POGO Closure in the Philippines: Options for Displaced Licensees

The Philippine Amusement and Gaming Corporation (PAGCOR) maintains a published list of cancelled POGOs, special class of BPOs, and service providers covering cancellations from 2016 to October 6, 2022. A cancelled offshore gaming license does not, by itself, bar a displaced licensee from pursuing other lawful business lines in the Philippines. What it ends is the privilege to operate a gaming site under that particular license. The practical question for a displaced licensee is therefore not whether the company can still do business, but which regulated activity it may lawfully pursue next — and under whose rules.

What a PAGCOR Cancellation Actually Means

A Gaming License is the document by which PAGCOR grants an Operator the privilege to establish, install, maintain, and operate a gaming facility or gaming terminals. Under the Gaming Site Regulatory Manual (Bingo Games), the license contains the terms and conditions and other PAGCOR regulations governing the operation of the gaming site.

When PAGCOR cancels a license, the Operator loses that privilege. The corporate entity itself is not dissolved, and its other lawful business purposes — if any — remain. This distinction matters because many displaced licensees hold SEC-registered corporations with Articles of Incorporation that list gaming as a primary or secondary purpose.

Option 1: Apply for a New PAGCOR Gaming License

A displaced licensee that wishes to remain in regulated gaming may apply for a new Gaming License, provided it qualifies. Under the Gaming Site Regulatory Manual:

• Only corporations duly registered with the Securities and Exchange Commission (SEC) may apply as Operator of a gaming site.
• The Applicant must pass PAGCOR's standard probity check for Operator suitability and comply with the documentary requirements.
• 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).

The Manual's documentary checklist requires, among others, SEC registration, the latest General Information Sheet, and Articles of Incorporation showing that gaming is one of the primary purposes of business — or, if gaming is only a secondary purpose, a copy of the Board's Ratificatory Vote on the same.

Option 2: Convert to a Lawful Non-Gaming Business

A displaced licensee whose Articles of Incorporation permit other primary purposes may continue operating as an ordinary corporation. Where gaming is a primary purpose but the company now intends to abandon gaming, the corporate documents — the Articles of Incorporation and By-Laws — will generally need to be amended and the change reported to the SEC.

Under the Manual, any change in ownership of a licensed corporation must be reported to PAGCOR's Gaming Licensing and Development Department (GLDD) upon occurrence. Any change in, or addition to, the Board of Directors must be reported to the GLDD within five (5) days from the occurrence of the change. These reporting duties attach to licensed Operators; a company that has fully exited the licensing regime should confirm its residual obligations with counsel.

Option 3: Wind Down and Comply with Post-Operational Requirements

The Gaming Site Regulatory Manual addresses voluntary closure of a gaming site and post-operational activities. A licensee that chooses to exit entirely should expect to account for its gaming equipment and paraphernalia. The Manual contains separate regulations on the movement, pull-out, transfer, and disposal of gaming equipment, including destruction of the same.

Practical wind-down steps typically include:

1. Settling outstanding PAGCOR shares and monetary obligations.
2. Securing approval for the pull-out, transfer, or disposal of gaming equipment.
3. Closing out player accounts and residual credits.
4. Filing the necessary reports with the SEC and the Bureau of Internal Revenue.
5. Retaining records for the period required by PAGCOR and tax authorities.

Option 4: Repurpose the Workforce and Facilities

Many displaced licensees operated as special class BPOs or service providers — PAGCOR's own list includes dozens of cancelled service providers with addresses across Makati, Pasay, Quezon City, Cebu, Pampanga, and Subic. These entities often hold BPO-oriented corporate purposes and physical office space. Where the corporate purpose permits, the entity may pivot to legitimate outsourcing, technology, or consultancy work, subject to the usual SEC, local government, and tax registrations.

Frequently asked questions

Can a cancelled POGO still operate in the Philippines? No. Once PAGCOR cancels the license, the entity can no longer operate a gaming site under that license. It may, however, pursue other lawful business activities if its corporate purposes and registrations allow.

Can a foreign-owned corporation apply for a new PAGCOR gaming license? Yes, 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 must be reported to PAGCOR after a change in the company? Any change in ownership of a licensed corporation must be reported to the GLDD upon occurrence. Any change in, or addition to, the Board of Directors must be reported within five (5) days from the change.

Practical takeaways

• A cancelled PAGCOR license ends the gaming privilege, not the corporation.
• Only SEC-registered corporations may apply as Operators of a gaming site.
• Foreign ownership in an applicant corporation must comply with the Regular Foreign Negative List B of the Foreign Investments Act of 1991.
• Changes in ownership and in the Board of Directors carry specific GLDD reporting duties.
• Gaming equipment must be pulled out, transferred, or disposed of under the Manual's rules — not simply abandoned.

Primary sources

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

List of Cancelled POGOs and Service ProvidersOpen 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.