Money Service Business License Philippines: BSP Registration Rules

Money service businesses (MSBs) in the Philippines must register with the Bangko Sentral ng Pilipinas (BSP) before operating. Under the consolidated MSB rules issued through BSP Circular No. 1206 (Series of 2024), remittance and transfer companies (RTCs), money changers, and foreign exchange dealers (MCs/FXDs) must secure a Certificate of Registration (COR) from the BSP. Registration involves submitting an application and a notarized Deed of Undertaking, paying the applicable fees, and commencing operations within three months of the COR's issuance. Operating without prior BSP registration exposes the business to penalties under the New Central Bank Act, disqualification from registration, and watchlisting of its owners and principal officers.

Who needs to register as an MSB

The BSP rules define an MSB as a non-bank entity engaged in remittance, money changing, and/or foreign exchange dealing. The registration requirement covers:

• Remittance and Transfer Companies (RTCs) — entities providing money or value transfer services, including remittance agents, remittance network providers, remittance platform providers, and e-money issuers.
• Money Changers / Foreign Exchange Dealers (MCs/FXDs) — entities buying or selling currencies in exchange for another currency.

Remittance sub-agents (RSAs) no longer need to register with the BSP, but the accrediting RTC must comply with notification requirements and remains responsible for the RSA's compliance with anti-money laundering rules.

How to register: the step-by-step process

1. Determine your classification. The BSP classifies applicants by type, from large-scale and small-scale operators to e-money issuers, remittance platform providers, and virtual asset service providers. Classification depends on the average monthly network volume of transactions.
2. Submit the application. File the Application for Registration and a notarized Deed of Undertaking with the appropriate supervising department of the BSP, following the registration procedures in the rules.
3. Meet the fit-and-proper standard. The BSP assesses the integrity, market reputation, competence, and financial capacity of the proprietor, partners, directors, or principal officers.
4. Complete AML/CFT training. The proprietors, partners, directors, president or equivalent officer, over-all head of the MSB operation, and head of the compliance unit must attend a seminar on AML/CFT laws and regulations before operations begin.
5. Pay the fees. A one-time, non-refundable registration fee applies, plus a supplemental fee for each office beyond the head office (except for e-money issuers). Annual service fees are paid not later than March of every year.
6. Receive the COR and metal plate. Once requirements are met, the BSP issues the COR and a metal plate bearing the unique registration number for the head office.
7. Commence operations within three months. Failure to start operations within three months from the COR's issuance results in cancellation of the COR.

Capital and documentary requirements

Minimum capitalization depends on classification. Large-scale remittance agents must have at least P50 million in capital, while small-scale remittance agents need less than P50 million. Large-scale MC/FXDs need at least P10 million; small-scale MC/FXDs less than P10 million. Remittance platform providers require P10 million. Virtual asset service providers range from P10 million to P50 million depending on whether they provide safekeeping services.

The BSP will not issue a COR if required documents are incomplete or if any proprietor, partner, director, or principal officer is not fit and proper.

Ongoing obligations after registration

Registered MSBs must notify the BSP within five business days of events such as commencement of operations, new offices, new or terminated tie-up partners, transfer of location, and closure of an office. Large value pay-outs exceeding P50,000 in a single transaction must be made only by check or direct credit to a deposit account.

Prior BSP approval is required for any change in ownership of a sole proprietorship or partnership, or control of a corporation involving at least twenty percent (20%) of voting shares. Failure to seek prior approval may result in cancellation of registration.

MSBs must also submit reports, including semestral reports on operating offices, audited financial statements, quarterly reports on money changing and remittance transaction values, and reports on crimes or losses.

Frequently asked questions

How much does it cost to register a money service business in the Philippines? The one-time registration fee is P100,000 for large-scale operators, e-money issuers, remittance platform providers, and VA custodians, and P20,000 for small-scale operators. A supplemental fee of P1,000 applies for each office beyond the head office, except for e-money issuers.

Can I operate a remittance business without BSP registration? No. RTCs, MCs, and FXDs must register with the BSP before operating. Operating without prior registration may result in penalties under the New Central Bank Act, disqualification from registration, and watchlisting of owners and principal officers.

What happens if I don't start operations after getting my COR? The COR is cancelled if the registered MSB fails to commence operations within three months from the date of issuance.

Practical takeaways

• Register with the BSP before operating — there is no legal way to run an MSB without a COR.
• Confirm your classification first, since it determines your capital requirement, registration fee, and annual service fee.
• Complete AML/CFT training for owners and key officers before starting operations.
• Commence operations within three months of receiving the COR, or the registration is cancelled.
• File notifications and reports on time; late or erroneous reports carry monetary penalties.

Primary sources

The rules discussed above are drawn from the following primary sources. Where the firm's library holds the document as a PDF it is embedded here in full; the rest are cited by title.

Consolidated Rules for Money Service Businesses (MSBs) under the New "Manual of Regulations for Non-bank Financial Institutions (MORNBFI)-M"Open in Law LibraryDownload PDF

• REPUBLIC ACT NO. 11127 - AN ACT PROVIDING FOR THE REGULATION AND SUPERVISION OF PAYMENT SYSTEMS

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