Philippines’ minimum guaranteed fee framed as market correction, not revenue tool: lawyer | AGB
Summary
The Philippines’ new minimum guaranteed fee (MGF) for licensed gaming system administrators (GSAs) is intended as a market‑cleaning measure rather than a pure revenue grab, according to legal analysis by Tonet Quiogue of Arden Consult. PAGCOR’s December 2025 memorandum requires all 65 GSAs to pay a fixed monthly fee from 1 April 2026, irrespective of actual revenues, with higher minimums for e‑casino operators and lower thresholds for non‑casino operators.
The two‑tier tariffs start at PHP9 million monthly for e‑casino GSAs (rising to PHP10.5 million by October 2026) and PHP3 million for non‑casino GSAs (rising to PHP4 million). Industry data indicate only around 25 operators currently generate the scale to naturally cover those floors, so the measure is expected to push inactive or low‑substance licence holders to disclose, consolidate, or exit.
Crucially, the memorandum contains a so‑called “coming out” provision (Section J) requiring underperforming operators to seek Board‑level extensions and explain their position — forcing transparency and Board scrutiny rather than quiet underreporting.
Key Points
- PAGCOR will enforce a monthly MGF from 1 April 2026 for all 65 licensed GSAs, regardless of revenues.
- E‑casino GSAs: PHP9m/month initially, rising to PHP10.5m by October 2026; non‑casino GSAs: PHP3m → PHP4m.
- Arden Consult analysis finds only ~25 operators currently meet the PHP30m monthly GGR threshold that would naturally cover the e‑casino minimum.
- Section J of the memorandum forces struggling operators to seek formal Board approvals for extensions — exposing low‑substance licences to scrutiny.
- The MGF complements 2025 measures (Anti‑POGO Act, B2B supplier accreditation, stronger KYC, ad restrictions) to institutionalise a regulated onshore market and push consolidation.
Why should I read this?
Short version: if you run, invest in, advise or work with Philippine iGaming, this is essential. The MGF tells you who can realistically stay in market, who will be forced to explain themselves — and where deals, exits and consolidations are likely to happen. It’s not tax theatre: it’s a regulatory stress test that will remake the sector fast. Read it so you’re not caught offside by deadlines, board approvals and tighter enforcement.