Regulatory AlertsPhilippines: crypto & digital assets regulation
Partially regulatedDual-regime: BSP moratorium on VASPs; SEC CASP Rules govern crypto-assets
- Lead regulator
- Bangko Sentral ng Pilipinas (BSP) & Securities and Exchange Commission (SEC)
- Core law
- SEC Rules on Crypto-Asset Service Providers (2025) & BSP Circulars
- Entry capital
- PHP 100m (SEC CASP)
- Approval timeline
- —
- Customer assets
- Licensed custodian required; segregation mandated
- Data protection
- Data Privacy Act 2012 · National Privacy Commission (NPC)
- Sandbox
- No
The Philippines operates a dual regulatory framework. The BSP maintains a moratorium on issuing new Virtual Asset Service Provider (VASP) licenses, focusing on existing entities and banking interfaces. Simultaneously, the SEC established a comprehensive licensing regime for Crypto-Asset Service Providers (CASPs) under the 2025 CASP Rules, treating crypto-assets as financial products. New market entrants must navigate the SEC's licensing path for asset services, while banking connections remain strictly supervised by the BSP.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Exchange / trading platform | LicenceCASPs License[1][2] SEC CASP Rules classify crypto-assets as financial products requiring licensing. | PHP 100m | — | SEC |
| Custody of client assets | LicenceCASPs License[1][2] Custody is a core CASP function under SEC rules; robust cybersecurity required. | PHP 100m | — | SEC |
| Token issuance / public offering | LicenceCASPs License[1] Issuance is regulated under SEC CASP Rules as a financial product offering. | PHP 100m | — | SEC |
| Broker-dealer / OTC desk | LicenceCASPs License[1] Broker-dealer activities fall under CASP licensing for crypto-asset services. | PHP 100m | — | SEC |
| Stablecoin issuance | Uncertainverify with regulator No specific stablecoin regime identified; likely treated as CASP or EMI. | — | — | — |
| Crypto payments acceptance | LicenceVASP Registration (Moratorium)[3] BSP moratorium on new VASP licenses; existing VASPs supervised for payments. | — | — | BSP |
| Mining / staking services | Uncertainverify with regulator Not explicitly addressed in provided documents. | — | — | — |
| Advisory / portfolio management | LicenceCASPs License[1] Advisory services regarding crypto-assets are covered by CASP Rules. | PHP 100m | — | SEC |
New — what changed recently
- 2026-06-05M-2026-023: Coin/Token Listing Guidelines — BSP mandates robust due diligence and accreditation for listing virtual assets by VASPs.[4]
- 2026-03-17CL-2026-013: Revocation of Zybi Tech Licenses — BSP enforced final revocation of EMI-NBFI and VASP registrations for non-compliance.[5]
- 2025-08-29M-2025-031: Continued VASP Moratorium — BSP extended moratorium on new VASP licenses citing consumer protection concerns.[3]
- 2025-05-30SEC CASP Rules & Guidelines — SEC established licensing framework for CASPs with PHP 100m capital requirement.[1][2]
Market-entry checklist
- 1Secure SEC CASP LicenseApply for CASP license with PHP 100m paid-up capital and robust cybersecurity plan.
- 2Establish BSP Banking LinkPartner with BSP-supervised banks for fiat on/off ramps under strict due diligence.
- 3Implement AML/CFT FrameworkAdopt BSP and SEC AML standards, including customer due diligence and reporting.
- 4Register with NPCComply with Data Privacy Act 2012 for all user data handling and protection.
Sources
- SEC Rules on Crypto-Asset Service Providers (SEC CASP Rules) · 2025-05-30
- SEC Guidelines on the Operations of Crypto-Asset Service Providers (SEC CASP Guidelines) · 2025-05-30
- M-2025-031: Continued Enforcement of the Moratorium on the Issuance of New Licenses for VASP · 2025-08-29
- M-2026-023: Coin/Token Listing Guidelines · 2026-06-05
- CL-2026-013: Revocation of EMI-NBFI License and Cancellation of VASP and OPS Certificates for Zybi Tech, Inc. · 2026-03-17