PAGCOR Special Class of BPO Accreditation Requirements: A Step-by-Step Guide

The PAGCOR Special Class of BPO (SCBPO) accreditation is the authorization that allows a Philippine BPO to provide support services to gaming operators licensed abroad. To obtain it, a company registered with the Securities and Exchange Commission (SEC) files a Letter of Intent with the PAGCOR Chairman and CEO, submits the documentary requirements within three (3) months, pays the applicable application fee, undergoes probity checking, and — once approved — completes pre-operational requirements before a Notice to Commence Operations (NCO) is issued. Operations may not begin without the NCO.

What an SCBPO Is — and What It Cannot Do

An SCBPO is an entity that services legitimately licensed gaming operators abroad. It is not allowed to handle betting in any way; its role is purely product marketing, customer relations, and support.

All SCBPOs must operate strictly on a business-to-business (B2B) basis and must never engage in business-to-consumer (B2C) gaming activities. They must also maintain technical controls to prevent the acceptance of bets or wagers through their systems.

Authorized acts include customer support and hotline services, player registration and assistance, VIP client coordination, loyalty program management, product and brand marketing, responsible gambling measures, game and platform integrity support, data science and machine learning, fraud detection and risk monitoring, cybersecurity, data analytics, proprietary tool chain development, administrative and back-office functions, advanced platform support, and odds management.

Prohibited acts include accepting bets and handling payouts, engaging in illegal activities, providing services to unlicensed entities, and sharing, leasing, or sub-contracting the PAGCOR accreditation to any person or entity.

Eligibility: Who May Apply

Under the Accreditation Framework for Special Class of BPOs, the applicant must:

• Be duly registered with the SEC;
• Be of good financial standing with a satisfactory corporate structure;
• Have directors and officers of good repute — considering character, honesty, and integrity — and of good financial standing;
• Have directors and officers not associated with any person of bad repute or unsatisfactory financial resources; and
• Provide services to a gaming operator licensed under a reputable jurisdiction.

Step 1: File the Letter of Intent

The applicant submits a Letter of Intent (LOI) addressed to the PAGCOR CCEO. The LOI must state the company name, intended address of operations, the name of the gaming operator to be serviced, details of the operator's license and licensing jurisdiction, the services to be provided, the contact person and contact details, and a statement that the applicant has read, understood, and will comply with the framework.

Attach the Articles of Incorporation and By-Laws, the latest General Information Sheet (GIS) including the beneficial ownership page, the Service Agreement with the licensed gaming operator abroad, the operator's registration documents, the operator's license, and the floor plan.

Step 2: Respond to ROASD's Issuances and Pay the Fee

Upon receipt of the LOI, the Remote Operations and Ancillary Services Department (ROASD) issues the Deposit Notice and Payment Form, a notification to undergo probity check with a Data Privacy Consent Form, the Application Form, and a request for ocular inspection.

The accomplished and notarized application form with complete documentary requirements must be submitted within three (3) months from issuance. Late or incomplete submissions are returned; if filed beyond the three-month period, the application is deemed denied and all fees are forfeited.

Application and renewal fees depend on the business model:

• Global Capability Center / Single Client BPO (Class 1): US$100,000.00 per year
• Third Party BPO (Class 2): US$50,000.00 per operator, per year

A Class 2 applicant must onboard at least two (2) licensed operators — within the validity period for a one-year accreditation, or within the first year for a two-year accreditation. Failure to onboard a second operator carries a penalty of US$50,000.00 per year of accreditation. A Class 2 SCBPO may service a maximum of ten (10) licensed operators abroad.

Submit the deposit slip or wire transfer receipt using the Remittance Form within five (5) working days from payment. The application fee is non-refundable and non-transferable unless approved by the Board of Directors (BOD) for valid reasons.

Step 3: Complete Pre-Operational Requirements and Secure the NCO

After approval, the applicant must comply with pre-operational requirements: the performance cash deposit; a Certificate of Registration with the Anti-Money Laundering Council; registrations with the SSS, HDMF, and PhilHealth; a copy of the engagement with an Internet Service Provider; the accomplished Manpower List Form; network topology; a pre-operational inspection and walkthrough report by CMED-EG and the ITD; and the NCO issued by ROASD.

To request the NCO, the SCBPO writes ROASD with the requirements and proposed inspection date. Upon a satisfactory inspection report, ROASD issues the NCO, after which the monthly administrative fee applies.

Key Ongoing Obligations

Accredited SCBPOs must maintain a 90% Filipino workforce. Foreign personnel may exceed the 10% threshold only for highly specialized or proprietary functions — such as advanced platform support, cybersecurity, fraud analytics, or market-specific product expertise — subject to BOD approval, and must never exceed 25% of the total workforce.

The performance cash deposit is US$50,000.00, and the monthly administrative fee is US$10,000.00. Accreditation is site-specific, non-transferable, and not a property right.

Frequently asked questions

How long does PAGCOR SCBPO accreditation last? An applicant may apply for a maximum period of two (2) years. If the Service Agreement with the gaming operator abroad is shorter than the accreditation's validity, the accreditation terminates when the agreement ends.

What happens if a Class 2 SCBPO fails to onboard a second operator? It is penalized US$50,000.00 per year of accreditation.

Can SCBPO employees work from home? Yes. SCBPOs may adopt a hybrid work arrangement, but only 40% of the workforce at a time may work from home, and prior approval from ROASD is required.

Practical takeaways

• File the LOI with the PAGCOR CCEO first, then complete the documentary requirements within three (3) months — late filing means denial and forfeiture of fees.
• Budget for the correct fee: US$100,000.00 per year for Class 1, or US$50,000.00 per operator per year for Class 2.
• Do not start operations without the NCO; doing so exposes the SCBPO to fines and suspension.
• Keep the 90% Filipino workforce ratio and secure Employment Registration Numbers for all directly hired personnel.
• Never accept bets, handle payouts, or service unlicensed operators — these are prohibited acts with heavy penalties.

Primary sources

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

Accreditation Framework for Special Class of BPOsOpen in Law LibraryDownload PDF

Compliance Framework for Special Class of BPOsOpen in Law LibraryDownload PDF

Removal of the Letter of No Objection (LONO) as a Requirement in the Application for a Special Class of BPOOpen 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.