PAGCOR Online Casino License Verification in the Philippines

A Practitioner-Oriented Legal Article

1. Statutory and Institutional Framework

Instrument	Key Provisions for Online Gaming
Presidential Decree (PD) 1869 (1983) – Consolidated PAGCOR Charter	Grants PAGCOR the “sole and exclusive authority and right” to operate and regulate games of chance, whether on-site or by “other modern means of communications.”
Republic Act (RA) 9487 (2007) – Charter Extension	Extends PAGCOR’s franchise to 25 July 2033 and expressly empowers it to “authorize, license and regulate games of chance, games of cards and games of numbers both in land-based venues and through the use of the internet.”
RA 10927 (2017) – AMLA Amendment	Brings casinos—land-based, shipboard and online—within the Anti-Money Laundering Act and requires risk-based customer due diligence.
RA 10173 (2012) – Data Privacy Act	Imposes data-protection standards on licensees, with the National Privacy Commission (NPC) exercising concurrent jurisdiction over breaches.
Implementing Rules and Regulations (IRRs) & PAGCOR Manuals	PAGCOR issues “Offshore Gaming Licensing Rules,” “Minimum Internal Control Standards” (MICS), “Technical Standards for Electronic Gaming,” and memoranda on Philippine Inland Gaming Operator (PIGO) licences issued during the 2020–2021 pandemic.

Note: Other economic-zone regulators—CEZA (Cagayan), APECO (Aurora) and AFAB (Bataan)—may issue interactive gaming licences, but domestic acceptance of bets remains exclusively under PAGCOR.

2. Categories of PAGCOR Online Licences

Philippine Offshore Gaming Operator (POGO).
- Customers: strictly outside the Philippines.
- Fiscal incentives: subject to 5 % gross gaming revenue (GGR) tax + 25 % income tax on alien workers.
Philippine Inland Gaming Operator (PIGO).
- Customers: Philippine residents who must first register onsite.
- Vertical-specific: e-casino, sports, e-bingo, e-sabong (cock-fighting), etc.
E-Games & E-Bingo Stations.
- Internet protocol is used but play occurs in a physical venue.
Special Classifications.
- Platform & System Provider, Audit Platform Provider, Gaming Support Provider (GSP).

3. Operator-Side Licence Verification

3.1 Application Dossier

Requirement	Primary Reference
SEC-registered corporation with ≥ PHP 100 M paid-in capital (PIGO) or USD 200 K (POGO)	PAGCOR Licensing FAQs
Beneficial-ownership diagram certified by the Corporate Secretary	RA 9160, Sec. 3(b)
Business plan and 3-year financial forecast	PAGCOR Junket & Gaming Circulars
System Architecture & RNG Certification from GLI/iTech Labs or equivalent	Technical Standards 2019
ISO 27001 or PCI-DSS compliance evidence (for payment solutions)	DICT Advisory 2020-02
Proof of “Gaming Site” or “Data Centre” lease with redundancy	PAGCOR ICT Memo 2021-05
BIR tax clearance and LGU Mayor’s Permit	BIR Revenue Memo 064-2020

3.2 Due-Diligence Phases

Pre-Qualification – Screening of corporate & individual backgrounds (Interpol, World-Check).
Technical Due Diligence – Sand-box tests on RNG, live-dealer studios, wallet segregation.
Financial Evaluation – Minimum bankroll / irrevocable stand-by letter of credit.
Probity Hearing before PAGCOR’s Board-level Compliance and Governance Committee.
Provisional Licence (6 months) → Notice to Commence once systems go-live.
Regular Licence issued; renewable annually upon passing:
- Quarterly systems audit by Accredited Audit Platform Provider (AAPP).
- AML/CTF compliance rating by PAGCOR‐AMLD Unit & the Anti-Money Laundering Council (AMLC).

4. Player-Side Licence Verification

Check the PAGCOR seal. Legitimate sites display a circular badge bearing the “@PAGCOR” logo hyperlinked to https://games.pagcor.ph/{license-id}.
Confirm the Master License Number. Format: 20XX-XXX-GAME (e.g., 2024-015-PIGO).
Consult the Public Register. PAGCOR uploads monthly PDF lists of authorised operators on its website; they include suspended and cancelled licences.
Observe the URL. Domains must end in .ph, .com.ph or a registered international TLD explicitly notified to PAGCOR.
Ask for the Notice to Commence. Operators post a scanned copy of the Notice in their “About Us” section.
Cross-check payment channels. Legitimate local e-wallets (GCash, Maya) require a PAGCOR merchants’ agreement citing the licence number.

Warning: Many rogue sites copy PAGCOR seals. The hyperlink must redirect to PAGCOR servers—hover to inspect; mismatched redirects signal fraud.

5. Ongoing Compliance Obligations

Area	Core Rules	Supervisory Tests
Responsible Gaming	Self-exclusion programme, 21+ age gating (local), pop-up bet/time limits	PAGCOR Responsible Gaming Framework; audits include “mystery player” testing
AML/CTF	KYC at PHP 100,000 aggregate threshold; mandatory STR within 5 days	AMLC Thematic Review; integration with CAMS/GoAML
Tax	5 % franchise tax on GGR + 50 % net income remittance (for PAGCOR-operated egames)	BIR cross-match of GGR declarations vs PAGCOR audit trail
System Integrity	24/7 mirroring to PAGCOR Data Warehouse; logging retention 10 years	Surprise forensic pull by PAGCOR‐ICTD
Advertising	No local mass-media advertising for POGOs; PIGOs must display responsible gaming taglines	CAPO Circular 2022-01

6. Enforcement and Penalties

Violation	Statutory Basis	Sanction
Unlicensed online casino targeting Filipinos	Art. 151, PD 1869; RA 9487	Cease-and-desist, asset seizure, fine up to PHP 500 K per day, and/or imprisonment 6–12 years for officers
Failure to submit AML reports	RA 9160 as amended	Civil penalty up to PHP 500 K per violation; possible licence revocation
Allowing minors / self-excluded persons	PAGCOR MICS §8	PHP 100 K per incident; suspension on 3rd offence
Tax evasion	NIRC, Sec. 254	Surcharge, interest, criminal prosecution

PAGCOR coordinates raids with the National Bureau of Investigation (NBI), Philippine National Police – Anti-Cybercrime Group (PNP-ACG) and the Bureau of Immigration for alien deportation.

7. Interaction with Special Economic Zones

CEZA and AFAB may license i-gaming but only for offshore patrons. Accepting Philippine bets without a PAGCOR PIGO licence is ultra vires.
Dual Licensing is prohibited: an operator cannot simultaneously hold a PIGO and CEZA interactive licence under current PAGCOR guidelines.

8. Emerging Issues (as of Q2 2024)

Consolidation Bill. A Senate bill seeks to merge PAGCOR’s dual role (operator-regulator) into a single Philippine Gaming Authority; if passed, expect a revised verification portal.
Cryptocurrency Bets. PAGCOR currently disallows crypto-denominated wagering, but drafts of the 2024 Technical Standards include wallet-chain-analysis tools.
Cloud Hosting. DICT’s Cloud First Policy permits offshore hosting provided data centres are ISO 27001 certified and mirror logs to PAGCOR within Philippine territory.

9. Practical Checklist for Lawyers & Compliance Officers

Corporate Housekeeping – SEC GIS must mirror ultimate owners disclosed to PAGCOR.
Licence Display – Embed the dynamic PAGCOR badge in footer and cashier pages.
Audit Calendar – Schedule quarterly AAPP audits 15 days before PAGCOR deadline.
Player Verification – Integrate e-KYC (PhilSys, e-Gov app) to satisfy AML CDD.
Incident Response – Maintain a 72-hour breach notification protocol to NPC and PAGCOR.

10. Conclusion

PAGCOR’s licence-verification regime for online casinos is both statutory—anchored in PD 1869 and RA 9487—and technical, demanding real-time API integrations and regular third-party audits. Operators that display a verifiable licence badge, pass rigorous AML and systems testing, and adhere to responsible-gaming rules not only secure legal certainty but also reinforce player trust. Conversely, unlicensed operators face swift administrative and criminal sanctions. Continuous monitoring of legislative reforms, especially the proposed Gaming Authority bill, is essential to keep licence-verification processes up-to-date.

This article is for informational purposes and does not constitute legal advice. For specific situations, consult qualified Philippine counsel.