The Philippines’ planned monthly “minimum guaranteed fee” (MGF) – to be paid by accredited and operating “gaming system administrators” (GSAs) – aims to eliminate online gaming operators that simply seek “licences of convenience”, suggests industry lawyer Marie Antonette Quiogue.
“In plain terms, Pagcor wants to prevent under-reporting or volatility in revenue shares by settling a baseline that must be paid no matter what,” wrote Ms Quiogue in a Thursday memo on the recently-announced policy.
She added: “It shifts some financial risk onto the operators and guarantees the government a predictable minimum take.”
The new fee regime “dramatically impacts the economics of online gaming operators going forward,” she also suggested.
Ms Quiogue, chief executive and founder of Arden Consult International Pte Ltd, advises the gaming sector in the Philippines.
All Philippines-accredited gaming system administrators must from April 1 this year pay a monthly minimum guaranteed fee, according to a December 15 memo from the Electronic Gaming Licensing Department of the country’s gaming regulator, the Philippine Amusement and Gaming Corp (Pagcor).
Gaming system administrators are Pagcor-accredited operators that run online gaming platforms, Ms Quiogue noted in the memo.
There are two types of GSA: those offering electronic casino games; and those providing only sports betting or other iGaming offerings.
Under a first phase of the new setup, from April 1 to September 30, 2026, electronic casino games providers must pay a minimum PHP9 million (US$153,034) monthly based on a gross gaming revenue (GGR) threshold of at least PHP30 million for the month.
Sports and iBetting providers must pay at least PHP3 million monthly on a GGR threshold over and above PHP15 million in the relevant month.
Under a second phase of the fee regime – from October 1, this year – electronic casino games GSAs must pay a PHP10.5-million monthly minimum when their GGR is above a threshold of PHP35 million for the month.
From the same date, other GSAs are to pay a minimum PHP4 million monthly minimum when their GGR reaches a threshold of PHP20 million in the month.
Reality check for online ops
Ms Quiogue suggested in her policy commentary: “Crucially, this guaranteed fee applies regardless of whether a GSA actually hits those [GGR] benchmark levels in a given month. Pagcor is ensuring it collects a steady stream even in slower periods.”
She also noted: “For operators, this introduces a use-it-or-pay-for-it dynamic: they must generate sufficient play or absorb the cost of the shortfall. The MGF is thus expected to instill greater fiscal discipline.”
She further observed: “If an operator is not misdeclaring but genuinely cannot reach the minimum benchmarks, the MGF compels that operator to confront Pagcor with the reality of its business.”
Ms Quiogue added: “A struggling operator does not get to quietly linger under the threshold while holding a regulatory badge. It must formally approach Pagcor, [to] explain why it cannot meet the required minimums…”
Out of the 65 currently-licensed GSAs, “roughly 40 licensees” would in likelihood fall short of the GGR threshold of the new guaranteed fee requirement, based on Arden’s analysis of the country’s monthly GGR data, Ms Quiogue also suggested.
“Some will surrender their licences… For operators who entered expecting a lower regulatory burden, the calculus has changed,” she wrote.
The lawyer additionally noted: “Others will seek investors or partners. A licence – even an under-performing one – has value, particularly to well-capitalised players [operators] looking to enter the Philippine market without starting from scratch, and especially during a time where a moratorium has been imposed on new applicants.”
Ms Quiogue’s memo asserted said that Pagcor’s move was not a “sudden revenue grab”, but an act of “deliberate” market correction from regulator, to discourage any gaming revenue under-reporting or any acts of misreporting, according to the memo.
The lawyer remarked: “That matters because it draws low-performing licensees out of invisibility. In a market where licensing carries legitimacy, forcing transparency is not a technicality – it is a safeguard.”
“A licence that consistently produces no meaningful revenue is not merely inefficient; it is a risk – because it can become a shell, a vehicle for regulatory arbitrage, or worse, a cover for activities that regulators cannot defend in public,” she also suggested.
