PAGCOR B2B framework opens new route for foreign iGaming firms
Foreign game studios and aggregators seeking entry into the Philippine iGaming market will need to turn to exclusive distributorship arrangements following the rollout of a new regulatory framework by the Philippine Amusement and Gaming Corporation (PAGCOR), according to legal advisory firm Arden Consult.
Last year, the gaming regulator introduced its “Regulatory Framework for the Accreditation of Gaming Affiliates and Support Service Providers.” Arden Consult described this framework as the first comprehensive accreditation regime covering all B2B service providers in the Philippine iGaming sector.
Under the framework, no Game Content Provider (GCP), Game Aggregator or Gaming Affiliate may legally provide games to PAGCOR-licensed operators or accredited Gaming System Administrators (GSAs) without securing PAGCOR accreditation.
Exclusive distributorship gains attention
The legal advisory firm said that PAGCOR’s framework allows foreign gaming affiliates to appoint a Philippine-registered and PAGCOR-accredited entity as their Exclusive Distributor (ED). Under this arrangement, the exclusive distributor becomes the accredited party recognised by PAGCOR and handles regulatory obligations on behalf of the foreign provider.
“The ED holds the PAGCOR accreditation and serves as the party of record before the regulator,” Arden Consult explained.
The distributor is also responsible for compliance management, game approvals, regulatory correspondence and maintaining the required Performance Cash Deposit. PAGCOR rules also limit each exclusive distributor to representing a maximum of five foreign gaming affiliates. The arrangement ends automatically if the foreign company later obtains its own PAGCOR accreditation.
According to Arden Consult, the structure provides foreign providers with a quicker and potentially less costly market-entry option.
“The exclusive distributorship model is not merely a regulatory workaround. It is a structured, PAGCOR-sanctioned market-entry vehicle,” the firm stated.
Regulatory and legal considerations remain
Despite its advantages, the legal advisory firm warned that exclusive distributorship agreements require careful structuring to avoid regulatory and commercial risks.
Arden Consult highlighted competition law concerns under the Philippine Competition Act, noting that exclusive arrangements are subject to “rule of reason” analysis under Republic Act No. 10667.
The advisory also pointed to PAGCOR’s recent amendment prohibiting GSAs from acting as exclusive distributors after reports of anti-competitive practices. The firm added that other areas requiring attention include intellectual property licensing, commercial terms, tax considerations, and dispute resolution mechanisms.
“Every exclusive distributorship agreement is unique,” Arden Consult said. “There is no one-size-fits-all template.”
Online gaming drives Philippine market growth
The increasing interest from foreign B2B gaming suppliers comes as online gaming becomes the dominant force in the Philippine gaming industry.
According to the latest PAGCOR data, the country’s gaming industry generated gross gaming revenues (GGR) of PHP396.14 billion ($6.6 billion) in 2025, representing a 6.39 per cent increase from PHP372.33 billion ($6.2 billion) in 2024. The strongest growth came from electronic and online gaming operations, which generated PHP201.12 billion ($3.4 billion), up 30.04 per cent year-on-year.
The figures marked a major shift in the Philippine gaming sector, where land-based casinos historically dominated industry revenues.
Licensed casinos recorded PHP182.50 billion ($3 billion) in revenue in 2025, down 9.58 per cent from the previous year. PAGCOR-operated casinos posted a sharper 20.95 per cent decline to PHP12.52 billion ($208.7 million).
“The increase in electronic gaming revenues shows how the industry has evolved,” Alejandro Tengco, PAGCOR Chairman, said. “Online gaming is no longer a supplementary segment but has now become the leading driver of overall GGR growth.”
Market momentum continues despite external pressures
PAGCOR also earlier warned that broader geopolitical and economic challenges continue to affect the global gaming industry.
“This is not a good time for everyone,” Tengco said in an earlier statement. “Gaming jurisdictions globally are feeling the impact of the oil crisis, and even more progressive countries like Singapore, Macau, and the United States are not spared.”
Tengco said that higher fuel costs and weaker travel flows have increased operating expenses for integrated resorts and affected consumer spending in land-based gaming markets. “These external pressures are affecting not only gaming operators but also the local gaming industry stakeholders,” he added.
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