Introduction
I attended SBC Summit in Lisbon this year, held from 29 September to 1 October, intending to talk about the Philippines. Most delegates wanted to talk about Brazil. Four days before the conference opened, Brazilian President Luiz Inácio Lula da Silva signed Provisional Measure No. 1.394, which banned fixed-odds sports betting and online casino games with immediate effect (Agência Brasil, 2026). Many of my conversations at the conference turned to why a country would license 85 operators and then close the market less than two years later (Mazza, 2026b; NBC News, 2026).
It was a fair question, and a little over a year ago it could have been asked of the Philippines.
In mid-2025, the Philippine Senate came close to prohibiting online gambling. This article looks at what the Philippines did instead, the reforms PAGCOR has introduced since, and what remains to be done, in particular the need for a clearer legal framework. I refer to India and Brazil only briefly, and only to what has been publicly reported.
The 2025 Proposals to Ban Online Gaming
Gaming in the Philippines is regulated by the Philippine Amusement and Gaming Corporation (PAGCOR), a government-owned corporation. PAGCOR licenses land-based casinos, including the integrated resorts in Entertainment City, Manila, as well as electronic and online gaming offered to players in the Philippines. Offshore gaming, which served players outside the country, was governed by a separate regime. It was shut down by executive order in 2024 and prohibited by law in October 2025.
The controversy over offshore gaming soon extended to domestic online gaming. By mid-2025, Senate hearings had turned to testimony on household debt, addiction and minors using gaming apps. Several senators filed bills seeking a total ban. These included Senate Bill No. 47, the Anti-Online Gambling Act, authored by the Senate Majority Leader (Philippine News Agency, 2025), and Senate Bill No. 686, which proposed prison terms (GGRAsia, 2025). At least one pending bill would have penalised anyone who placed a bet online. The Bangko Sentral ng Pilipinas (BSP), the Philippine central bank, ordered e-wallets to remove their links to gaming platforms (Philippine News Agency, 2025). For a time, a ban appeared likely.
In the end, the Philippine President did not call for a ban. PAGCOR, under Chairman Alejandro Tengco, took the position that stricter regulation, rather than prohibition, was the answer, and introduced measures to support that position. It required a full know-your-customer (KYC) verification before a player could fund an account, set the minimum playing age at 21, removed gambling advertisements from billboards and primetime broadcast, required self-exclusion tools, and accredited treatment centres for problem gamblers (Philippine News Agency, 2026). In March 2026, the Senate and PAGCOR began drafting a comprehensive regulatory bill (BusinessMirror, 2026). The discussion in Congress is now about how online gaming should be regulated.
We set out our views on this in July 2025, in Why Smart Regulation, Not Prohibition, Is the Path Forward for Online Gaming in the Philippines (Arden Consult, 2025). Our position was that a ban would not reduce demand and would only remove supervision. In 2025, PAGCOR estimated that most Filipino online players were already using illegal sites. The aim should be to move these players to licensed platforms, a process the industry calls channelisation. A ban would have had the opposite effect.
India and Brazil
I do not practise in India or Brazil and leave the analysis of their laws to lawyers in those jurisdictions. However, the reported outcomes in both countries are relevant to the Philippine debate.
India passed the Promotion and Regulation of Online Gaming Act in August 2025, prohibiting online money games. By March 2026, the government reported having blocked more than 8,300 gambling and betting sites (Parameter, 2026). The Advertising Standards Council of India reported that offshore betting advertisements increased after the Act (AGBrief, 2026). India’s Enforcement Directorate has described offshore operators collecting deposits from Indian players through thousands of mule bank accounts (Directorate of Enforcement, 2025).
Brazil opened a licensed online market on 1 January 2025 and suspended it by Provisional Measure No. 1.394 on 25 September 2026, pending conversion into law by Congress. Licensed operators were required to take their sites offline by 6 October (Agência Brasil, 2026), and their licences were revoked on 25 October 2026 (Mazza, 2026b). Monitoring data reported in the trade press showed more than 400 new illegal betting sites appearing within two days of the announcement (Mazza, 2026a).
In both countries, the reports indicate that players moved to unlicensed operators rather than stopped playing. This is the outcome the Philippines avoided.
PAGCOR’s Regulatory Reforms
PAGCOR has focused on raising the standards for holding a licence and on closing gaps in the licensed market. Since 1 March 2024, new applications for accreditation as a Gaming System Administrator (GSA), the licence category for online gaming platforms, have been on hold while PAGCOR reviews existing licensees. Suppliers to licensees must now be accredited under a business-to-business (B2B) framework. Distributor and reseller arrangements must be declared to PAGCOR, and undeclared agreements are void. Owners and key officers are subject to probity and fit-and-proper checks, and rebates and cashback offers are capped.
The KYC, age, advertising and self-exclusion rules described above now apply across licensed platforms. PAGCOR has also reduced the licence fees it charges electronic gaming operators from more than half of gross gaming revenue to 30 percent, and to 25 percent for the online platforms of integrated resorts (Inside Asian Gaming, 2026). This allows licensed operators to remain competitive while meeting the cost of compliance.
Other government agencies have supported these efforts. The Department of Information and Communications Technology (DICT) has taken down thousands of unauthorised gaming sites identified by PAGCOR (Philippine Daily Inquirer, 2025), and the BSP has required regulated payment providers to stop gaming transactions they cannot account for. PAGCOR has also begun separating its role as regulator from its role as casino operator, a dual role that has long drawn criticism of the Philippine model.
In the short term, the licensed market has become smaller, and gaming revenue contracted in early 2026 as the new rules took effect (Inside Asian Gaming, 2026). A smaller market of supervised operators is preferable to a larger market that could have been prohibited outright.
The Need for a Clearer Legal Framework
The Philippines is a developing country and an emerging market. Illegal sites continue to target Filipino players, enforcement resources are limited, and online gaming remains politically sensitive. The reforms of the past year are significant, but they can still be reversed.
The most important gap is the absence of a statute on online gaming. The current framework rests largely on PAGCOR’s charter, Presidential Decree No. 1869 as amended by Republic Act No. 9487, and on PAGCOR’s own issuances. These issuances have improved the market, but they can be revised, deferred or challenged, and the charter was not written with online gaming in mind. A statute should set out which online activities may be licensed and by whom, the criteria for a licence, and the basis for fees and taxes. It should also define offences that cover not only illegal operators but also those who knowingly process payments for them, advertise them or recruit players for them.
The same law should give the regulator clear enforcement powers, including the power to order the blocking of illegal sites, to direct banks and e-wallets to stop processing illegal gaming payments, and to work with the Anti-Money Laundering Council on tracing funds. Website blocking alone has limited effect, as illegal operators can move to new domains. Payment channels are harder for them to replace.
Rule-making should also be predictable. Licensees can comply with strict rules, but rules that change without consultation or take effect without transition periods are difficult to implement. Published timelines, consultation drafts and a consistent fee policy would support channelisation.
Finally, PAGCOR should collect and publish data on gambling harm, including self-exclusion numbers, helpline use and the share of play on licensed platforms. Future policy decisions on online gaming should be based on that data.
Conclusion
A ban can be announced quickly. Regulation takes longer and requires continuing engagement between government and industry. The Philippines chose regulation, and PAGCOR has implemented that choice despite considerable political pressure. What is needed now is a law that puts the framework on a firm legal footing, keeps the licensed market competitive, and gives the regulator the enforcement powers it needs. If Congress passes such a law, the Philippines can serve as a model for other emerging markets in the region. I hope that at next year’s SBC Summit, more delegates will want to talk about the Philippines.