Entertainment City Casino License: PAGCOR Requirements and Rules

Operating a casino in Entertainment City requires a Provisional License and Authority to Operate from the Philippine Amusement and Gaming Corporation (PAGCOR), read together with PAGCOR's Casino Regulatory Manual for Entertainment City Licensees. The Manual does not stand alone: it "shall be read in conjunction with and is intended to supplement the Provisional License and Authority to Operate." In practice, the license is the starting point, and the Manual supplies the operating standards — casino layout, gaming tables, electronic gaming machines, surveillance, chips, playing cards, and reporting — that a licensee must meet on an ongoing basis.

What PAGCOR requires before casino operations begin

PAGCOR's regulatory role is set out in the Manual's Foreword. The regulator aims to ensure a level playing field among industry proponents, maintain an orderly and predictable regulatory environment, enforce license terms and conditions, promote fairness and integrity in the conduct of games, provide a platform for responsible gambling, disallow access to gaming venues by minors and financially vulnerable persons, and prevent licensed gaming venues from being used for illegal activities.

Those objectives translate into concrete pre-operational requirements. Before a Notice to Commence Casino Operations issues, the Manual requires a minimum hotel room capacity (Regulation 2, Section 10) and compliance with gaming capacity rules (Regulation 2, Section 11). The casino layout plan must be submitted to PAGCOR for approval, and any change to an approved layout requires PAGCOR's approval as well.

The core compliance areas under the Casino Regulatory Manual

The Manual is organized into numbered Regulations. For a new Entertainment City licensee, the practical build-out checklist covers:

• Casino layout and gaming capacity — maximum gaming area, designation of gaming areas, gaming mix ratios, and an unobstructed gaming area (Regulation 2).
• Gaming tables — approval of new or additional tables, table mix ratios, table limits, authorized table games, and PAGCOR-approved table layouts (Regulation 3).
• Electronic gaming machines — machine ratios, technical standards, minimum return-to-player percentage, and approval of modifications (Regulation 4).
• Peripheral gaming equipment — card shoes, electronic shufflers, dice, money wheels, and roulette wheels (Regulation 5).
• Casino Management System — components, pre-operational requirements, version upgrades, and remote access controls (Regulation 6).
• Surveillance — a Surveillance Plan for casino premises, minimum coverage requirements, and a surveillance monitoring and control room (Regulation 7).
• Gaming chips, plaques, and playing cards — approval, specifications, inventory, and storage (Regulations 8 and 9).
• Procurement and supplier accreditation — general guidelines, foreign procurement, local purchase, and accreditation of suppliers of gaming equipment and paraphernalia (Regulations 10 and 11).

Casino Operational Rules and Guidelines

A licensee cannot simply adopt its own house rules. Regulation 14 requires the formulation and submission of Casino Operational Rules and Guidelines (CORG), and casino operations must be consistent with the approved CORG. Deviations from the approved CORG or related control procedures are treated as regulatory offenses.

Ongoing obligations: fees, reporting, and PAGCOR monitoring

Once operating, the licensee must comply with PAGCOR's revenue and reporting framework. Regulation 22 governs the determination of Gross Gaming Revenue and PAGCOR license fees for gaming tables, while Regulation 23 covers the same for electronic gaming machines. Regulation 24 governs the collection and remittance of PAGCOR license fees.

PAGCOR supervises compliance through the PAGCOR Monitoring Team, whose functions, access rights, and records requirements are set out in Regulation 30. The Manual also addresses patron disputes (Regulation 25), prescribed offenses (Regulation 26), disciplinary proceedings (Regulation 27), responsible gaming (Regulation 28), and the Gaming Employment License (Regulation 29).

What happens if a licensee violates the rules

PAGCOR's Regulatory Framework for Offenses and Penalties (Licensed Land-Based Casinos), effective August 13, 2025, classifies violations as Minor, Moderate, or Major and applies progressive discipline.

Minor offenses carry a Written Warning or Corrective Action Order for a first instance, a monetary penalty for a second instance, and a higher monetary penalty for a third. Moderate offenses carry monetary penalties that escalate per instance, with a Corrective Action Order as an accessory penalty. Major offenses may result in license suspension or revocation.

The framework also sets out the procedure: an Evaluation Committee conducts an initial evaluation within ten (10) business days, and where warranted issues a Notice to Show Cause Order. The licensee submits a written Answer within ten (10) business days from receipt. A decision issues within ninety (90) calendar days from receipt of the Answer or the lapse of the period to submit. A Motion for Reconsideration may be filed within fifteen (15) working days from receipt of the decision, with only one MR entertained.

Frequently asked questions

What license do I need to operate a casino in Entertainment City? A Provisional License and Authority to Operate from PAGCOR. The Casino Regulatory Manual for Entertainment City Licensees supplements that license and sets the operating standards.

Is the Casino Regulatory Manual part of the license? Yes. The Manual states it shall be read in conjunction with, and is intended to supplement, the Provisional License and Authority to Operate.

What happens if a casino violates PAGCOR rules? PAGCOR may impose sanctions under its Regulatory Framework for Offenses and Penalties, ranging from a Written Warning or Corrective Action Order for minor offenses to license suspension or revocation for major offenses.

Practical takeaways

• Secure the Provisional License and Authority to Operate first; the Casino Regulatory Manual supplements it.
• Treat the Manual's Regulations as a build-out and compliance checklist, from casino layout and gaming tables to surveillance and the Casino Management System.
• Submit the required Surveillance Plan, Casino Operational Rules and Guidelines, and casino layout plan for PAGCOR approval before commencing operations.
• Expect continuing supervision by the PAGCOR Monitoring Team and strict remittance of license fees.
• Understand the offense classifications and procedural timelines under the Regulatory Framework for Offenses and Penalties before a violation arises.

Primary sources

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

Casino Regulatory Manual for Entertainment City Licensees Version 4.0Open 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.