 Constitution does not ban gambling outright; it merely requires that “franchises or concessions” be granted under law and in the national interest. Authority therefore rests on the enabling statutes above.

3 | Regulatory Authorities

PAGCOR – Issues POGO and PIGO licences; supervises domestic e-games cafés, integrated resorts’ remote gaming, bingo, sports betting, and recently trialled “live dealer” studios for locals.
CEZA (via First Cagayan Leisure & Resort Corp.) – Handles Interactive Gaming Licence (IGL) holders that must geo-block Philippine IP ranges and market only offshore.
AFAB / APECO / PEZA – Smaller economic zones that may license e-gaming as part of fintech or IT-BPO incentives, but PAGCOR approval is still required for any gambling content.
AMLC – Monitors compliance with AML/KYC and imposes hefty administrative fines.
BSP – Regulates e-money issuers, payment gateways and foreign-exchange dealers that process gaming funds.
LGUs & Barangays – May impose additional “regulatory fees” and zoning rules on physical studios or data centres; can also block business-permit renewals.

4 | Licensing Regimes in Detail

Regime	Target market	Key licence prerequisites
POGO (2016-)	Non-Philippine players only	• US$200 k paid-up capital (B2C) • Gaming system locates servers in PH but configures IP-blocking, geo-fencing, and third-party testing • Probity checks on major shareholders; no person with a “criminal or gambling debt record” may hold >5 % share.
PIGO (2021-)	Philippine residents	Available only to existing PAGCOR licensees (e.g., integrated resorts, e-games cafés). Must deploy strict age-verification, a 100-meter radius self-exclusion, and daily loss limits.
CEZA IGL (2003-)	Offshore	Similar to POGO but falls under CEZA audit; licencees pay a “zone fee” (2 % of GGR) plus USD 40 k–100 k annual licence fee.
Government-run portals (e.g., eGameStations)	Domestic	Operated directly or under contract with PAGCOR; uses pre-approved RNGs, no live-dealer.

5 | Taxes & Fiscal Incentives

For PAGCOR casino licensees (PIGO):

5 % “franchise tax” on gross gaming revenue (replaces all other national taxes).
50 % of net earnings remitted to the National Treasury as the PAGCOR dividend.

For POGOs:

5 % tax on GGR (RA 11590)
25 % withholding tax on foreign workers’ gross income OR P12,500/month, whichever is higher.
Documentary stamp tax on bets (P0.10 per P200 wager) if the bet originates from PH-based servers.

Common obligations: value-added tax on non-gaming revenues; LGU business-permit fees; annual regulatory fees (inspection, audit platform, responsible-gaming fund).

6 | Consumer-Protection & Responsible-Gaming Rules

18+ Age restriction; digital ID verification required for remote play.
Self-exclusion & Limits – Players may voluntarily self-exclude for 6 months minimum; operators must maintain a national exclusion registry. PIGO licensees must implement deposit, wagering, and loss ceilings (recommended: P10 k daily, P100 k monthly, unless higher limit approved).
Advertising – No TV/radio ads from 6 a.m.–9 p.m.; celebrity endorsements must carry an 18+ disclaimer; social-media marketing must geo-fence minors.
Data privacy & cybersecurity – Compliance with RA 10173 (Data Privacy Act) and RA 10175 (Cybercrime Prevention Act). Encryption of payment data at rest and in transit; retention limited to five years for KYC documents.

7 | Anti-Money Laundering & Counter-Terrorist Finance

Since 2017, all casinos are “covered persons” under the AMLA. Key pillars:

Know-Your-Customer – Full face-to-face or equivalent digital ID verification above an initial measured threshold (P5,000 for online gaming).
Record-Keeping – 5-year retention.
Reporting
- CTR – Cash transactions ≥P5 million (≈USD 90 k) in any one-day period.
- STR – Any suspicious pattern regardless of amount.
Compliance Officer & Training – Mandatory; subject to on-site AMLC audits.
Penalties – Up to P500 k per violation per transaction; possible criminal prosecution.

8 | Prohibited Acts & Criminal Liability

Provision	Offence	Penalty
Revised Penal Code Art. 195-196	Betting or maintaining illegal gambling venue	Arresto mayor + fine (P200–P2,000) – rarely used now.
RA 9287 (2004)	Numbers games without franchise (e.g., jueteng, masiao)	Graduated; up to life imprisonment + P10 m fine.
PAGCOR / CEZA Rules	Operating without licence, failing to geo-block, employing unlicensed software	Immediate closure, forfeiture of security deposit (US$250 k typical), blacklist of directors/shareholders, possible deportation of foreigners.
Cybercrime Act	Computer-related fraud or hacking of RNGs	Prision mayor + fine up to P1 m.

Note: Individual players who wager on offshore websites are generally not criminally liable, but their deposits may be frozen if linked to unlawful activity; the government also routinely blocks IPs and payment rails of unlicensed sites.

9 | Judicial & Policy Precedents

Basco v. PAGCOR (G.R. No. 91649, May 14 1991) – Supreme Court upheld the PAGCOR charter’s constitutionality, recognising broad police power to regulate gambling.
Philweb v. PAGCOR litigation (2016) – Confirmed PAGCOR’s discretion to renew or deny e-games café licences.
Senate Blue Ribbon & Ways and Means Hearings (2020–2024) – Highlighted kidnapping, tax-evasion, and human-trafficking risks tied to POGOs; resulted in AMLC and Bureau of Immigration task forces, plus an as-yet-unpassed Senate bill seeking to phase out offshore gaming by 2028 unless “economic benefits outweigh social costs”.

10 | Cross-Border & Payment Issues

Geo-Fencing – POGOs must block IPs originating within Philippine territory; failures have led to multi-million-peso fines.
Payment Gateways – BSP Circular 1108 (2020) requires a licence for operators offering e-money or virtual-asset settlements; gaming funds must pass through designated bank escrow.
Foreign Exchange – All repatriations of winnings to overseas players must be coursed through Bangko Sentral-regulated banks, with invoice and player ledger.
Double-Tax Treaties – Revenue sourced from play outside the Philippines is not subject to local withholding tax, provided supporting transfer-pricing study.

11 | Special Topic: The 2022 e-Sabong Ban

• e-Sabong was authorised under PAGCOR Memorandum Circular 2021-12, generating ~P640 m monthly in licence fees. • May 3 2022: Executive Order halted operations citing “serious social cost” and ongoing criminal investigations of 34 missing sabong agents. • No online cockfighting is currently lawful, and PAGCOR will not accept new applications pending congressional review.

12 | Compliance Checklist for Prospective Licensees

Choose the correct regime (POGO, PIGO, CEZA IGL).
Incorporate a Philippine-registered corporation with minimum paid-up capital.
Apply for licence – submit Business Plan, RNG certification, server-room floorplan, and Responsible-Gaming Program.
Post security deposit (USD 250 k – 500 k) to PAGCOR/CEZA.
Undergo probity & technical audits (third-party lab).
Register with AMLC & BIR; configure reporting API.
Secure LGU locational clearance and Occupational Permits for expatriate staff.
Open escrow bank account; integrate with an accredited e-wallet.
Launch in “soft-opening” monitored by regulators.
Annual licence renewal – subject to compliance scorecard and updated security audit.

13 | Future Direction (2025 - 2030)

Possible Senate ban or moratorium on POGO renewals; outcome dependent on 2025 revenue-versus-social-cost study.
Digital Peso Pilot (BSP) may create a regulatory sandbox for on-chain gaming settlement.
Higher ESG/Responsible-Gaming scores – PAGCOR draft rules (April 2025) propose P50 m annual fund contributions for mental-health programs tied to gambling harm.
Regional competition – Thailand and Japan are drafting their own i-gaming bills; Philippine regulators aim to maintain “first-mover” advantage by streamlining onboarding and adopting ISO 27001 data-security standards.

14 | Practical Advice

For Operators: Engage local counsel early; budget at least 6-9 months for full licensing if foreign-owned.
For Payment & Tech Vendors: Obtain separate BSP or DICT accreditation; cross-list your solution with PAGCOR’s Gaming Systems Providers roster.
For Players: Use only domains listed on PAGCOR’s or CEZA’s public registries; verify SSL certificates and look for the Responsible Gaming logo to avoid phishing clones.
For Investors: Monitor House Bill 5082 (pending) which seeks a unified Gambling Regulatory Authority—this could consolidate PAGCOR’s regulatory and operating roles, forcing divestment of state-run casinos and reshaping online concessions.

15 | Conclusion

The Philippine legal landscape does not merely tolerate online casinos—it actively licences and monetises them, albeit within a strict and evolving compliance envelope. Companies that align with the PAGCOR or CEZA rulebooks, pay the correct taxes, and implement world-class AML/responsible-gaming controls can lawfully tap into both offshore and (to a limited extent) domestic markets. Conversely, unlicensed operators—and even licensed firms that neglect data-security, tax, or KYC duties—face swift suspension, multi-million-peso penalties, and potential criminal action.

This article is for general information only and does not constitute legal advice. Seek professional counsel for specific situations.