The Philippine blockchain market is experiencing rapid adoption, transitioning from early-stage crypto speculation to practical, real-world financial utility. The Philippines ranks among the top global markets in grassroots cryptocurrency adoption (ranking 9th globally in Chainalysis’ 2025 Global Crypto Adoption Index).

Key sectors adopting Distributed Ledger Technology (DLT) and blockchain include:

• Remittances & Cross-Border Payments: Major players, e-wallets, and non-bank entities leverage stablecoins and crypto infrastructure to facilitate cross-border money transfers, reduce settlement friction, and enable remote workers to receive stablecoin salaries directly converted into local bank accounts and e-wallet accounts.
• Banking & Digital Financial Services: Licensed Virtual Asset Service Providers (VASPs) including traditional banks (e.g., UnionBank) and digital banks (e.g., GoTyme Bank) integrate crypto and asset tokenization features into their platforms.
• Public Sector & Government Services: The Philippine national government has implemented blockchain initiatives, such as hosting the entire national budget tracking on BayaniChain, a blockchain-based platform designed to foster institutional transparency and operational efficiency.
• Retail Payments & Micro-Transactions: Merchants and payment platforms use DLT/crypto rails for daily expense settlements, merchant acquisitions, and integration into e-wallets.

While there is no single umbrella “Blockchain Act,” several sectoral statutes, administrative rules, and regulatory frameworks govern application of blockchain technology, crypto assets, and DLT operations in the Philippines:

Primary Regulators

1. Bangko Sentral ng Pilipinas (BSP): Regulates Virtual Asset Service Providers (VASPs), Electronic Money Issuers (EMIs), Operators of Payment Systems (OPS), and BSP Supervised Financial Institutions IT risk management framework and cybersecurity.
2. Securities and Exchange Commission (SEC): Regulates crypto-asset service providers, crpyto assets, crypto asset securities, online trading platforms, and crowdfunding.
3. Insurance Commission (IC): Oversees Insurtech platforms and DLT/blockchain initiatives within insurance products under sandbox frameworks.

Key Regulatory Frameworks & Legislation

• SEC Memorandum Circular (MC) No. 04, Series of 2025 (SEC Rules on Crypto-Asset Service Providers) (CASP Rules) and MC No. 05, Series of 2025 (Guidelines on the Operations of Crypto-Asset Service Providers) (CASP Guidelines) regulate entities providing crypto asset services, offering crypto-asset securities, and marketing third parties.
• BSP Circular No. 1108 (2021): Guidelines for Virtual Asset Service Providers (VASP)
• BSP Travel Rule: BSP Memorandum No. M-2023-042 requires all VASPs (including non-custodial ones) to perform due diligence and screen all transacting parties against terrorism and proliferation financing lists under the Philippine Travel Rule.
• Regulatory Sandbox Frameworks: Institutionalized via BSP Circular No. 1153, SEC MC No. 9, Series of 2024 (via the PhiliFinTech Innovation Office or PhiliFINNO), and IC Circular Letter No. 2020-73 to test innovative DLT and fintech applications.
• Anti-Financial Account Scamming Act (AFASA – R.A. No. 12010): Criminalizes money muling and social engineering schemes involving financial accounts and mandates real-time automated monitoring systems.
• Data Privacy Act of 2012 (R.A. No. 10173) & Cybercrime Prevention Act (R.A. No. 10175): Applies to DLT nodes, data storage, and network architecture operating within the jurisdiction.

Philippine regulators maintain a receptive, progressive, yet risk-averse and consumer-protection-oriented stance toward blockchain technology.

Regulators actively support DLT through sandbox frameworks (BSP, SEC, IC) and national initiatives like the Innovative Startup Act (R.A. 11337) and the Konektadong Pinoy Act. The government itself utilizes blockchain technology (e.g., BayaniChain for budget tracking).

While welcoming blockchain innovation, regulators strictly enforce licensing rules against unauthorized platforms. The SEC and National Telecommunications Commission (NTC) actively issue advisories and block unauthorized/unlicensed crypto platforms (e.g., Binance, eToro) that solicit investments from Philippine residents without secondary licenses.

The Bangko Sentral ng Pilipinas (BSP) launched Project CBDCPh (rebranded later as Project Agila), focusing primarily on a wholesale Central Bank Digital Currency (wCBDC). The BSP prioritized wholesale CBDC applications (targeting cross-border payments, interbank settlements, and liquidity management) over retail CBDCs, given that existing e-money systems (like GCash, Maya) and real-time retail rails (InstaPay and PESONet) already adequately serve retail digital payment needs.

While the BSP has seen the potential of CBDC for liquidity management, among others,  it also recognizes the need for refinements in legal, supervisory, and regulatory frameworks, and more importantly, the interoperability of wCBDC with existing and prospective financial market infrastructures and international payment networks.

Crypto assets are categorized based on their functional characteristics (i) Virtual Assets (VAs): Digital representations of value that can be digitally traded or transferred; entities providing VA transfers/exchanges are regulated as VASPs under BSP supervision. (ii) Crypto-Asset Securities: Under SEC MC No. 04 and MC No. 05, any cryptographically secured representation of value/rights offered as a security under the Securities Regulation Code (SRC) is subject to full SEC registration, secondary licensing, and compliance obligations. For crypto asset that are not securities, the filing of disclosure statement will suffice but without prejudice to the offeror’s compliance with anti-money laundering law (AML).

The Philippines does not presently have a standalone regulatory regime or statutory definition specifically governing DeFi. Instead, Philippine regulation is largely activity-and intermediary-based: the BSP and SEC regulate particular virtual asset / crypto-asset services, securities activities, and financial intermediation, rather than DeFi as a distinct legal category. Hence, genuinely decentralized protocols are not automatically regulated simply because they are DeFi, but the people or entities performing regulated activities around them may be.

Both BSP-regulated VASPs and SEC-regulated crypto-asset service provider (CASPs) are subject to the Philippine AML/CFT framework. CASPs are expressly designated as ‘covered persons’ under Section 8.1 of the SEC’s CASP Rules. VASPs, meanwhile, are subject to AML/CFT obligations through the BSP’s VASP regulatory framework and the AMLA’s covered-person framework applicable to BSP-regulated entities

The Philippines does not currently have a comprehensive crypto-asset or DeFi-specific tax regime. Instead, crypto-asset and DeFi-related income is generally analyzed under the National Internal Revenue Code (NIRC) and applicable BIR issuances. Under the NIRC’s general income-tax principles, realized gains and other economic benefits derived from crypto-asset activities may be subject to income tax depending on the nature and characterization of the income and the status of the taxpayer. This may include income or rewards arising from activities such as crypto-asset trading, mining, staking, and play-to-earn activities, although the BIR has not, to date, established a comprehensive crypto-specific classification or tax treatment for each of these activities.

Philippine resident citizens are generally taxable on income from sources within and outside the Philippines. Accordingly, the use of an offshore crypto-asset exchange or DeFi protocol does not, by itself, remove otherwise taxable income from Philippine income taxation.

Separate BIR rules increasingly address digital services and e-commerce. RR No. 3-2025 implements the 12% VAT on digital services supplied or consumed in the Philippines, including certain services supplied by nonresident digital service providers.  In addition, RR No. 16-2023 imposes creditable withholding tax on specified gross remittances made by electronic marketplace operators and digital financial services providers to sellers/merchants. However, the possible application of these issuances to a DeFi protocol would still depend on whether the relevant activity and entity fall within the definitions and conditions of the applicable tax rules.

Industry estimates project the Philippine tokenized-asset market could reach approximately US$60 billion by 2030

Wholesale Tokenisation: The government has successfully piloted tokenized treasury bonds (e.g., Bureau of the Treasury’s tokenized bond issuances using DLT) to optimize settlement efficiency and possibly broaden financial inclusion.

Retail Tokenisation: Retail tokenization (such as fractionalized real estate, tokenized equities, or debt instruments) may fall under the jurisdiction of the SEC. Where a tokenized asset constitutes a security or the relevant activity constitutes a regulated crypto-asset service, existing securities and crypto-asset regulations may apply, including the Securities Regulation Code and, where applicable, the SEC’s CASP Rules and Guidelines. The regulatory treatment depends on the legal nature of the underlying asset, the rights attached to the token, the offering structure, and the activities performed by the relevant intermediary.

The use or trading of crypto assets per se is not prohibited. However, there are activities, including the public offering of crypto assets, that if undertaken by a crypto-asset service provider (CASP), will trigger regulatory requirements. As a general rule, the sale, offer for sale, or distribution of crypto assets in the Philippines is allowed only after complying with the requirements of the SEC’s CASP Rules and CASP Guidelines. Among them are (i) the requirement that the offeror must file with the SEC (and publish on the platform’s website, social media account, and other means of communication) a “disclosure document relative to a Crypto-asset to be offered in the Philippines” and (ii) need to secure a CASP license. Apart from public offering of crypto-asset, operating a crypto-asset trading venue, and providing crypto-asset intermediation activities (e.g., advising, dealing services, order execution, and order transmission) makes one a crypto asset service provider and must therefore secure registration as such with the SEC. Unlicensed platforms providing these services in the Philippines may face domain blocking by the National Telecommunications Commission (NTC) and the SEC.

However, if the crypto assets are being offered for purposes other than as a financial product, as defined under R.A. No. 11765 or the Financial Products and Services Consumer Protection Act, then the rule requiring the filing of a disclosure document need not be complied with. An example of a situation falling under the exception is when the crypto-asset holder may only use it in exchange for goods and services in a limited network of merchants with contractual arrangements with the offeror.

Crypto trading and utility usage are highly common. As of late 2025/2026, 10 active VASPs operate legally in the country (e.g., Coins.ph, Maya, PDAX, UnionBank, GoTyme Bank), serving millions of retail users for remittances, payroll, micro-payments, and investment.

Around 2017, numerous ICOs have been launched which prompted the SEC in January 2018 to make its first official pronouncement on ICO in relation to virtual currencies. According to SEC, an ICO is the first sale and issuance of a new virtual currency to the public usually for the purpose of raising capital for start-up companies  or funding  independent  projects. The SEC warned that some of these new virtual currencies, based on the facts and circumstances surrounding their issuance, could be a security, particularly in the form of an investment contract. As a security, activities relating to the ICO trigger the registration requirements under the Securities and Regulation Code. Whereas the country’s central bank (Bangko Sentral ng Pilipinas) looks at virtual currencies (now termed virtual assets) in how they impact the delivery of financial services, the SEC looks at ICOs as another means to raise capital for start-ups and increase the public’s participation in capital markets.

On 2 August 2018, the SEC issued the draft Rules on ICO and requested public comment thereon. On 27 December 2018, again the SEC issued the draft rules (with revisions) for another round of request for comments. Nothing was heard from the SEC regarding the draft ICO rules since. To the extent that an ICO amounts to the public offering of crypto-assets or crypto-asset securities, then the SEC’s CASP Rules (MC No. 4) and CASP Guidelines (MC No. 5) will apply.

On transfer of title: The general law governing ownership, rights over, and transfer of personal property is the Civil Code of the Philippines (Civil Code). It defines what constitutes movable or personal property and sets out the legal modes by which ownership may be acquired or transferred, such as occupation, donation, sale, succession, and delivery. There is also the Personal Property Security Act (PPSA) which regulates the legal framework for security interests in personal property. It governs the creation, perfection, priority, and enforcement of security interests over movable property used as collateral for an obligation. None of these laws however have contemplated of crypto-assets.

Since the CASP Rules define crypto-asset as “cryptographically secured digital representation of value or of a right that relies on a cryptographically secured distributed ledger or a similar technology to validate and secure transactions that can be transferred, stored, or traded electronically” in practice, the closest equivalent of having “legal title” of crypto-assets is having knowledge and custody of the private keys over the crypto assets which confers full control over such assets. However, whether such full control over the crypto-asset can be given full effect of having legal title or ownership may also depend on some other underlying transaction, contract, or relationship with or involving another party or parties.

On granting of security: Under the Civil Code all things which may be appropriated are considered either as immovable (or real property), or movable (or personal property). One type of personal property are those movables susceptible of appropriation which are not enumerated as a real property. The Civil Code also recognizes some intangibles (Article 417 par 1) as personal property. Since crypto assets are not among those enumerated as real property and is susceptible of appropriation (primarily manifested through one’s ability to authorize transactions using the relevant cryptographic credentials), then crypto assets are arguably personal property even if it is technically intangible.

As a personal property, a security interest may be created over it as a collateral to secure an obligation under the PPSA which applies to “all transactions of any form that secure an obligation with movable collateral.” A security interest is defined as “a property right in collateral that secures payment or other performance of an obligation… regardless of the type of asset….” The last clause may be broad enough to include crypto assets.

Under the PPSA a security interest may be perfected (i.e., it is created and is binding on 3rd persons) in three ways: (i) registration of a notice with the Personal Property Security Registry; (ii) possession of the collateral; and (iii) control of investment property and deposit accounts. Interestingly, the CASP Rules expressly characterizes crypto-assets “as financial products defined under Section 3(c) of the [Financial Products and Services Consumer Protection Act], specifically investments.” While registration is one way, if the crypto-asset remains within the control of the grantor of the security interest even after default, there may be issues on enforcement of that security interest in the future. Hence, properly structured contractual stipulations and mechanisms are key.

There is no Philippine law or regulation defining smart contracts. However, the Philippine SEC has used the term “smart contract” descriptively, particularly in its enforcement/advisory materials concerning blockchain-related schemes. The Bangko Sentral ng Pilipinas[1] on the other hand has used the definition of the U.S. Department of Commerce National Institute of Standards and Technology (NIST) in defining a smart contract – as a “collection of code and data (sometimes referred to as functions and state) that is deployed using cryptographically signed transactions on the blockchain network. The smart contract is executed by nodes within the blockchain network; all nodes must derive the same results for the execution, and the results of execution are recorded on the blockchain” – in the context of explaining the potential benefits of having a Central Bank Digital Currency in this jurisdiction.

There may be enforceability issues in smart contracts. Since smart contracts are code-dependent, where the code conflicts with the parties’ natural-language agreement, the question of which would legally prevail might arise. Another possible issue is whether an automatically executed transaction remains legally binding where the execution results in an outcome that is legally inconsistent with the parties’ (traditional) contractual rights. Another legal issue concerns the allocation of responsibility when a smart contract relies on an external oracle to determine whether contractual conditions have been satisfied. Where the oracle’s data is erroneous or manipulated, it may be unclear whether the resulting automated execution should be treated as valid contractual performance and who should bear the resulting loss.

[1] Central Bank Digital Currency for the BSP Fundamentals and Strategies

Philippine law does not currently confer legal personality upon an un-incorporated DAO. Under the Revised Corporation Code (R.A. No. 11232), legal entity status requires formal registration with the SEC.  Without formal SEC incorporation or partnership registration, a DAO operating within the Philippines risks being classified as an unregistered general partnership or an unincorporated association. Consequently, individual members, token holders, or core developers could face joint and several personal liability for obligations, debts, or regulatory infractions committed by the DAO.

The foregoing notwithstanding, the country’s Cagayan Economic Zone Authority (CEZA) announced in 2023 the launch of a DAO registry. A year later, the CEZA issued the Offshore Financial Technology Licensing Rules and Regulations, whose objective is to “provide a lawful basis for registration and control of Offshore Financial Technology business-related activities.” Hence if the DAO’s activities fall under the regulated Offshore Financial Technology Business Activity and it chooses to avail of the benefits and incentives of establishing presence within the economic zone, DAO registration may be explored. However, where the DAO registry precisely fits within the OFTLRR remain unclear.

Yes. The Philippine SEC has taken regulatory and enforcement actions against activities involving blockchain technology, particularly online schemes that use blockchain or crypto-assets as part of their business or investment model. These schemes have typically promised high returns, commissions, or other financial rewards, and the SEC has treated the offer or sale of securities—particularly investment contracts—as unlawful where the securities are unregistered and/or the persons or entities offering them lack the requisite registration or license.

In some cases, the SEC has gone beyond issuing public advisories and has issued Cease and Desist Orders, as in the case of Forsage. In other cases, it has coordinated with law-enforcement authorities in enforcement operations that resulted in the arrest of individuals, as in Decentra.

The SEC has also taken other regulatory measures. In the case of Binance, for example, the SEC in 2023 sought to have access to Binance’s websites blocked and subsequently coordinated with Google and Apple toward the removal of Binance applications from their Philippine app stores.

Yes. For instance, in response to a query from a national government agency, the National Privacy Commission has opined that the use of blockchain technology may present the issue of who the actual controllers are and of the manner of implementing the data subject rights to correction or erasure given the immutability of data once recorded on the blockchain. Hence, the NPC advised that the parties should structure their agreements clearly.

Apart from legal structure, technical structure may play a crucial role as well. For instance, blockchain itself is not necessarily incompatible with the DPA and the compatibility may depend on how the system is designed—for example, whether personal information is stored directly on-chain or whether the blockchain contains only hashes/pointers while the underlying personal data remains in an off-chain system.

Relatedly, the BSP (BSP— M-2026-023 June 5, 2026) has recently provided additional guidelines for VASPs in their listing of coins/tokens on their platform. Significantly, the BSP said that the offering of anonymity- enhancing VAs, otherwise known as privacy VAs, is prohibited from being listed/supported by VASPs.

On the other hand, R.A. No 10142 or the Financial Rehabilitation and Insolvency Act of 2010 provides the framework for rehabilitation or liquidation of financially distressed enterprises and individuals and addresses the debtor’s assets, creditor claims, secured and unsecured claims, and the administration and liquidation of the debtor’s estate. Should a VASP or CASP become insolvent, several questions may arise including the legal ownership of the virtual or crypto asset, or whether the crypto it ‘holds’ can be considered as part of its assets, or those of its customers, or that of a third party. Similarly, answers to these questions may also depend heavily on the technical architecture behind the blockchain as deployed and the legal arrangements governing the relationships of the parties involved.

A key issue legal practitioners should be aware of is the Philippine government’s increasing legislative and regulatory recognition of blockchain as an emerging technology and potential area of investment. Commercially, one specific law expressly mentions blockchain: the Freeport Area of Bataan (FAB) Act of 2009, as amended in 2019. Unlike CEZA, which had to rely on its broad regulatory and investment-promotion powers, the amended FAB Act expressly identifies blockchain as one of the “emerging and future technologies” that the FAB may tap as an area of investment and economic activity. This reflects legislative recognition, as early as 2019, that blockchain is a technology capable of forming part of a broader investment and development ecosystem.

Legal counsel should also note that the BSP has extended indefinitely the moratorium on the issuance of new VASP licenses, subject to reassessment based on global and local developments. Existing BSP-supervised financial institutions (BSFIs) may continue to apply to offer VASP services, subject to applicable licensing and supervisory requirements. Accordingly, expanding operations via existing licensed BSFIs or acquiring/partnering with licensed entities remains the primary market entry path.