Any companies looking to delay or avoid accreditation by Philippine gaming regulator PAGCOR under its new regulatory framework for B2B suppliers are taking a huge regulatory and commercial risk, according to specialist gaming law firm Arden Consult, with operational bans and reputational damage among the likely outcomes.
The warning follows a memo issued by PAGCOR in October outlining details of the new framework for suppliers to the domestic online gaming industry, and a follow-up memo issued in late January imposing strict compliance deadlines.
The new regulations require all B2B suppliers to operators of online gaming services in the Philippines to be fully accredited by no later than 31 March 2026, after which time they will be deemed unauthorized.
According to a new analysis paper by Arden Consult’s CEO and Head of Regulatory and Compliance, Marie Antonette “Tonet” B. Quiogue, any suggestion that PAGCOR might delay enforcement or offer some leeway to those with existing presence in the market have by now been emphatically dispelled.
“At this stage, any B2B provider still hoping to avoid or delay accreditation is running out of excuses – and time,” Tonet explained. “PAGCOR’s firm deadlines and recent actions mean that, come April 2026, unaccredited providers will simply have no official pathway to operate. The consequences of non-compliance are both regulatory and commercial.”
As noted in the analysis paper, PAGCOR has made it “abundantly clear” that it will not hesitate to declare unaccredited services illegal and order them shut down, with systems from non-accredited providers to be deemed “unauthorized” after the deadline.
“Practically speaking, if a provider hasn’t secured accreditation, their games could be pulled from platforms or their software switched off by the operators under PAGCOR’s direction,” Tonet said. “We can expect PAGCOR to issue cease-and-desist letters to any operator still using an unaccredited vendor, as indicated by the required supplier lists. This is not a drill – it’s an enforcement mechanism that puts both the operator and the provider at risk if ignored.”
While operators and aggregators are likely to activate compliance clauses against any suppliers that remain unaccredited, effectively allowing them to suspend or terminate contracts with any vendor that doesn’t meet the accreditation requirement, of greater concern to some suppliers may be potential reputational damage.
“Being sanctioned or dropped for non-compliance can tarnish a company’s image in other jurisdictions too [because] gaming is a global industry, and regulators talk to each other,” Tonet added. “A firm that ignores one jurisdiction’s rules might find itself under greater scrutiny elsewhere. Conversely, those that proactively comply stand to strengthen their credibility. We have seen that accredited status in the Philippines can be touted in business discussions, demonstrating a commitment to regulatory adherence. That can only help in an era where compliance records are as important as product quality.”
One notable early trend, Arden Consult’s analysis observes, is that most major international and publicly-listed gaming suppliers have moved quickly to gain accreditation since the framework was first announced.
Global gaming supplier Light & Wonder even hosted a symposium for its Philippine-based customers during the 2025 IAG EXPO in Manila after becoming the country’s first international accredited systems aggregator and game content provider licensed by PAGCOR.
According to Arden Consult, gaining early accreditation “signaled to operators that [Light & Wonder] are low-risk, approved vendors”.
The law firm added that it is clear the industry’s largest platform providers, game studios and payment firms “did not wait around; they saw the writing on the wall and filed their applications ahead of the pack” in order to gain peace of mind”.
Others, however, took a “wait-and-see” approach – perhaps hoping that the rules might be delayed, enforcement might be uneven or that continued operations could proceed without immediate regulatory engagement. A lack of experience operating in closely supervised jurisdictions or hesitancy over the cost of potentially establishing a Philippines base have also been touted as reasons some companies paused, although Arden notes that there remain some more cost-effective means of maintaining a market presence such as utilizing an approved aggregator or distributor.
Either way, “any lingering doubts about enforcement … should now be firmly dispelled,” Tonet said.
“The January 2026 memorandum removes ambiguity: PAGCOR is enforcing the framework through operators and licensed entities themselves. By requiring operators to submit comprehensive lists of their B2B providers and signaling the use of cease-and-desist orders against unaccredited suppliers, the regulator has made clear that reliance on operator discretion or regulatory inertia is no longer viable.
“Continued use of non-compliant vendors now directly exposes operators to regulatory risk. This firm stance has triggered a noticeable surge in applications and compliance inquiries in recent weeks, as even previously hesitant providers move to regularize their position in anticipation of full enforcement.”
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