Market consolidation expected
The policy is expected to trigger significant consolidation. Quiogue predicts that some operators will surrender licences as the regulatory environment no longer matches their original business model. For existing licensees, the implications are clear, she argues: scale up, form compliant partnerships, or exit the market.
In her analysis, the minimum guaranteed fee is ultimately about determining which operators deserve to remain licensed, rather than extracting higher tax payments. Operators unable to meet the minimum are required to engage transparently with PAGCOR — a safeguard designed to support market sustainability rather than allow regulatory drift. If enforcement is applied consistently, Quiogue expects the post-2026 market to be smaller, more resilient, and easier to defend from a regulatory standpoint.
Others may seek investors or partners, though she cautioned that any ownership changes require prior PAGCOR Board approval.
‘We are aware of ‘consultants’ and intermediaries attempting to broker deals involving licences, platforms, or beneficial ownership interests as if these were freely transferable assets. They are not,’ she warned. ‘There is no concept of sublicensing in the Philippine iGaming framework — and history has shown what happens when that line is blurred.’
The minimum guaranteed fee works in tandem with PAGCOR’s broader 2025 regulatory architecture, including a B2B accreditation framework implemented in October that requires all third-party gaming suppliers to be vetted and accredited by March 31st, 2026.
2025 as institutionalization, not prohibition
The MGF announcement came in the same month Congress enacted Republic Act No. 12312, the Anti-Offshore Gaming Operator Act of 2025, which codified the executive branch’s POGO ban and imposed criminal penalties.
Yet 2025 should not be remembered primarily as a year of prohibition, Quioque argues, but as the year the Philippines institutionalized onshore online gaming. While the Anti-POGO Act closed one chapter, PAGCOR’s series of measures – from advertising restrictions to supplier accreditation to the minimum fee – formed what she describes as “the opening blueprint for a regulated onshore market.”
Central to that blueprint is responsible gaming, which evolved from rhetoric into enforceable architecture. Following Senate hearings in mid-2025 that included testimony from parents of a teenager who died by suicide after accumulating gambling debts, PAGCOR Chairman Tengco made harm reduction the condition for the industry’s political survival.
‘Responsible gaming became not just the moral response, but the commercial one: the only path by which the industry remains politically sustainable, socially tolerable, and investable,’ Quiogue observed.
PAGCOR subsequently mandated stricter Know-Your-Customer (KYC) protocols, minimum deposit and bet thresholds, the removal of all out-of-home gaming advertisements, and the delinking of gaming mini-apps from e-wallet platforms. Violations have drawn substantial fines and, in at least one case, license cancellation.
‘Safeguards are no longer optional ‘best practices.’ They are enforceable obligations, backed by real consequences,’ Quiogue wrote. ‘The result is a market beginning to behave like regulated markets do: where player protection is not a public relations layer, but a compliance standard that shapes product design and operations.’
The lawyer noted that while enforcement will prove critical in 2026, the regulatory shift has already made the Philippine market ‘legible to experienced, internationally regulated gaming companies’ seeking clear rules and consistent oversight.
‘Global operators do not enter chaotic markets,” she stated. “They enter markets with clear rules, consistent enforcement, and regulators that demonstrate competence and resolve.’
Dingnews.com 06/01/2026