Signal Spotlight · Philippine crypto and iGaming, payment infrastructure
What happened
The Bangko Sentral ng Pilipinas, under Governor Eli M. Remolona Jr., has circulated a draft circular proposing a twelve-month freeze on new Operator of Payment Systems (OPS) applications, alongside amendments to the Manual of Regulations for Payment Systems targeting what the draft calls “layered merchant arrangements,” multi-tiered payment setups where third-party aggregators sit between local acquiring banks and the actual underlying platform, as reported by BitPinas, Cryptopolitan, and CryptoTimes. Under Section 1003.2(e) of the proposed circular, virtual asset service providers, online gambling operators, casinos, adult content platforms, and money service businesses would be required to operate only through direct merchant arrangements, no intermediary layer between the platform and the bank.
The mechanism being closed is specific: offshore platforms without a Philippine license have been routing deposits through QR Ph aggregators, letting a Filipino user scan a standard QR code through their existing e-wallet or bank app while a third party handles settlement and, in some cases, fiat-to-crypto conversion behind the scenes. That structure let offshore operators reach local users without ever holding a local license themselves.
The draft also proposes a National QR Code Merchant Database, recording every QR Ph merchant’s identity, ownership, and sanctions status. Existing licensed virtual asset providers, including Coins.ph, PDAX, Maya Philippines, Moneybees Forex, and UnionBank, remain authorized but move into a high-risk merchant classification carrying tighter scrutiny. Supervised institutions would get six months to audit every existing merchant relationship, and additional time beyond that to fix or terminate any arrangement that doesn’t meet the new structure.
Why it matters
QR Ph is one of the most frictionless deposit channels available to Filipino consumers, working across every major e-wallet and bank app without a card. That’s exactly what made it attractive to platforms trying to reach local users without local licensing, and exactly why closing this specific workaround matters more than a generic tightening would. Offshore gambling and crypto platforms lose their cheapest, lowest-friction local funding channel if this draft is finalized as written.
This sits alongside, but is a separate document from, BSP’s earlier and still-unfinished push toward dedicated online gambling payment safeguards, first proposed in mid-2025 and still in draft form as of BSP’s most recent public update. Different circular, same underlying direction: BSP is treating online gambling payment flows as a distinct risk category requiring its own rules, not something existing frameworks already adequately cover. Seen together with PAGCOR’s own recent moves, its consumer verification app, its enforcement action against Casino Plus over unapproved promotion, this is now a third, independent data point showing multiple regulatory bodies converging on payment and marketing-adjacent gambling risk from different angles at the same time.
For licensed operators, the practical effect is a structural advantage that doesn’t require doing anything new. As offshore platforms lose their easiest local funding channel, the relative cost of acquiring and retaining Filipino users through unlicensed channels rises, while compliant, already-licensed operators see no equivalent new friction. For any operator still routing deposits through a QR aggregator via a third-party intermediary, the exposure is immediate: the draft doesn’t distinguish between platforms with good intentions and bad ones, only between direct merchant arrangements and layered ones.
What to watch
The consultation window and finalization timeline. This is a draft, not yet in force. Watch for the close of the public comment period and any BSP circular formally adopting these provisions, plausible before year-end given the pace of BSP’s recent gambling-and-crypto-adjacent rulemaking.
How GCash, Maya, and other licensed aggregators respond. Their updated terms of service or public guidance will show how enforcement actually works at the transaction level, whether screening happens automatically or requires merchant-level self-certification.
Whether PAGCOR references these QR restrictions directly in its own enforcement communications. BSP payment-rail rules and PAGCOR operator enforcement have moved in parallel before, and joint or cross-referenced action would confirm this is coordinated regulatory strategy, not two agencies moving independently toward a similar conclusion.
What this means for exchanges and platforms
Audit every QR Ph-based payment arrangement in your current stack now, before the draft is finalized. If any aggregator relationship involves a layered structure, funds passing through an intermediary rather than a direct merchant arrangement, that’s the specific pattern this draft targets, regardless of whether your own platform holds a valid BSP license. Document your aggregator due diligence now, since the twelve-month OPS licensing freeze means switching to an alternative licensed aggregator later, if your current one falls short, will not be a simple or fast option.
What this means for compliance
Map every QR-based payment channel in your current stack and confirm each aggregator has a documented BSP license and an on-file compliance review. Treat this as a genuine deadline-driven review, not a wait-and-see item, given how little room the licensing freeze leaves to correct course later if a gap surfaces after the rules are final.
What this means for industry bodies
BSP’s combination of a licensing freeze with targeted structural restrictions on layered payment arrangements signals coordinated tightening, not isolated rulemaking. Industry associations have a real opening to engage the consultation process directly, particularly to ensure draft language distinguishes clearly between legitimate licensed operators using standard aggregator relationships and the specific layered structures offshore platforms use to evade licensing. How precisely that line gets drawn will determine how much compliance friction falls on the licensed industry versus the gray-market operators this draft is actually aimed at.