PAGCOR's License Freeze Continues. Here's the Legal Risk Hiding in the Gray Market.

What happened

PAGCOR chairman and CEO Alejandro Tengco told legislators at a House Committee on Appropriations hearing that the regulator has no immediate plans to lift its moratorium on new online gaming licenses, in place since a board resolution on March 1, 2024. "For now, I want the whole industry to consolidate," Tengco said, as reported by Philstar and FocusGN. "So that the weak can leave, and when it consolidates, we will decide if we will issue licenses next time." The number of licensed online gaming operators has already fallen. Tengco also disclosed that PAGCOR has identified license holders keeping accreditations idle specifically to sell them, and said the regulator is taking active steps to remove those entities from the market.

The freeze sits alongside real fiscal pressure at PAGCOR itself. First-half 2026 net income fell 85.3% year-on-year to ₱1.58 billion, and PAGCOR's full-year 2026 net income is projected to drop 91% to ₱1.66 billion, from ₱17.47 billion in 2025. Tengco attributed the weaker performance in significant part to the delinking of e-wallets from online gambling platforms, saying gaming activity dropped by roughly 40% once that convenience disappeared, alongside broader consumer caution tied to Middle East conflict.

Why it matters

A freeze with no defined end condition functions differently than a temporary pause. Tengco's language, deciding whether to resume "next time," with no criteria attached, effectively makes this indefinite policy rather than a bridge to a known future state. Combined with PAGCOR's own minimum fee floor, which Arden Consult's analysis puts at more than 60% of licensed operators currently running below the required revenue benchmark, the regulator is running two simultaneous instruments of contraction: a cap on new entrants, and financial pressure pushing existing weaker operators out. That's a managed reduction in the size of the licensed market, not organic attrition PAGCOR is simply observing.

Separately, a gray market has formed around the resulting scarcity, worth understanding precisely. With no new licenses available, existing accreditations are reportedly changing hands informally for between $3 million and $15 million. Arden Consult has flagged a specific, serious legal problem with that gray market: a PAGCOR gaming accreditation is a permit or privilege, not a contract or property right, and does not create a vested right under Philippine law. That means these gray-market sales may not constitute a legally valid transfer of anything at all, buyers could be paying seven-figure premiums for an accreditation that PAGCOR retains full authority to simply not recognize as transferred.

For operators who already hold one of the current licenses and have the capital to weather this period, the freeze functions as genuine protection, no new entrant can undercut on price or acquisition spend, and distressed competitors are exiting at the same time. That window has a natural endpoint once consolidation settles into a stable, smaller operator base, and Tengco's own comments suggest PAGCOR intends to hold this position for a while yet.

What to watch

Any PAGCOR action against dormant licensees identified as holding accreditations for resale. Tengco specifically flagged this group for removal, watch for confirmed cancellations, which would both shrink the operator count further and potentially undercut the gray resale market's already questionable legal footing.