·By Ablola, Saribong & Gueco Law Offices · researched and citation-checked against the firm's law library

PAGCOR Gaming Supplier Accreditation in the Philippines: A Guide for Foreign Companies

How foreign companies can secure PAGCOR gaming supplier accreditation in the Philippines, from SEC registration to probity checks and documentary requirements.


Foreign companies that want to supply gaming equipment and paraphernalia to PAGCOR-regulated gaming sites must go through PAGCOR accreditation. In practice, the starting point is corporate registration: PAGCOR's Gaming Site Regulatory Manual (Bingo Games) requires that only corporations duly registered with the Securities and Exchange Commission (SEC) may apply as an Operator of a gaming site. A corporation with foreign nationals as shareholders may apply, provided foreign ownership complies with the Regular Foreign Negative List B of the Foreign Investments Act of 1991 (R.A. No. 7042, as amended by R.A. No. 8179). Suppliers are then evaluated under PAGCOR's accreditation standards for suppliers of gaming equipment and paraphernalia.

What PAGCOR accreditation covers

The Gaming Site Regulatory Manual (Bingo Games), Version 3.0 (March 2017), issued by PAGCOR's Gaming Licensing and Development Department, devotes a specific regulation to the Accreditation of Suppliers of Gaming Equipment and Paraphernalia. That regulation covers accreditation of suppliers and the standards against which they are evaluated.

Accreditation matters because gaming equipment and paraphernalia used in a gaming site must meet PAGCOR requirements. The manual defines "gaming paraphernalia" broadly as apparatus, furnishing, or accessories used in or necessary in the conduct of gaming operations. Suppliers therefore sit within PAGCOR's regulatory perimeter even though the Operator holds the gaming license.

Who may apply: the corporate and ownership rules

A foreign supplier should expect the same baseline corporate requirements that apply to Operators:

  • SEC-registered corporation. Only corporations duly registered with the SEC may apply. A foreign company typically incorporates a Philippine subsidiary or affiliate for this purpose.
  • Foreign ownership limits. A corporation with foreign nationals as shareholders may apply, provided foreign ownership complies with the Regular Foreign Negative List B of the Foreign Investments Act of 1991 (R.A. No. 7042, as amended by R.A. No. 8179).
  • Gaming as a corporate purpose. The Articles of Incorporation must show that gaming is one of the primary purposes of business; if it is only a secondary purpose, a copy of the Board's Ratificatory Vote on the same should be submitted.
  • Probity. The applicant must pass PAGCOR's standard probity check for suitability and comply with the submission of documentary requirements.

Documentary requirements to prepare

The manual's documentary table for corporations lists items that a foreign applicant should prepare in advance. These include a company profile, SEC registration, the latest General Information Sheet duly stamped as received by SEC, and the Articles of Incorporation and By-Laws duly stamped as received by SEC. Where a stockholder is itself a corporation, a copy of that corporation's latest GIS should likewise be submitted.

Two warnings in the manual deserve emphasis. Any misrepresentation or false information in the documentary requirements will result in the outright denial of the application. If the license has already been granted and the misrepresentation is discovered, the license shall be revoked outright.

Reporting changes after accreditation

Accredited suppliers with Philippine corporate vehicles must keep PAGCOR informed of corporate changes:

  • Any change in ownership of the corporation shall be reported to the Gaming Licensing and Development Department (GLDD) upon occurrence of the change. For new Operators, the sale or transfer of any share in the corporation is not allowed within two (2) years from commencement of operation of the gaming site, unless with prior written approval from the GLDD and for serious and justifiable cause.
  • Any change in, or addition to, the Board of Directors shall be reported to the GLDD within five (5) days from the occurrence of the change.

How accreditation fits with equipment approval

Accreditation is not the end of the compliance chain. Gaming equipment deployed in a gaming site must also satisfy PAGCOR's technical standards. PAGCOR's Technical Standards for Electronic Gaming Machines (Version 1.0, December 2013) govern the design and operation of electronic gaming machines, and PAGCOR recognizes independent gaming laboratories for testing gaming equipment against those technical standards. The manual also addresses procurement of gaming equipment and paraphernalia, including foreign procurement, inspection, and inventory.

For a foreign supplier, this means two parallel workstreams: securing supplier accreditation through the corporate and probity route, and ensuring the specific equipment or paraphernalia offered meets the applicable technical standards.

Frequently asked questions

Can a foreign-owned company be accredited as a PAGCOR gaming supplier? Yes, subject to ownership limits. A corporation with foreign nationals as shareholders may apply, provided foreign ownership complies with the Regular Foreign Negative List B of the Foreign Investments Act of 1991 (R.A. No. 7042, as amended by R.A. No. 8179).

What happens if a supplier submits false documents to PAGCOR? Any misrepresentation or false information in the documentary requirements results in outright denial of the application. If a license has already been granted, it shall be revoked outright.

Does a supplier need SEC registration to deal with PAGCOR? The manual requires that only corporations duly registered with the SEC may apply. A foreign company ordinarily establishes a Philippine corporation for this purpose.

Practical takeaways

  • Incorporate a Philippine corporation with the SEC before applying; gaming should appear as a primary corporate purpose.
  • Confirm foreign ownership complies with the Regular Foreign Negative List B of the Foreign Investments Act of 1991 (R.A. No. 7042, as amended by R.A. No. 8179).
  • Prepare the full documentary set: company profile, SEC registration, latest GIS, and Articles of Incorporation and By-Laws duly stamped as received by SEC.
  • Expect a probity check and treat every submission as material — misrepresentation leads to denial or revocation.
  • Report ownership changes to the GLDD upon occurrence and Board changes within five (5) days.
  • Confirm that the specific equipment offered meets PAGCOR technical standards and recognized laboratory testing.

Primary sources

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

PAGCOR Technical Standards for EGMs v1.0Open in Law LibraryDownload PDF

Gaming Site Regulatory Manual ver. 3.0 ( Bingo Games)Open 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.

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