PAGCOR Casino License Requirements for Clark: A Regulatory Compliance Guide

The PAGCOR casino license requirements for Clark are governed by the Casino Regulatory Manual for Clark Special Economic Zone Licensees (Version 2.0), which must be read together with the licensee's Provisional License and Authority to Operate. The Manual sets out the regulatory standards a Clark licensee must meet across casino layout, gaming tables, electronic gaming machines, surveillance, and internal controls. Compliance is not a one-time filing: it is an ongoing condition of the license, enforced through the Manual and PAGCOR's Regulatory Framework for Offenses and Penalties (Licensed Land-Based Casinos).

What the Casino Regulatory Manual requires of Clark licensees

The Manual is the primary regulatory policy for Clark licensees. It covers casino layout, gaming tables, electronic gaming machines, peripheral gaming equipment, the Casino Management System, surveillance, gaming chips and plaques, playing cards, procurement, and operational rules.

It states that it shall be read in conjunction with and is intended to supplement the Provisional License and Authority to Operate. A licensee therefore cannot treat the Manual as a separate checklist; the license terms and the Manual operate together.

Casino layout and gaming capacity requirements

Before commencing operations, a licensee must comply with casino layout rules. Regulation 2 covers the maximum gaming area, designation of gaming areas, gaming mix ratios, and submission of a casino layout plan. Section 10 of Regulation 2 specifically addresses the minimum hotel room capacity required prior to issuance of the Notice to Commence Casino Operations, while Section 11 covers gaming capacity.

Any change to the casino layout requires PAGCOR approval. Breaching the approved gaming capacity for gaming tables is classified as a Moderate offense under the Regulatory Framework.

Gaming tables, EGMs, and equipment approvals

Regulation 3 governs gaming tables, including new or additional tables, relocation, mix ratios, table limits, and authorized casino table games. Regulation 4 governs electronic gaming machines, including the required ratio, technical standards, and minimum return-to-player percentage.

A recurring requirement across the Manual is prior PAGCOR approval. Under the Regulatory Framework, the following are Moderate offenses:

• Unauthorized installation and operation of gaming tables (CRM 3.3)
• Breach of the prescribed Table Games Mix Ratio (CRM 3.2)
• Unauthorized installation and operation of EGMs (CRM 4.2)
• Configuration of EGMs below or above the prescribed Return-to-Player percentage (CRM 4.3)
• Use of gaming equipment not approved by PAGCOR, or modified without approval (CRM 5.1 and CRM 5.2)

Surveillance, Casino Management System, and internal controls

Regulation 7 requires a surveillance plan for casino premises, subject to PAGCOR approval, with minimum requirements for coverage, recording, and records. Regulation 6 governs the Casino Management System, including pre-operational requirements.

The Regulatory Framework treats the following as Moderate offenses:

• Modifying the surveillance system or plan without prior PAGCOR approval (CRM 7.1)
• Unauthorized tampering with or compromise of the surveillance system or its recordings (CRM 7.2)
• Use of an unapproved Casino Management System, features, or unauthorized software changes (CRM 6.1)
• Circumvention of internal control procedures, such as cage, count, or drop box processes (CRM 14.1)

License fees, GGR reporting, and remittance

Regulations 22 to 24 cover the determination of Gross Gaming Revenue and PAGCOR license fees, and the collection and remittance of those fees. Misstatement, under-declaration, or falsification of GGR reports from table games or EGMs is classified as Moderate (CRM 21.1 and CRM 22.1).

Failure to remit the required license fee in full or in part within the prescribed period, without valid justification and despite notice or demand, is classified as a Major offense (GO 06).

How PAGCOR enforces compliance

The Regulatory Framework for Offenses and Penalties (Licensed Land-Based Casinos), effective August 13, 2025, classifies offenses as Minor, Moderate, or Major. Penalties escalate progressively: a first-instance Minor offense may draw a written warning or corrective action order, while a Major offense may result in license suspension or revocation.

Before a penalty is imposed, PAGCOR issues a Notice to Show Cause Order, and the licensee must submit a written Answer within ten (10) business days from receipt. Failure to answer is construed as a waiver of the right to be heard. A Motion for Reconsideration may be filed within fifteen (15) working days from receipt of the decision, and only one motion is allowed.

Frequently asked questions

What are the PAGCOR requirements for a casino license in Clark? A Clark licensee must comply with the Casino Regulatory Manual for Clark Special Economic Zone Licensees (Version 2.0), which covers casino layout, gaming tables, EGMs, surveillance, the Casino Management System, and operational rules, read together with the Provisional License and Authority to Operate.

Does a Clark casino need PAGCOR approval before changing its layout or equipment? Yes. Changes to casino layout, gaming tables, EGMs, and the surveillance plan require prior PAGCOR approval. Unauthorized changes are classified as Moderate offenses under the Regulatory Framework.

What happens if a Clark licensee violates the Casino Regulatory Manual? PAGCOR may issue a Notice to Show Cause Order. The licensee must answer within ten business days. Penalties range from a written warning or corrective action order for Minor offenses to license suspension or revocation for Major offenses.

Practical takeaways

• Treat the Casino Regulatory Manual as a supplement to the Provisional License and Authority to Operate, not a standalone document.
• Secure prior PAGCOR approval before any change to casino layout, gaming tables, EGMs, or the surveillance plan.
• Maintain accurate GGR reporting and remit license fees on time; non-remittance is a Major offense.
• Respond to any Notice to Show Cause within ten business days to avoid waiving the right to be heard.
• Remember that a Motion for Reconsideration must be filed within fifteen working days and only one is allowed.

Primary sources

The rules discussed above are drawn from the following PAGCOR issuances, embedded here in full for your reference.

Casino Regulatory Manual for Clark Licensees Version 2.0Open in Law LibraryDownload PDF

Regulatory Framework for Offenses and Penalties for Licensed Land-Based CasinosOpen in Law LibraryDownload PDF

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.