PAGCOR Gaming System Administrator Accreditation: Rules, Fees and Penalties

Operators of PAGCOR-licensed gaming venues must engage a Gaming System Administrator (GSA) — the entity accredited by PAGCOR to provide the electronic gaming system (EGS), its suite of games, and the online gaming platform (OGP), if any. Accreditation is granted per game offering, so a GSA must be separately accredited for each offering it intends to supply. Only corporations duly registered with the Securities and Exchange Commission may apply. The application is filed with PAGCOR's Electronic Gaming Licensing Department (EGLD), requires a non-refundable accreditation fee, probity clearance, and inspection, and is approved by the PAGCOR Board of Directors.

What is a Gaming System Administrator?

Under PAGCOR's Regulatory Framework for the Accreditation of Gaming System Administrators, a GSA (formerly called a Gaming System Service Provider) is the entity accredited by PAGCOR to provide the necessary electronic gaming service, along with its suite of games, to PAGCOR-licensed gaming venues per specific game offering.

The EGS is the technology — software, servers, databases, communications technology, and proprietary hardware — designed or modified for the conduct of gaming. It may include an OGP, which is the online channel that lets registered players access games remotely through the internet.

Accreditation covers these game offerings: Traditional Bingo Games, Electronic Bingo Games, Electronic Casino Games, Sports Betting, Specialty Games, Online Poker Games, Numeric Games, and any other suite of games PAGCOR may allow in the future.

Who may apply for GSA accreditation

Only corporations duly registered with the SEC may apply. The applicant must meet PAGCOR's probity standards, meaning it must be:

• Of good repute, considering character, honesty, and integrity;
• Not associated with any person who is not of good repute or who has undesirable or unsatisfactory financial resources;
• Possessed of sufficient experience and ability to establish and manage gaming operations;
• Not excluded from engaging in gaming under the framework or any other law; and
• In the case of an artificial person, of stable financial standing and satisfactory corporate structure.

The accreditation process, step by step

1. Download the application form for accreditation of a GSA from the PAGCOR regulatory website.
2. Submit a Letter of Intent addressed to the PAGCOR Chairman and Chief Executive Officer.
3. File the accomplished application form with the EGLD, together with the documents listed in Annex A (List of Documentary Requirements).
4. Undergo probity checks on the identity, finances, integrity, competence, and criminality of each key official, including a certification or report from a third-party probity checker at the applicant's cost.
5. Pay the non-refundable accreditation fee of Five Million Pesos (PhP5 Million) for each game offering, upon the EGLD's advice.
6. Enrol with the Gaming Licensing and Development Department (GLDD) before doing business with a PAGCOR-licensed operator or licensee.
7. Undergo ocular inspection, walkthrough, and testing of the EGS, OGP, and games by the PAGCOR Inspection Team.

The EGLD processes all applications, and only applications with complete requirements are considered received. Incomplete applications are returned and may be resubmitted once the insufficiencies are addressed.

The application is recommended to the PAGCOR Board only upon complete documentary requirements, payment of the fee, satisfactory inspection and testing results, and compliance with probity requirements. If approved, the Certificate of Accreditation (COA), signed by the PAGCOR Chairman and CEO, is issued. The COA is a permit or privilege, not a contract, and may be amended, supplemented, suspended, or revoked. It is not a property right and does not create a vested right.

Performance Cash Deposit and other fees

Before commencing operations, the GSA must post a Performance Cash Deposit (PCD) with PAGCOR:

• One game offering: Twenty-Five Million Pesos (PhP25 Million)
• Two or more game offerings: Fifty Million Pesos (PhP50 Million)

A PCD is also posted per game offering and required from the Operator before the suite of games may be offered at its venue. For any additional game offering, the GSA must post the PCD before operations of the new offering commence.

A Reprinting or Reissuance Fee of Twenty Thousand Pesos (PhP20,000.00) applies to requests for reprinting or reissuance of any certificate, where the correction or change is through no fault of PAGCOR — for example, a lost, torn, or damaged certificate, or an approved change in the certificate's details.

Ongoing obligations of an accredited GSA

Accreditation carries continuing duties. The GSA must:

• Establish or contract a minimum number of operational gaming venues. A newly accredited GSA must have at least one operational venue prior to commencement, at least ten (10) within twelve (12) months from the commencement date, and twenty (20) within twenty-four (24) months.
• Register one main brand name and one main domain name/URL, with up to six (6) sub-brands permitted.
• Submit yearly documents to the EGLD on or before May 31 — the valid Business/Mayor's Permit, the latest General Information Sheet filed with the SEC, and the duly filled-out Authorized Signatory form.
• Report any change in ownership or in its Board of Directors within fifteen (15) calendar days from the change.
• Report monthly the number of active registered players per age bracket.
• Comply with the Anti-Money Laundering Council rules, the Data Privacy Act (Republic Act 10173), and PAGCOR's probity check requirements.
• Not allow player registration or accept bets emanating outside the Philippines.

Grounds for suspension or cancellation

The PAGCOR Board may suspend or cancel an accreditation — and may forfeit the PCD where warranted — on grounds such as: the GSA is no longer a suitable corporation to be accredited; its directors, key officers, or beneficial owners are convicted of violating Philippine anti-gambling laws or any serious offense; it violates a condition of its accreditation; it is bankrupt or under rehabilitation; it obtained accreditation through materially false or misleading representation; or suspension is required to protect the public interest or the integrity of gaming. Non-compliance with the No Subleasing, Subletting or Sublicensing Policy carries revocation of accreditation and blacklisting.

Frequently asked questions

Can a foreign corporation apply for PAGCOR GSA accreditation? Only corporations duly registered with the Securities and Exchange Commission may apply. Registration with the SEC is a threshold requirement under the framework.

How much is the PAGCOR GSA accreditation fee? The non-refundable accreditation fee is Five Million Pesos (PhP5 Million) for each game offering, payable upon the EGLD's advice.

How much is the performance cash deposit for a GSA? Twenty-Five Million Pesos (PhP25 Million) for one game offering, and Fifty Million Pesos (PhP50 Million) for two or more game offerings.

Practical takeaways

• Accreditation is granted per game offering — a separate accreditation is required for each offering a GSA intends to supply.
• Only SEC-registered corporations that pass PAGCOR probity standards may apply.
• Budget for the PhP5 Million non-refundable accreditation fee per offering, plus the PCD of PhP25 Million (one offering) or PhP50 Million (two or more).
• Expect ocular inspection and actual testing of the EGS and OGP before the PAGCOR Board acts on the application.
• Accreditation brings continuing obligations, including venue build-out targets, yearly document submissions, and AMLC and Data Privacy Act compliance.

Primary sources

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

Regulatory Framework for the Accreditation of Gaming System AdministratorsOpen in Law LibraryDownload PDF

Annex D-2 - Amendments to the Regulatory Framework for the Accreditation of Gaming System Administrators Revision No. 0Open 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.