PAGCOR Offenses and Penalties for Remote Gaming Operations Explained

PAGCOR regulates remote gaming operations through a Regulatory Framework for Offenses and Penalties issued by its Electronic Gaming Licensing Department (EGLD). The framework lists specific violations, the fines they carry, and the escalation that can follow — from a written warning to suspension or even revocation of a license or accreditation. Penalties may be collected from the erring entity or deducted from the Performance Cash Deposit (PCD) it posted. The current framework is Revision No. 3, effective 06 November 2025, which supersedes previous PAGCOR issuances on offenses and penalties for electronic gaming operations.

Who the rules cover

The framework governs offenses committed by PAGCOR-licensed Operators, accredited Gaming System Administrators (GSAs), Business-to-Business (B2B) Providers such as Gaming Affiliates and Support Service Providers, and Contractees or Licensees of Integrated Resorts. Revision No. 3 refers to these collectively as Authorized Entities.

The earlier framework, Revision No. 1 effective 31 July 2024, covered remote gaming operations and applied to Operators, accredited Service Providers, Contractees, and Integrated Resort Licensees. It has since been superseded.

How PAGCOR enforces compliance

When an Authorized Entity does not comply with the regulatory frameworks, the EGLD issues a Show Cause requiring an explanation or compliance within fifteen (15) days from receipt, unless otherwise stated. If the entity is found non-compliant or fails to respond, the EGLD issues an electronic Notice of Non-compliance or Imposition of Penalty.

The framework also provides that the privilege to operate a gaming venue may be revoked under the Regulatory Framework for the Issuance of Gaming License for the Establishment of Gaming Venue. The accreditation of GSAs and B2B Providers may likewise be revoked depending on the severity of the infraction, with revocation determined by the EGLD and subject to approval by PAGCOR's Board of Directors. Suspension of operations may be imposed as determined by the EGLD, subject to approval of PAGCOR's Chairman and CEO.

Common offenses and their fines

For Gaming Venue Operators, a written warning is issued for the first offense for each specific violation. For second and subsequent offenses, the framework sets fines that include:

• Late or non-remittance of amounts due to PAGCOR (PAGCOR Share and/or Audit Fee): 25% of the total amount due, imposed per transaction. Continuous non-remittance may lead to suspension or revocation of the license.
• Non-payment of player's winnings: PhP100,000.00 or the amount of the winnings, whichever is lower.
• Unauthorized deduction from winnings or redeemed balances: PhP100,000.00 or the amount of the winnings, whichever is lower.
• Unauthorized suspension of operations without just cause: PhP50,000.00 per day of offense.
• Unauthorized operation of the gaming venue: PhP200,000.00.
• Procurement of gaming equipment without prior approval: PhP200,000.00.
• Portable gaming terminal found outside the gaming venue: PhP100,000.00.
• Failure to submit the annual Business Permit: PhP100,000.00 per year of offense.

For GSAs, IR Licensees, Contractees, and B2B Providers, penalties are generally higher and are not preceded by a written warning in the same way. Examples include:

• Unauthorized operation of an electronic gaming system, including online gaming platform websites and applications: PhP500,000.00.
• Failure to integrate with PAGCOR's third-party audit platform: PhP500,000.00.
• Allowing player registration, accepting bets, or sales outside the Philippines: PhP1,000,000.00.
• Non-adherence to prescribed processes and operational standards: PhP300,000.00.
• Implementation of game parameter settings other than PAGCOR-approved settings: PhP300,000.00.
• Access and play by banned and unregistered personalities: PhP500,000.00. If a minor has accessed and played, the penalty is revocation of accreditation.
• Operation of game content without prior PAGCOR approval: PhP300,000.00 per game content, with all income from the unauthorized content collected in favor of PAGCOR.

Paying penalties and interest

Authorized Entities must pay the corresponding penalty within fifteen (15) days from receipt of the notice of imposition of penalty, unless otherwise stated. Interest of twelve percent (12%) per annum is imposed on any amount unpaid after fifteen days, pro-rated on a daily basis.

Payments must be submitted to the PAGCOR Fund Management Department, copy furnished the EGLD, together with a duly accomplished Payment Processing Request Form (EG Form No. 2) for issuance of an Official Receipt. The entity must secure the Official Receipt as proof of payment and submit a copy to the EGLD.

Upon termination of gaming venue operations or accreditation, voluntary or otherwise, unpaid penalties are deducted from the Performance Cash Deposit.

When violations become habitual

Under Revision No. 3, a succeeding offense refers to instances where the Authorized Entity has been previously found liable and penalized for the same offense on five (5) or more instances, including cases where a written warning was issued. Such offenses are considered habitual or repetitive. For succeeding offenses, the penalty may be increased as determined by the Board of Directors upon the EGLD's recommendation.

Acts not covered by existing frameworks that substantially undermine PAGCOR's regulatory authority, or violations of PAGCOR issuances and national or local laws, are subject to the determination of the PAGCOR Board of Directors, which may impose a fine, suspension, or revocation depending on severity.

Frequently asked questions

What happens if a PAGCOR licensee violates the regulatory framework? The EGLD issues a Show Cause requiring explanation or compliance within fifteen days. If the entity is non-compliant or fails to respond, a Notice of Non-compliance or Imposition of Penalty follows, and the applicable fine is imposed.

How much is the penalty for accepting bets outside the Philippines? For GSAs, IR Licensees, Contractees, and B2B Providers under Revision No. 3, the penalty is PhP1,000,000.00.

What happens if unpaid penalties are not settled? Interest of twelve percent per annum is imposed on amounts unpaid after fifteen days from receipt of the notice, pro-rated daily. Unpaid penalties may also be deducted from the Performance Cash Deposit upon termination of operations or accreditation.

Practical takeaways

• A written warning is issued for a first offense for each specific violation by Gaming Venue Operators; second and subsequent offenses carry the listed fines.
• Penalties for GSAs, IR Licensees, Contractees, and B2B Providers can reach PhP1,000,000.00, and allowing a minor to access and play may result in revocation of accreditation.
• Payment is due within fifteen days from receipt of the notice; unpaid amounts earn 12% interest per annum.
• The EGLD may suspend operations with approval of the Chairman and CEO, and revoke accreditation with approval of the Board of Directors.
• Revision No. 3, effective 06 November 2025, supersedes previous PAGCOR issuances on offenses and penalties for electronic gaming operations.

Primary sources

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

Regulatory Framework for Offenses and Penalties Rev. No. 3Open in Law LibraryDownload PDF

Regulatory Framework for Offenses and Penalties (Remote Gaming Operations) Rev. No. 1Open 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.