Circular No. 1237: Regulations on the Operation of Digital Financial Marketplace and Presentation of Financial Products and Services in Digital Platforms

BANGKO SENTRAL NG PILIPINAS The Monetary Boa d. in its Resolution No. 490 dated 04 June 2026. approved the guidelines for the adopt'on and participation of BSP-supervised Financial Institutions (BSFls)in digital financial marketplaces or digital platforms. These guidelines ecognize the pivotal role of digital platforms in advancing inclusive, customer-cent ic financial ecosystems. Under this framework. BSFls are empowered to offer their proprietary financial products and services while also featuring third-party financial or non-financial products or services that complement their business models. This collaborativ approach enables BSFls to expand operational scale, reach a wider customer base, and deliver a more integrated and tailored customer experience. The Bangko Sentr I, through this framework. fosters an enabling env'roninent that promotes responsible in ovation. ensures robust consumer protection, and up holds the stability of individual BSF s and the financial system. The guidelines articulate supervisory expectations on governa ce and risk management standards, requiring BSFls to effectiveIy manage key risks - including operational. reputation al. Information Technology 11T) and money laundering IML). terrorist financing (TF). and proliferation financ'rig (PF) risks. Moreover. the guideline reinforce adherence to sound consumer protection. market conduc , and data governance standards, including data privacy. sharing and portability. Section, . Section 1161/04-N of the Manual of Regulations for Banks IMORB)/Manual of Regulations for Non ank Financial Institutions (MORNBFl) entitled "Operation of a Digital Financial Marke place and Presentation of Financial Products and Services in Digital Pbrforms, " are he eby added to read, as follows: Subject: OFFICE OFTHE GOVERNOR CIRCULAR No. 1237 Series of 2026 Regula ions on the Operation of Digital Financial Marketplace and Presen at ion of Financial Products and Services in Digital Platforms Section 1.61^04- OPERATION OF A DIGITAL FINANCIAL MARKETPLACE AND PRESENTATION OF FINANCIAL PRODUCTS AND SERVICES IN DIGITAL PLATFORMS Policy stotement. The Bangko Sentral recognizes the emergence of new business models and strategic collaborations that harness digital technologies to drive innovation and deepen financial inclusion. Bangko Sentral-supervised financial institutions (BSFls) are increasingly leveraging digital platforms to expand their reach, enhance customer experience and improve access td financial products or services. Through digital financial marketplaces. customers are empowered to make better and informed financial decisions by giving them access to a broad range of products and services. It is in this light t at the Bangko Sentral provides an enabling regulatory framework that supports the responsible adoption of digital financial marketplaces and the presentation of financial products and services in digital platforms by BSFls. This policy builds upon existing regulatory standards to establish a cohesive framework that integrates sound governance, robust risk management and strong consumer protection. including an effective consent-driven information sharing arrangement consistent with the Open Finance Framework. This policy aims to ensure that attendant risks on digital financial marketplace or other digital platform activities are adequately managed. and consumer interests are

safeguarded. as w 11 as to promote a more inclusive. innovative and collaborative financial system. Scope Grid Appl, objlity. The guidelines in this Section shal apply to a BSFl authorized to operate a digital financial marketplace and to a BSFl as a provider of financial products or services in a digital financial marketplace or other digital platform, The guidelines hav three (3) sub-parts covering: a. BS 10 mark lace operator. A bank or EMI-NBFl may be authorized to operate a digital finan Ial marketplace for the presentation of products or services offered by thir -party providers. as well as the presentation, sale and distribution of its own prod cts or services. The digital financial marketplace shall include at least three (3) providers that are riot affiliated with or part of the BSFl's group or conglomerate. As a digital fin ncial marketplace operator. a bank or EMI-NBFl may allow the presentation o products and services of third-party providers that are not supervised by t e Bangko Sentral. The said bank or EMI-NBFlshallestabl'sh clear guidelines governing the arrangements with said provider/s following the applicable provisions outlined in this Section. Other BSFls' in y be allowed to operate a digital financial marketplace. subject to approval by the Bangko Sentral on a case-by-case basis considering the requirements under this Section. b. BSFI OS fiban 101 service provider. A BSFl may present. display or distribute financial products or services in a digital financial marketplace operated or owned by another BSFl or in a digital platform This shall also cover BSFls in their capacity as bro er, dealer. agent or distributor. as may be allowed under existing laws. rules and egulations. c. General provisions governing the activities of BSFls under items "a " and "b' The provisions under this Section shall cover the online and digital presentation of products and servi es by BSFls. The presentation and/or sale of financial products and services within the physical premises of banks shall be governed by Sec. 1/3 while those presented th ough the BSFl's social media platforms shall be governed by Sec. 150. The presentation of unit investment trust funds IUITFs) in a digital financial marketplace shall be governed by the provisions under this Section, subject to notification requirements under Sec. 4/4/414-Q IUnit Investment Trust Funds) and Sec. 110-T foilstri'bu ion of Trust Products). Definition of terms. The following definitions shall apply for the purpose of this Section: nS t refers o any freely given. specific. informed indication of will, whereby the customer a rees to the collection and processing of personal data. Consent shall be eviden ed by written. electronic or recorded means. It may also be given on behalf of the customer by an agent specifically authorized by the customer to do so, The guidelines under this Sec ion shall likewise be applicable. to the extent relevant. to the operations of NBFls engaged in quasi-banking fu ctions. non stock savings and loan associations INSSLAs). pawnshops. non bank credit card issuers. trust corp rations. other NBFls holding a trust license. and other NBFls that are supervised by the Bangko Sentra!. Page 2 of 17

b. 01'91tal financial marketplace or "marketplace" refers to a web- or app-based platform and/ electronic channel operated by a BSFl that presents and/or directs custom rs to a range of products or services offered by product or service providers, whic should include at least three (3) providers that are not affiliated with or part of the BSFl's group or conglomerate, A web or app based platform and/or electronic channel that only: (i) offers or presents the products or services of the marketplace operator. (ii) lists promotional deals. discounts. or rewards of merchants, (iii) functions as a payment facility or gateway. or (iv) houses government online services without offering products or services from private third-party product or service providers, shall not be considered a marketplace under this Section, When a BSFl operates a digital marketplace which mainly or mostly offers non-financial products or services. the applicability of the requirements under this Section shall be evaluated by the Bangko Sentral on a case-by-case basis. A BSFl may own the digital marketplace platform or may contract third-party provider/s to d velop or maintain the digital platform which it will operate, subject to the outsourcing framework as provided under Sec. 1/21/02-N. c. Digital platform, as used in this Section. broad y refers to a third-party platform typically web- o app-based, which is operated by an entity hereafter referred to as digital platform operator that is neither classified as a marketplace operator under these gu'delines nor is supervised by the Bangko Sentral. that connects users to a variet of products and services. d. Financial data portab re ers to the ability of a customer to access, retrieve. and securely transfer their financial data across financial service providers or platforms. subject to consent and applicable laws. rules and regulations. e. Financial service provider (FSP) refers to an entity under the jurisdiction of the Bangko Sentral. Securities and EXchange Commission (SEC). or the Insurance Commission tic which presents financial products or services in the marketplace or digital plat orm. This includes BSFls, insurance companies, investment companies. agents. brokers. or other financial institutions. Marketplace operator refers to a bank, EMI-NBFl or other BSFl which has the primary respon ibility for the operation. maintenance. and management of the digital financial marketplace; Marketplace participants refer to BSFls that are marketplace operators and FSPs in a marketplac or a digital platform; and Service or product provider ISPP) refers to an entity duly accredited by the marketplace op rator that presents or displays non-financial products or services in a digital financial marketplace. I. Marketplace opera or Activities in o dig tai findnciol ingrketploce. The activities in a digital financial marketplace shal e limited to the presentation or display of the products and services o accred ted FSPs and Spps. as well as the presentation, sale and distribution of the roducts and services of the marketplace operator. The marketplace all enable customers to compare and select products and services from different FSPs/Spps that best meet their needs. To ensure neutrality and impartiality, t e marketplace operator shall not favor affiliate or related Page 3 of 17

companies in the p esentation. comparison, recommendation, or access to products and services in the digital financial marketplace. The marketplace operator shall also d'sclose to custom rs the criteria used to determine the order or sequence in which products and serifi es are presented. The marketplace operator may perform ancillary functions that enhance user experience. operational efficiency and assessment of risks. These may include preliminary screening, initial credit underwriting or pre, assessment of borrowers' creditworthiness. customer identification and verification. or client suitability assessment. among others' The marketplace operator may also act as an intermediary that facilitates the secure. efficient, and compliant payment and settlement of transactions that originated from the marketpl ce. Moreover. the marketplace operator may integrate or connect third-party systems to the marketplace to enable functional it Ies such as purchase, subscription, order taking. request processing, payments, among others, through the marketplace. The processing, approval and consummation of the transaction. however. shall be undertaken by the FSP/Spp. Subject to the con ent of the customer. a marketplace operator may also facilitate the collection. shar rig. or transfer of customer financial data. including activities that support financial d to portability in relation to third-party financial services. subject to assessment of its potential role as open finance participant under Sec. 1541 152-or130-N Guidefines for the Adoption of Open Finance Framework and alignment with sai principles Eligible products grid services. The following products or services may be presented in the di tal financial marketplace: Financial products or services created or distributed by the marketplace operator or its ccredited FSP: Provided, That such financial products or services have been duly authorized or approved by the relevant regulatory authority, as applicable, and/or are part of the powers/authorities of the marketplace operator or SP to distribute/sell. This may include the following: (lI (2) (3) Simple d POSit products: Consume and micro, small and medium enterprises (MsME)loans; Plain va '11a debt securities. and equity securities allowed for public offering/ istribution; Electroni money. payment cards such as cash cards or debit cards; Simple insurance. takaful and other Shari'ah compliant insurance products health maintenance organization (HMO). and pre-need products Provided, That customers will only be redirected to the respectiv providers or intermediaries unless the marketplace operator has obtained the appropriate license from the IC; Collective investment schemes (CIS) or pooled investment funds: Provided, That in the case of UITFs. customers will only be redirected to the providers and that he guidelines in Section 4/4/414-orllO-T shall be observed; and Other fin ncial products or services (4) (5) (6) (7) Non-financial products or services created or distributed by an accredited Spp which complement the marketplace operator's business model or strategies: Provided, Tha such non-financial products or services have been duly authorized by the relevant regulatory authority. as applicable. and/or are part of the powers/au horities of the marketplace operator or Spp to distribute/sell: Provided, further, That products or services associated with gambling activities (e. g. , online c sinos. online betting. electronic gaining. or other forms of gambling/gain rig), or any activities that are riot aligned with the promotion of Page 4 of 17

financial sou driess or well-being of customers, shall riot be displayed or presented in t e marketplace operated by a BSFl, Applicotion for the grunt of outhority to engoge OS o ingrketploce operotor. A BSFl may engage in digital financial marketplace activities as a marketplace operator subject to the approval of the Bangko Sentral and submission of the following documents to the appropriate supervising department of the Bangko Sentral within thirty (30) banking days prior to target date of implementation: a. Application re ter signed by the president or officer of equivalent rank. which shall indicate he intention of the applicant to become a marketplace operator. The applicatio shall be supported by documentation of the business model and ajustification t at the application is aligned with the applicant's business model and strategic irection, including its capacity to address the associated risks from operatin a marketplace; b. Corporate Secretary's certificate on the approval by the board of directors or its equivalent. for he BSFl to engage as a digital financial marketplace operator; Certification si ned by the president or officer of equivalent rank and the chief compliance offcer ICCO) that the applicant has complied with all the prudential criteria presc ibed under Sec. 111^01-N Prudential Criteria), and the requirements for digital financial marketplace operator under this Section; and Such other documents as may be deemed necessary by the Bangko Sentral to evaluate the PPIication Ie. g. , information on risk management system. IT infrastructure onsumer and data protection measures, outsourcing or third￾party arrangements, among others). Processing und icensing fees. Applicants seeking authority to become a marketplace opera or shall pay both processing and licensing fees provided under Sec. 11/1/01-N IProcessing and Li^ensing Fee The processing fee shall be non refundable and shall be paid upon filing of the application to engage as a marketplace operator. The licensing fee shall be immediately charg d upon approval of the application for authority to engage as a marketplace opera or. The assessment and collect'on of fees shall be in accordance wth the guidelines on fees provided in Appendix 1241N-14. Qualifications to engoge OS incrketp, oce operator. Applicants seeking authority to be a marketplac operator shall adhere to the following requirements: Compliance w th all the prudential criteria prescribed under Sec. 11/1/01-N (Pruden ti'o1 Cri eria); Advanced Elec ronic Payments and Financial Services IEPFS) license. subject to the requirem nts provided under Sec. 7011401-N and Append'x 1361 Appendix Q-89 C. Net worth or c in bined capital of at least PI. O billion. computed in accordance with Sec. 12/1402-N and Sec. 702; d. Adequate and eliable information technology (IT) infrastructure and solutions coinmensurate to its digital marketplace operations; Adequate risk management system to identify, measure. monitor and control the risks arising from digital marketplace operations. including sound governance an risk management standards, particularly on IT. cybersecurity. Page 5 of 17

anti-money undering/countering terrorism and proliferation financing IA M L/CT P F I, ata privacy. consumer protection and market conduct, coinmensurat to the digital financial marketplace operations; Approval or Ii ense from the relevant authority/ies Ie, g. , secondary license, insurance bro er/agent or online insurance aggregator license with the IC. broker/dealer cense or registration and/or salesman license with the SEC in case of the off ring of. dealing in and solicitation of securities), as applicable, including the uthority to distribute products or services of Spps in the digital marketplace; Registration s an Operator of Payment System (Ops), subject to the requirements provided under Sec. 502 of the MORPS, as applicable; and Compliance w'th other requirements for a marketplace operator under this Section. Applicants should on duct a self-assessment of compliance with the requirements prior to submitting application to the Bangko Sentral. A Bangko Sentral authorized marketplace ope ator shall continuously comply with the qualification requirements even after the authority has been granted. Any deviation or non-compliance may be a basis for the imposition of appropriate enforcement actions, including evocation of authority to engage as marketplace operator. as warranted Governance Grid monogement of the digitol findnciol incrketploce. The board of directors of the marketplace operator shall be primarily responsible for overseeing the operations and activities of the marketplace. They shall ensure that an effective risk management system is in place to identify. measure, monitor and control the risks associated wit the marketplace operations. In relation to thi , the marketplace operator shall have in place a sound. comprehensive an clearly defined policies, procedures. processes and controls on the operation of a d gital financial marketplace which shall. at a minimum. cover the fo lowing: Formulation. eview and approval of a digital financial marketplace strategy which shall be consistent with the business model and overall strategy of the marketplace operator. The said strategy shall consider the scope of marketplace perations. target customer segments, products and services to be presented in the marketplace. and extent of integration or collaboration with the FSP/ PPs. among others: Governance a an gements and the roles and respons'bilities of the board of directors, sen'or management. internal audit and other relevant units. in re ation to dig'tai marketplace operations. including the level and frequency of board or management reporting; Operations a d internal controls on digital marketplace leg, , cybersecurity controls, fraud management systems and other key controls to protect financial accounts. compliance with data privacy. records retention. business continuity and contingency plans, systems development and maintenance. and risk management system), Mechanisms to support financial data portability sh uld be adopted to ensure that customer-permissioned data can be shared sec rely and with consent. in accordance with Sec. 1541/30-N on the Guidelines for the Adoption of Open Finance Framework; Select on, ac reditation, monitoring and periodic review of FSPs/Spps. The marketplace perator shall exercise due care and diligence in partnering with Page 6 of 17

FSPs/Spps and shall consider the following in the selection, accreditation. and review of FSP ISPPs: Reputa 'on. ownership a rid governance structu re, technical expertise. and operational capability. including robust after-sales service and custom r relationship management: (2) Alignm nt of FSP/Spp's products and services with the marketplace operato 's business model and overall strategy; (3) Financi I performance and condition (e. g. , ongoing viability, outstanding commitments. capital/funding strength. liquidity and operating results including performance of the products or services being offered) as support d by audited financial statements for the last three (3) years' FSPs/Spps with less than three (3) years of operations in the Philippines may provide the available annual financial statements or annual reports duly filed with the SEC or other relevant regulatory authority; Registr on/authority of the FSPs/Spps from its respective regulator includi g the authority to present or distribute products or services in the market lace, as applicable; and (5) Coinpl rice with applicable laws. rules and regulations including the requirements on FSPs/Spps under this Section, as applicable. as well as compliance with the governing agreement. The marketpl ce operator shall ensure periodic monitoring and review of the FSPs/Spps an maintain proper documentation to support that marketplace arrangements have undergone the necessary due diligence and review. This shall include periodic review by the internal audit function or other independent competent units. Such documentation shall be made available upon request by the Bangko Sentral. In case of a cease-and desist order issuance. insolvency or placement under receivership, prohibition from doing business in the Philippines. revocation of license/authority of a particular FSP/Spp. or existence of valid ground/s for suspension or termination based on the agreement. among others, the marketplace operator shall take appropriate measures (e. g. , delisting of the FSP/Spp's products or services from the marketplace platform) in a timely manner Digital mark tplace contract to govern the relationship between the marketplace operator and FSP/Spp, which shall cover the roles and responsibilitie of each party. suspension and termination clauses, fee structure. am rig others, The marketplace operator shall maintain a central record of all d'gital marketplace contracts; and Material outsourcing arrangements of the marketplace operator. as applicable, in relation to t e digital marketplace operations which shall be consistent with the outsourcing guidelines under Sec. 1/21/02-N. BSFl as financial service provider in a digital financial marketplace or other digital platform Present@CIOn or isploy of products or services in o digitol findncio, ingrketp, oce or ot er digitol plotform by o BSFl. A BSFl may present or display products or services in a digital financial marketplace or other digital p at form. subject to the appli able requirements under this Section, Page 7 of 17

BSFls with a Supe isory Assessment Framework (SAFr) composite rating of at least '3", or its equivale may present or display their products or services in a digital financial marketp ace without prior Bangko Sentral approval and notification. Meanwhile, the no ification requirements under this Section shall apply to, i) BSFls with SAFr rating below "3", or its equivalent. that will engage a digital financial marketplace: and ii) all BSFls. regardless of SAFr rating, that will present their products in a digita platform, Notwithstanding t e provisions in this Section. trust entities that will present or display UITFs in a igital financial marketplace shall continue to comply with the notification requirements under Sec. 4/4/414-Q/110. T. Responsibilities of o BSF, OS FSP. The board of directors of a BSFl shall be primarily responsible for the oversight of the presentation or display of products or serv'ces in a digital financial marketplace or other digital platform. They shall ensure that an effective risk management system is in place to identify. measure. morii or and control the risks associated with marketplace or distribution platform activities. In relation to this BSFl shall have in place a sound, comprehensive. and clearly defined policies. procedures. processes and controls on the presentation or display of its products or services in a digital financial marketplace or other digital platform, which shall cover the following at the minimum: a. Roles and responsibilities of the board of directors, senior management and other relevant nit/s; b, Formulation. review and approval of a distribution or marketing strategy which shall be consistent with the business model and overall strategy of the BSFl: Due diligence review of the digital marketplace or digital platform; Arrangement ith a marketplace/digital platform operator supported by a written contract or service level agreement which shall at a minimum contain the following: c. d. (I I (2) (3) (4) Coinple e description of the scope of work to be performed or services to be provided: Fee stru ture; Amendment to and/or termination of contract; Delineat on of responsibilities of the BSFl and the marketplace/digital platform operator consistent with this Section, as applicable. including fines. penalties and accountability for errors. omissions and frauds; Data go ernance covering all data and information shared with both parties. segregation of the data of the BSFl from that of the marketplace/digital platform operator and its other clients, actions that the BSFl may take against the marketplace/digital platform operator for breach of confidentiality or any form of disclosure of confidential informa ion; Disaster ecovery plan and business continuity and contingency plan, Access of internal and/or external auditors to information in relation to the activities contracted; Bangko Sentral access to the digital financial marketplace/platform operato in order to rev'ew certain aspects of its operations when necessary. in relation to the activities/services rendered to the BSFl: Governi g arrangement covering situations where the digital financial marketplace/platform operator further outsources or subcontracts any of the activi ies it has been engaged to perform: (5) (6) (7) (8) (9) Page 8 on7

(10) Reined es to the BSFl in the event of change of ownership. assignment, attachment of assets, insolvency. or receivership of the digital financial marke lace/ platform operator; and Provisi allowing the BSFl to cancel the contract by contractual notice ofdism ssalor extraordinary notice of cancellation as may be required by the Ba gko Sentral. (11) Due diligence on performonce review. Prior to entering into an arrangement with a marketplac or digital platform operator. a BSFl shall conduct appropriate due diligence review to assess the capability of the marketplace or d gital platform operator in performing the service to be contracted. BSFls shall only deal with marketplace and/o digital platform operators that are duly licensed or registered with the relevant regulatory authority. As part of due diligence, a BSFl shall consider both qualitative and quantitative factors that may affect the performance of the contracted service. such as reputation, financial condition and results of operation for the last three (3) years, risk management practices, technical expertise and compliance with applicable laws. rules and regulations. A BSFl shall undertake a periodic performance review of the marketplace/digital platform that it engages. The results of the review shall be documented and reported to the appropriate board or management level A BSFl shall also maintain a complete and up to-date database or record of all its marketplace or dig al platform arrangements. which shall be made available to the Bangko Sentral upon request General Provisions Credit underwrit, g grid client suitobility CSSessment. The marketplace participants shall ensure that the products or services presented and/or recommended are appropriate and consider the needs, goals. and risk profile of consumers, In this r spect. the marketplace operator and BSFl-FSP shall observe the guidelines on credit underwriting under Sec. 1431/22-N. and client suitability assessment under Sec. 4/4/414-or612/612-Q. and Appendix 861Q-49. as applicable. The marketplace operator shall put in place a mechanism to require other FSPs/Spps which are riot supervised by the Bangko Sentral to observe credit underwriting and/or client suitability assessment consistent with the rules and regulations as may be prescribed by their respective regulatory authority. The conduct of p eliminary screening, underwriting, or suitability assessment shall look into the cust me r's creditworthiness, financial condition, understanding of, tolerance for and capacity to manage various risks. particularly for investment products, The marketplace operator may conduct such preliminary assessments in accordance with i s policies, procedures. and arrangements with the FSP/Spp: Provided, That said arrangement with the FSP/Spp is formally documented and expressly requires adherence to all applicable laws and regulations. including those on data privacy, consumer protection, and other relevant rules within the context of marketplace or digi al platform activities, The FSP may rely on the underwriting and su'tability assessme ts undertaken by the marketplace operator, provided that such assessments are consistent with the FSp's own parameters and criteria The FSp/Spp shall remain ultima ely responsible for the final approval or rejection of customers availing the produc s or services presented in the marketplace. Data generated from proming. underwriting, and suitability assessments conducted within the marketp ace shall be made available to custome s in a portable format Page 9 of 17

upon their reques provided that such requests relate exclusively to their own data. as part of the data haring arrangement between the marketplace operator and the FS PIS P p. Consumer protec ion. Marketplace participants shall adhere to applicable laws, rules and regulat ns on consumer protection in relation to digital marketplace activities. Marketp ace operator and BSFl-FSP shall comply with the provisions of Republic Act (RA N0 11765 or the "Financial P oducts and Services Consumer Protection Act", as implemented under Part Ten/Part Ten of the Q-Regulations on Financial Consume Protection Regulations. In addition. mark tplace operator and/or BSFl-FSP shall be responsible for the following: Disclosure and Transparency. Marketplace participants shall ensure that consumers are rovided with adequate. accurate and accessible information to enable them to make informed decisions on products and services offered or presented in th marketplace. As such. information on the products and services including the urpose. features, terms and conditions. pricing or any cost associated, risk and benefits, among others, are presented in a clear. simple. and understandable manner in the marketplace p atform or delivery channels and contracts. This should also include disclosure by the marketplace operator of the criteria used to determine the order or sequence in which products and services are presented. consistent with the neutrality and impartiality requirements under this Sect'on. Moreover. customers should be informed of their rights to financial data portability, including the means by which they can request, retrieve. or shar their financial data with other FSP/Spps. subject to consent and security safeguards. Marketplace p rticipants shall also comply with the applicable disclosure requirements under Sec. 3061414/4/4-Q. Moreover, the marketp ace operator shall have a me hanism in place or undertake appropriate measures to require FSPs/Spps whic are not supervised by the Bangko Sentral to comply with the applicable disc OSure requirements as may be prescribed by their respective regulatory auth rity/ies. There should b appropriate measures to clearly distinguish the marketplace operator from t e FSP/Spp in engaging with clients, As such. the roles of the marketplace operator and FSP/Spp shall be clearly communicated to the customers. Moreover. the terms and conditions on the use of the platform shall include. among others, the disclosure and prominent display of the identity of the FSP/Spp. ncludjng information that the FSP/Spp has the ultimate responsibility o er the products or services presented in the marketplace. An FSP/Spp that is acting as a distributor or agent shall also comply with the applicable discl sure requirements under this Section. Moreover. the te ms and conditions on the use of the platform may also include grounds for deactivation or suspension of user account. This may include ij engagement of users in fraudulent transactions or unlawful activities. ii) submission o users of information and documents found to be fictitious. or iii)issuance of c urt order. directive from government agency, or other instances requiring deactivation or suspension of user account. as may be provided under the marketplac operator's policy. Fair treatment. The marketplace participants shall have a mechanism in place to ensure that f ir treatment is observed in areas including, among others, the setting of term and conditions. customer service. marketing and advertising, determination o customer eligibility, underwriting. and servicing and collection. Page 10 of 17

There shall be no discr'minatory treatment between different categories of consumers on he basis of race or ethnic origin, religion. or such other attributes or profiles whe used as the sole basis to deny access to products or services. To ensure the effective and inclusive adoption of digital marketplace, consumers must be provided with the knowledge. skills, and confidence to use and evaluate the information presented in a digital marketplace platform. In this regard, marketplace p rticipants may implement financial and digital literacy programs that educate consumers on the benefits and risks of using a digital marketplace platform. c. Effective recourse. Marketplace participants shall establish an effective complaint handling and redress mechanism to ensure that any complaints that may arise from digital marketplace activities are resolved in a fair. timely and efficient manner. Customer complaints. inquiries or requests that relate to the platform and/or activities conducted within the marketplace shall be addressed or resolved by the marketplace operator. Meanwhile. those that relate to the products or services presented at the marketplace shall be addressed or resolved by the FSPs/Spps. Marketplace participants shall make available multiple accessible touchpoints for lodging complaints, inquiries or requests. In the event that a customer complaint remains unresolved within the turn around time a may be agreed by the marketplace operator and FSPs/Spps, the marketplace o erator shall have the right to intervene and take appropriate actions. as may be necessary, to protect the interest of the customers. Product bundl rig. The marketp ace participants shall likewise recognize the rights of customers to choose from a range of products and services that are well-suited to t eir needs. requirements and preferences. The customer shall be free to choose roducts or services and shall be under no obligation to avail of products or se 'ces presented by particular FSP/Spp that are tied or bundled to the marketplac operator's own product or service. or vice-versa. That is, access to one product r service must not be conditional on purchasing another product or service from articujar FSPs/Spps. d Moreover. the marketplace participants that present bundled products and services shall es ablish a mechanism to ensure that customers are provided with adequate information on market-based prices of products or services included in the bundle to enable them to compare and make informed decision. fing-off policy. The marketplace participants shall establish a cooling-off policy on specifc products and services to allow customers to consider the costs and risks of a financial product or service and to permit customers to terminate. withdraw or re urn the product/service contract within the coo ing-off period. consistent with the requirements under RA No. 11765. their implementing rules and regulations. and the rules and guidelines on financial consumer protection under Part Ten Part Ten of the Q-Regulations. Marketplace participants shall ensure that cus omers are adequately informed of said cooling-off policy. The marketplace perator shall undertake appropriate measures to requ're that FSPs/Spps riot supervised by the Bangko Sentral to comply with the applicable consumer protection standards under RA No. 11765. R. A. No. 11967 or the "Internet Transactions Act 0 2023", RA No. 8792 or the "Electronic Commerce Act of 2000". and RA No. 7394 r the "Consumer Act of the Philippines" and their respective implementing rules and regulations. as well as the applicable regulations or Page n of 17

guidelines on con umer protection issued by the FSP/Spps' respective regulatory authority. Coinplionce with RA No. 72070 or the '^rin-Findnciol Account Scornming Act 1:4FASA, " und its inprementing rules und regulations. Marketplace participants shall comply with t e applicable provisions of the AFASA and its implementing rules and regulations. This includes. but is not limited to. the implementation of robust account authentication protocols. real-time fraud detection and monitoring systems. and other preventive controls. Participants shall also observe provisions on fund restitution. including liability for unauthorized transactions. and the temporary holding of funds in o1ved in disputed transactions. Doto governance und consent monogement. Data plays a critical role in a digital marketplace as I facilitates better understanding of customer needs and preferences. In thi regard. marketplace participants. as users and/or providers of data in the in a ketplace. shall adopt robust safeguards in ensuring the privacy/confidentia ity. integrity. security and availability of customer data, inc uding personal data. Marketplace participants shall ensure that a data governance policy is in place to manage the handling, storage, security. processing. and sharing of customer data. including consent management. The responsibilities of the marketplace operator and FSP/Spp on data governance and accountability shall be embedded in their formal agreements and contracts, A privacy notice containing the essential information on the specific processing activity shall also be clearly communicated to the customer, des ribing how personal data will be collected. processed, stored. used. shared. and protected/secured. among others' Moreover, marketplace operators shall also ensure mechanisms are in place to support financial data portability. allowing customers to access and transfer their financial information to other FSPs/Spps. The data governance policy shall. at the minimum cover the following: a, Data privacy and protection. Compliance with the data privacy and data protection laws. including but not limited to RA No. 11765IFinancial Products and Services Consumer Protection Act). RA No. 10173IThe Data Privacy Act of 2012), and their implementing rules and regulations. The marketplace participants shall ensure that customers are given the opportunity to exercise their rights as data subjects, which include the right to be informed about data-sharing, including the parties with whom their personal data will be disc OSed to or shared with. and the right to refuse the sharing of their personal data to a third-party including related companies of banks, among others. Marketplace participants shall also ensure that consent for financial data sharing and portability is explicitly captured. and that data is shared only for purposes authorized by the customer. In case of any significant change or amendment to the information previously provided to the data subject in a consent form. ivacy notice. or similar communication, the customer shall also be notified and Iven an opportunity to object and/or withdraw consent. As such, the marketplac participants shall ensure that there is an effective mechanism on consent in a agement. For customer ermissioned and consent-based personal data processing, marketplace p rticipants shall employ reasonable and appropriate consent management s sterns which have the capability of tracking. enforcing, and documenting c risent preferences regarding personal data processing act'vities. These systems must be compliant with the provisions of the Data Privacy Act of Page 12 o

2012. its impl meriting rules and regulations. and issuances of the National Privacy Coinm ssion on consent. The marketplace participants shall ensure that the processing of customer's data is adequate. re evant. suitable, necessary. and riot excessive in relation to the declared and specified purpose. Personal data shall be processed only to the extent necessary, and only where the purpose cannot reasonably be achieved by less intrusive means. Moreover, the marketplace participants sha I ensure that when customer's personal data is shared to the marketplace operator or across authorized FSPs/Spps, the data is transferred securely. with consent and used in a manner consistent with the relevant laws. rules and regulations; b. Data access a d con , Marketplace participants may access shared data only as needed to c rry out their responsibilities and shall not include access to the other party's data. except as expressly provided in their agreement. Data-sharing and access arrangements shall be designed and implemented in a manner that will not provid undue advantage or favor any entity or otherwise distort fair competition in he marketplace: c. Data security. strong and reliable IT system must be established to protect the confidentiality. security. accuracy. and integrity of customer's personal data, especially throughout the personal data collection. storage and sharing process, as well as the conduct of periodic trainings on data privacy and cybersecurity: and d. Data confidentiality. Customer consent must be obtained before sharing customer's per on al information with third parties Ii. e. , partner providers, and related companies of banks) and providing customers the ability to manage their data preferen es. including an opt-out mechanism on data sharing arrangements. ny modifications or changes to the data sharing arrangements must also be documented in writing and confirmed by both parties; Findnciol Doto P rtobility Endblement. Marketplace operators shall establish technical and operational capabilities to support financial data portabi ity in accordance with the principles under Sec. 1541/30-N, as far as practicable. This may include providing customer dashboards for consent management, secure APIS for data transmission. and procedures for the customer-initiated transfer of financial data to other regu ated entities or authorized third-party providers of products or services. Customer due din ence (COD) Grid coinplionce with AML/'CTPF lows, rules und regulotions. The marketplace participants shall establish controls to ensure their adherence to the relevant provisions of Part Nine/Part Nine of the Q-Regulations (Anti-Money Laundering and Combating the F1hancing of Terrorism Pegubti'on SII Part Six of the N-Regulations of the MORNBFl, Anti-Money Laundering Regulations) or the Anti. Money aundering Act (AMLA). as amended. and its related laws, rules, and regulations. The marketplace operator shall establish mechanisms to enjoin FSPs/Spps that are not supervised by the Bangko Sentral but are covered persons under the AMLA. a amended. to comply with the AML/'CTPF laws, as well as rules and regulations iss ed by the relevant regulatory authority. The marketplace operator may conduct the initial CDD based on its existing policies or agreement with the FSPs/Spps, subject to compliance with the applicable AML/CTPF laws, rules and regulations. Notwithstanding the initial CDD conduc ed by the marketplace operator, the ultimate responsib'lity for conducting the CDD ies w'th the covered person relying on the third party. Moreover. in cases where he Page, 3 of, 7

customer is preli inarily assessed as high risk by the marketplace operator, the FSPs/Spps that are covered persons shall conduct separate enhanced due diligence. Said FSPs/Spps sh 11 have the sole and final authority to decide on the transaction. The FSP/Spp shal assume full responsibility for associated risks and potential regulatory implic tions on transactions allowed by them within the digital marketplace following their conduct of an independent enhanced due diligence. Notificotion req ifements. BSFls shall notify the appropriate supervising department of the angko Sentralwithin ten (10) banking days from approval by the BSFl's board of dir ctors or equivalent body. as follows: a The marketpla e operator to submit a notification in case of any material change/s in the digital financial marketplace strategy or scope leg. , significant shift in the business model. target market, technological or operational infrastructure of the digital marketplace), presentation of new financial and/or non-financial p oducts or services in the marketplace. and partnerships with new merchants/partners that have not been previously approved/authorized; and BSFls with a SAFr rating below '3". or its equivalent. that will present or display products or services in a digital financial marketplace, and all BSFls. regardless of SAFr rating, that will engage digital platform operators, to submit a notification on the BSFl's decision to undertake such activity, together with the following documents: Notifica on letter signed by the president or officer of equivalent rank, indicatin that the BSFl will engage in digital financial marketplace or distributi n arrangement, including the details of the said arrangement/s (e. g. . products/services that will be presented. profile of the digital marketpl ce/digital platform operator. among others); Corporat secretary's certificate on the approval by the BSFl's board of directors (or equivalent management committee in the case of foreign bank branches) to engage in digital financial marketplace/distribution activities as provider of products/services: and Certificat on signed by the president or officer of equivalent rank and the CCO, cer ify, ing that the BSFl has (1) no outstanding major supervisory finding/c ricern related to the proposed digital marketplace activities; and (ii) conducted a due diligence review showing that the selected digital marketplace or platform operator meets the minimum requirements under this Section. The said certification shall be supported by adequate justificati n on its ability to manage the associated risks with d'gital marketpl ce/distribution activities. Record retention. Documents evidencing compliance with this Section shall be retained by the in a ketplace participants for a period of not less than five (5) years unless otherwise required by law or other rules and regulations. or as directed by the Bangko Sentral or ther regulatory agency/body to be retained for a longer period. Moreover. records which are the subject of. or are pertinent to, the conduct of audit. examination. inves 19ation or legal proceedings shall be retained and preserved beyond the five-ye r retention period until such time that the audit, examination. investigation or case has been fully resolved. decided or terminated with finality by the Bangko Sentral or other relevant regulatory agency/body, or a court. Supervisory enfor ement octions. Consistent with Sec, 002 1002-N. the Bangko Sentral may, without prejudice to the imposition of sanctions by other relevant regulatory authorit , deploy enforcement actions to BSFls that engage in digital financial marketpl ce activities as marketplace operator and/or FSP to promote Page 14 on7

adherence to the requirements set forth in this Section and bring about timely corrective actions. The Bangko Sentral may, among others, issue directives to improve the inari gement of risks associated with digital financial marketplace activities or impose sanctions to limit the level of or suspend any business activity that poses or in a pose adverse effects on the safety or soundness of the BSFl. Monetary and non-monetary sanctions, as provided under existing laws. Bangko Sentral rules and regulations, may likewise be imposed on the BSFl and/or its directors, officers and/or employees concerned. Section 2, Secti0 1/11/01-N of the MORB/MORNBFl on the Type of License of Permissible Activities are ereby amended to include and classify the authority of BSFls to engage in digital financial marketplace operations as Type A license. and shall now read. as follows: In LICENSING XXX Enforcement ctions, x Type of Licen e of Permissible Activities'. The type of license attached to permissible activiti s of Bangko Sentral supervised financial institutions (BSFls) shall be as follows: Type of License A B C xx FCD o eration of Rural Bank IRB)/Coo Bank O e at ion of a di it al financial market lace xx xx XXX 101. N GRANT OF LI ENSES AND AUTHORITIES XXX Permissible Activity Enforcement ctions. x Type of license of permissible octivities". The type of license attached to permissible activiti s of Bangko Sentral supervised financial institutions (BSFls) shall be as follows: Type of License A Section 3. Section 44/4/4-Q of the MORB/MORNBF on Unit Investment Trust Funds is hereby amended to read as follows: Permissible Activi Trust and Other Fiducia Business O elation of a di it al financial market lace xXX xxx B C Related Sections xxx xxx Sec. 1/6 XXx xxx XXX " Applications filed with the Bang o Sentrai xxx Related Sections xXX Sec. I 04- N xxx xxx Page 15 of 17

4/4/414-Q Unit Inv stment Trust Funds XXX U, TF Market, g personnel. " The trustee shall ensure that there are board approved policies rid procedures covering the following: For purposes of this Section. a UITF may be sold within the bank premises by a bank employee be origing to the same financial conglomerate as the trustee, subject to the provision of he cross-selling framework. A TE may also present UITFs in a digital financial marketplace. subject to the p ovisions of Sec. 16/104-N. A TE that intends to present any or all of its UITFs in a d gital financial in rketplace shall notify the appropriate supervis rig department of the BSP of this intention, A notification shall be made for each digital marketplace in which the TE intends to present its UITFs. The submission shall include the following: O ) Notification letter signed by the president of the TE or an officer of equivalent rank. statin the intention to present the TE's UITFs in a specified digital financial marketplace; and (2) Corporate Secretary's certificate on the approval of the board of directors for the TE to engage the said marketplace for UITF presentation. To ensure the ompetence and integrity of all duly designated UITF Marketing Personnel all personnel involved in the sale of UITF must be certified as UITF Marketing Personn I through a UITF Certification Program (UCP) administered by a reputable financia services industry association/organization acceptable to the Bangko Sentral. xx Section 4. Section 10-T of the MORNBFl on Distribution of Trust Products is hereby amended to read, as follows: 110-T Distribution f Trust Products XXX Third-porty Di tributors of U, TFs. x a. b. The distribution of UITFs inside bank premises shall be governed by the p ovisions on cross selling under Sec. 1/3 of the MORB. The use of a se ice provider, such as an electronic platform, to offer UITFs shall riot be considered as a distribution arrangement, It shall be subject to the outsourcing framework provided under Sec. 1/2-T, However. a TC may present UITFs in a digital financial marketplace. subject to the requirements under Sec. 1/6 of the MORB. XXX XXX A TC that intends to present any or all of its UITFs in a digital financial marketplace shall otify the appropriate supervising department of he Bangko Sentral of this inten 'on. A notification shall be made for each digital marketplace Page 16 of 17

in which the TC intends to present its UITFs. The submission shall include the following: (1) (2) Notification letter signed by the president of the TC, stating the intention to present the TC's UITFs in a specified digital financial marketplace: and Corporate Secretary's certificate on the approval of the board of directors for the TC o engage the said marketplace for UITF presentation. Section 5. Applic bility to other nori. bank financial institutions. The provisions under Section I and 3 of t is Circular shall likewise be applicable, to the extent relevant, to the ope ations of NBFls engaged in quasi-banking functions. non-stock savings and loan associat'ons INSSLAs). pawnshops, non-bank credit card issuers, trust corporations. -other NBFls holding a trust license. and other NBFls supervised by the Bangko Sentral Section 6, Transitory Provision. Marketplace participants in an existing digital financial marketplace and digital platforms must comply with the applicable requirements provided herein within one (1) year from the effectivity of this Circular. This includes the submission of application by existing digital financial marketplace operators to the appropriate supervising department of the Bangko Sentral for the grant of authority to engage as marketplace operator. Existing marketplace operators are also provided two (2) years from the effectivity of this Circular to on board in the digital financial marketplace at least three (3) product or service providers that are ot affiliated with or part of the BSFl's group or conglomerate The prohibition o online gambling/gaining- elated products and services shall take effect upon the effectivity of this Circular. notwithstanding the one-year transitory period. This transitory provision shall be incorporated as a footnote to Section 1161/04-N of the MORB/MORNBFl on t e Regulations on the Operation of Digital F1hanc!'o1 Marketplace and Presentation of Financial Products and Services In Digital Platforms. Section 7. This C rcular shall take effect fifteen (15) calendar days following its publication ether in the Official Gazette orin a newspaper of general circulation. I^. June 2026 FOR THE MONETARY BOARD: ^;;'Mf;;M:;^- Governor Page 17 of ,7