PAGCOR Live Dealer Game Content Approval: Guidelines for Online Casinos

Live dealer games are casino games whose outcome comes from live feeds of a real human croupier, streamed in real time to a gaming website or app — not from a random number generator. Under PAGCOR's Guidelines on Live Dealer Game Contents (Rev. No. 1, effective 15 November 2023), live dealer games are allowed as game content only for a PAGCOR-approved electronic (casino) remote gaming platform operated by a PAGCOR-accredited Electronic Gaming System (EGS) Service Provider. The E-Games Licensing Department (EGLD) processes all evaluation and approval requests. Live peer-to-peer poker is excluded, as poker games are licensed separately through the Table Games Department.

Who may offer live dealer games

Two layers of approval matter. First, the platform: live dealer games may be deployed only on a PAGCOR-approved electronic (casino) remote gaming platform of a PAGCOR-accredited EGS Service Provider. Second, the content itself: only live dealer games provided by legitimate Game Providers are allowed, and only live feeds must be used to determine the outcome of the games.

This means a random number generator cannot stand in for the live feed in a live dealer offering. The result the player sees must come from the streamed studio table.

The approval requirements for live dealer content

Under the Guidelines, the following must be satisfied:

1. EGLD processes the request. All evaluation and approval involving requests to offer and operate live dealer games goes through the E-Games Licensing Department.

2. Legitimate Game Providers only. Only live dealer games from legitimate Game Providers are allowed as game content, and only live feeds may be utilized for game outcomes.

3. Independent laboratory certification of the platform. The gaming software platform hosting the live dealer games must be certified by a reputable and independent gaming laboratory under applicable standards.

4. Streaming source and accreditation. Feeds may be streamed live from a gaming studio located within the territorial jurisdiction of the Philippines or abroad. Where the studio is located in the Philippines, the Streaming Provider must be duly accredited under the provisions of the Accreditation Procedures for Data/Content Streaming Provider of Electronic Gaming Sites, and must secure the necessary Permit To Possess (PTP) for its concerned gaming studio under the Application Procedures for Permit To Possess Gaming Equipment & Gaming Paraphernalia for Data/Content Streaming Provider of Electronic Gaming Sites.

A PAGCOR-accredited Live Studio and Streaming Provider (LSSP) under the Offshore Gaming Licensing Department (OGLD) may provide live feeds for live dealer games given its existing operational resources and technical capabilities — provided it complies with the Philippine-studio requirement above.

5. License fee. Gross Gaming Revenue (GGR) attributable to live dealer games is subject to a 47.50% PAGCOR Share or License Fee.

How this fits the remote gaming platform framework

The live dealer guidelines operate alongside the Revised Regulatory Framework for the Remote Gaming Platform (Rev. No. 3, effective 15 November 2023), which governs the platform on which such content sits. Key points:

• Only games and/or markets with prior written approval from PAGCOR may be deployed as game contents on a remote gaming platform.
• The remote gaming platform must have prior written approval from PAGCOR before implementation.
• The platform must be integrated with PAGCOR's third-party audit platform, and all player transactions are attributed to the player's designated gaming site.
• A PAGCOR Evaluation Team — drawn from EGLD, the Compliance Monitoring and Enforcement Department (CMED), and the Information Technology Department (ITD) — conducts actual testing and a walkthrough of the platform's process, from player registration up to report generation, before a Notice to Commence operations is issued.
• Service Providers operating an approved remote gaming platform must comply with the PhP50 Million cash bond requirement.
• Operators and Service Providers must comply with Anti-Money Laundering Council rules as supervised by PAGCOR's Anti-Money Laundering Supervision and Enforcement Department (PASED).
• Any deviation from submitted certifications, or breach or circumvention of the framework, is ground for suspension of the remote gaming platform, with losses borne by the Service Provider.

Frequently asked questions

Can live dealer games be offered on any PAGCOR-approved online casino? They may be allowed as game content for a PAGCOR-approved electronic (casino) remote gaming platform of a PAGCOR-accredited EGS Service Provider, subject to the live dealer guidelines.

Do live dealer games need a random number generator? No. The outcome must be derived from live feeds of a real human croupier. Only live feeds may be utilized for the outcome of the games.

Can the gaming studio be located abroad? Yes. Feeds may be streamed from a studio within the Philippines or abroad. If the studio is in the Philippines, the Streaming Provider must be accredited and must secure the required Permit To Possess for the studio.

How much is the PAGCOR share on live dealer games? Gross Gaming Revenue attributable to live dealer games is subject to a 47.50% PAGCOR Share or License Fee.

Practical takeaways

• Live dealer content requires both an approved remote gaming platform and PAGCOR approval of the game content itself through EGLD.
• Only legitimate Game Providers may supply live dealer games, and only live feeds may determine outcomes.
• The hosting platform needs certification from a reputable, independent gaming laboratory.
• Philippine-based studios require Streaming Provider accreditation and a Permit To Possess for the gaming studio.
• Expect a 47.50% PAGCOR Share or License Fee on GGR from live dealer games, and note that live peer-to-peer poker is excluded from these guidelines.

Primary sources

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

Revised Regulatory Framework for the Remote Gaming PlatformOpen in Law LibraryDownload PDF

Guidelines on Live Dealer Game ContentsOpen 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.