BSP's Draft Rules Close the QR Ph Workaround, and Freeze New Competition in the Same Document

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.