Unified Gaming License PAGCOR Philippines: What Operators Need to Know

The Unified Gaming License (UGL) is a single PAGCOR-issued gaming license that authorizes a qualified operator to establish and operate one integrated gaming venue offering the full range of Mandatory Game Offerings under the Electronic Gaming Licensing Department (EGLD). It replaces the need to hold several Standard Gaming Licenses (SGLs) — one per game offering — with one license, one validity period, and consolidated approvals. It is an alternative, incentive-based structure; PAGCOR has not discontinued the SGL, which remains available as a separate licensing option.

How the UGL differs from a Standard Gaming License

An SGL authorizes only the specific game offering or offerings expressly approved by PAGCOR, and separate SGLs may carry different validity and renewal dates. A UGL, by contrast, covers multiple PAGCOR-approved game offerings within one gaming venue under a single license, with one validity period for all authorized game offerings.

Under the framework, a new UGL is valid for three (3) years, with the first year serving as the period within which the operator must commence gaming operations. A renewed UGL is valid for two (2) years. An amended or reprinted UGL issued because of an approved relocation retains the unexpired term of the existing UGL. Failure to commence operations within the prescribed period is governed by the framework's rules on extension, cancellation, or revocation.

What game offerings a UGL covers

Game offerings under a UGL are classified into two groups.

Mandatory Game Offerings form the core basis of the UGL:

• Electronic Bingo Games
• Electronic Casino Games

Ancillary Game Offerings are optional and may be added or removed during the validity of the UGL, subject to EGLD approval:

• Traditional Bingo Games
• Sports Betting
• Specialty Games
• Online Poker Games
• Numeric Games

The operator must maintain the authority, capacity, and operational readiness to offer all Mandatory Game Offerings throughout the UGL's validity. An operator that permanently removes a Mandatory Game Offering may no longer hold a UGL; the license must be converted to the appropriate SGL or SGLs. A Mandatory Game Offering may be temporarily suspended for a period not exceeding ninety (90) calendar days, subject to the framework's conditions and procedures.

Minimum venue requirements

Unless PAGCOR modifies them, reduced minimum requirements apply to UGL gaming venues:

• Twenty-five (25) terminals or machines for Electronic Bingo Games
• Twenty-five (25) terminals or machines for Electronic Casino Games
• Twenty-five (25) terminals or seats for Traditional Bingo Games, if offered as an Ancillary Game Offering
• One (1) terminal or machine for Sports Betting, Specialty Games, Numeric Games, Online Poker Games, and other approved offerings requiring terminal or machine deployment

These minimums apply to the gaming venue as a whole. A UGL may cover gaming areas located on different floors, units, or portions of the same building or approved premises, provided the complete approved address is indicated in the UGL, the operator exercises common management and operational control over all gaming areas, and the configuration does not impair PAGCOR inspection, monitoring, surveillance, access control, or responsible gaming measures. The original UGL must be posted at all times in a visible location, with reprinted copies posted in separately configured gaming areas.

Applying for a new UGL

Applications for a new UGL follow the same application requirements, evaluation procedures, documentary submissions, inspection requirements, and payment of fees applicable to an SGL, unless the UGL framework provides otherwise. In addition, a UGL applicant must comply with the prescribed venue configuration, minimum gaming venue requirements, system and equipment readiness standards, mandatory game offering requirements, the Performance Cash Deposit (PCD), and applicable fees.

A new UGL application is subject to approval by the PAGCOR Board of Directors, and submission of complete requirements does not guarantee approval. Before any Mandatory Game Offering may commence, the operator must undergo pre-operational inspection, testing, or validation by the Compliance Monitoring and Enforcement Department – Electronic Games (CMED-EG). Upon satisfactory compliance, EGLD issues the corresponding Notice to Commence (NTC). No gaming operation may begin without an NTC or written authorization from PAGCOR.

Converting existing SGLs into a UGL

An existing operator with valid SGLs may apply to consolidate or convert them into a UGL if the SGLs remain valid at the time of application and pertain to the same approved gaming venue; the venue is existing and duly approved by PAGCOR, regardless of operational status; the venue can comply with UGL minimum and configuration requirements; and the operator is in good standing with no outstanding regulatory obligation, unpaid fee, penalty, assessment, or unresolved compliance requirement, unless PAGCOR allows otherwise.

The conversion application requires the prescribed Application Form for Conversion, a valid business permit, existing and proposed floor layout plans and site concept renderings, a Board Resolution or Secretary's Certificate with the latest General Information Sheet, and payment of the applicable Application Fee. Upon approval, PAGCOR issues a Notice of Approval indicating the approved operational game offerings and the requirement to post a PCD per gaming venue — not per game offering — within fifteen (15) days from receipt.

Credits may be applied against the conversion Application Fee, subject to PAGCOR validation and accounting clearance: One Hundred Thousand Pesos (Php100,000.00) for every complete and unexpired year remaining on each valid SGL to be consolidated, regardless of operational status; application fees previously paid for an additional game offering application not processed because of the decision to convert; and renewal fees paid for an existing SGL where the operator subsequently elects to convert. Credits apply only to the relevant conversion application, cannot exceed the Application Fee, and are not refundable in cash.

The affected SGLs must be cancelled and surrendered to EGLD before the UGL is released, and their validity periods are superseded by the UGL's validity period.

Frequently asked questions

Can a UGL holder still offer games that are not in the mandatory list? Yes. Ancillary Game Offerings such as Traditional Bingo Games, Sports Betting, Specialty Games, Online Poker Games, and Numeric Games may be added or removed during the UGL's validity, subject to EGLD approval and pre-operational testing.

What happens if a UGL operator stops offering a mandatory game? Permanently removing a Mandatory Game Offering disqualifies the operator from holding a UGL. The license is converted to the appropriate SGL or SGLs covering the remaining operational and approved ancillary offerings.

How long is a UGL valid? A new UGL is valid for three (3) years, with the first year as the period to commence operations. A renewed UGL is valid for two (2) years.

Practical takeaways

• A UGL consolidates multiple PAGCOR-approved game offerings into one license with a single validity period, instead of maintaining separate SGLs.
• A new UGL runs for three (3) years, with operations required to commence within the first year; renewals run for two (2) years.
• Electronic Bingo Games and Electronic Casino Games are Mandatory Game Offerings; removing either permanently disqualifies the operator from holding a UGL.
• Conversion from SGLs requires PAGCOR Board approval, and PCD is posted per gaming venue, not per game offering.
• Existing SGL holders may credit Php100,000.00 for every complete and unexpired year remaining on each valid SGL, subject to PAGCOR validation.

Primary sources

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

Regulatory Framework for the Issuance of Gaming License for the Establishment of Gaming VenuesOpen in Law LibraryDownload PDF

Annex B (Article on the Unified Gaming License) - Regulatory Framework for the Issuance of Gaming License for the Establishment of Gaming Venue 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.