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More than 60% of licensed Philippine online gaming system administrators were operating below the country’s new minimum revenue benchmarks based on 2Q run rates, according to Arden Consult. The legal and regulatory advisory firm said the minimum guaranteed fee introduced by the Philippine Amusement and Gaming Corp. could speed up consolidation among smaller operators.
Arden Consult estimated Philippine online gross gaming revenue at approximately $1.19 billion in the first half of 2026, down 31% year-on-year. The firm described the fee structure as a market selection mechanism rather than only an additional cost.
Monthly Fee Rules Take Effect
The first phase of PAGCOR’s MGF regime began on July 1 and will remain in effect until the end of 2026. A gaming system administrator offering electronic casino games must pay the higher of PAGCOR’s percentage-based regulatory fee or PHP9 million, or $147,000, per month, based on a monthly GGR benchmark of PHP30 million, or $489,000.
GSAs without electronic casino games must pay a PHP3 million, or $49,000, monthly minimum if they meet the PHP15 million, or $245,000, revenue benchmark. The fixed fee floor applies even when an operator’s actual revenue is below the relevant benchmark.
The requirements will increase again on January 1, 2027. For electronic casino operators, the benchmark will rise to PHP35 million, or $571,000, and the monthly MGF will be PHP10.5 million, or $171,000. For GSAs without electronic casino games, the benchmark will rise to PHP20 million, or $326,000, and the minimum fee will be PHP4 million, or $65,000.
Pressure Builds on Smaller Operators
Arden Consult founder and CEO Marie Antonette “Tonet” Quiogue said the MGF was part of a regulatory cleanup. She said weaker or non-operational accreditation holders would need to recapitalize, consolidate, pursue an approved transaction, or leave the market.
The fixed fee raises the cost of retaining dormant or underperforming accreditation. Arden Consult said this could lead to consolidation as smaller operators reassess whether they can continue.
Quiogue said the Philippine market was not becoming less relevant to foreign capital, but was becoming more selective about the capital it accepts.
Existing Accreditations Offered at Premium
The new fee regime comes as investors and intermediaries increasingly seek entry into the regulated Philippine online gaming market. Arden Consult said existing accreditations were being offered at prices ranging from $3 million to as much as $15 million.
The prices reflect scarcity created by PAGCOR’s moratorium on new GSA applications. New applications have been held in abeyance since March 2024, meaning foreign investors seeking direct exposure generally need to invest in, acquire, or make a commercial arrangement with an existing accredited operator.
However, an accreditation cannot be purchased separately from the company that holds it. A GSA Certificate of Accreditation is a non-transferable privilege issued to a specific corporation or legal entity.
Approval Required for Ownership Changes
Any acquisition, share subscription, merger, or change in ownership, beneficial ownership, or control requires prior PAGCOR Board approval and a full probity review. Arden Consult warned that offers involving dormant companies, URLs, or financing structures could be viewed as undisclosed control transfers, unauthorized sublicensing, or attempts to evade the moratorium.
The firm said the ownership, control, and operating arrangements presented to PAGCOR must reflect how the business will actually function. Buying an accredited company can also mean taking on its regulatory and financial history, including possible unpaid fees, performance-deposit deductions, player balances, tax exposure, AML findings, unapproved brands, and contracts with unaccredited providers.
Market Entry Remains Uncertain
Arden Consult said investors should consider whether waiting could be cleaner than paying a scarcity premium for an existing operator and its historical liabilities. PAGCOR has not indicated when, or whether, it will reopen GSA applications.
The firm said the current scarcity may be temporary. The MGF’s effect on consolidation and PAGCOR’s review of the existing roster remain factors for investors.
Source: Asia Gaming Brief
