Regulatory AlertsPhilippines: fintech & payments regulation
RegulatedBSP regulates payments/EMI; SEC regulates crypto; strict licensing for MSBs and VASPs
- Lead regulator
- Bangko Sentral ng Pilipinas (BSP)
- Also involved
- SEC (crypto/CASPs) · AMLC (AML/CFT supervision)
- Core law
- BSP Circular No. 1191 (MORPS) & Circular No. 1206 (MORNBFI-M)
- Entry capital
- PHP 50,000,000 (EMI-NBFI)
- Approval timeline
- 3-6 months for EMI-NBFI; 1-3 months for MSB registration
- Customer assets
- Segregated trust accounts required for EMI funds
- Data protection
- Data Privacy Act of 2012 · National Privacy Commission (NPC)
- Sandbox
- Yes - Regulatory Sandbox
The Philippines maintains a strict, dual-regulator framework for fintech. The Bangko Sentral ng Pilipinas (BSP) is the primary supervisor for all payment systems, electronic money issuers (EMIs), and money service businesses (MSBs), including remittance and foreign exchange. The Securities and Exchange Commission (SEC) regulates crypto-asset service providers (CASPs) under the SEC CASP Rules. The regulatory environment is tightening, with the BSP enforcing strict licensing for MSBs and maintaining a moratorium on new VASP licenses, while the SEC has recently formalized its crypto oversight.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | LicenceOperator of Payment System (OPS) Requires OPS registration; merchant acceptance needs separate MAL | — | — | BSP |
| E-money & wallet issuance | LicenceEMI-NBFI License Moratorium lifted Dec 2024; strict capital and governance rules apply | PHP 50,000,000 | — | BSP |
| Domestic money transfer | LicenceMoney Service Business (MSB) Registration Domestic remittance falls under MSB rules; strict enforcement active | — | — | BSP |
| Cross-border remittance | LicenceMoney Service Business (MSB) Registration Cross-border remittance is a regulated MSB activity under BSP | — | — | BSP |
| Agent network | LicenceMoney Service Business (MSB) Registration Agent networks must be registered as MSBs or partners of licensed MSBs | — | — | BSP |
| Open banking / account information | Uncertainverify with regulator No specific open banking framework; relies on general payment rules | — | — | — |
| Foreign-exchange services | LicenceMoney Service Business (MSB) Registration Money changing and FX dealing require MSB registration with BSP | — | — | BSP |
New — what changed recently
- 2026-06-17BSP Circular No. 1238 — Amended NRPS framework to mandate fair, market-based pricing for merchant payments and lift InstaPay/PESONet fee moratorium.
- 2025-08-29BSP Memorandum M-2025-031 — Enforced continued moratorium on issuing new VASP licenses citing consumer protection concerns.
- 2025-05-30SEC CASP Rules — Established licensing framework for crypto-asset service providers with PHP 100m minimum capital.
- 2024-12-15BSP Lifting of EMI-NBFI Moratorium — Lifted moratorium on new EMI-NBFI applications to promote digital payments and financial inclusion.
Market-entry checklist
- 1Register as MSB or EMI with BSPApply for Money Service Business registration or EMI-NBFI license depending on activity scope.
- 2Meet PHP 50m EMI CapitalEnsure PHP 50,000,000 paid-up capital for Electronic Money Issuer applications.
- 3Implement AML/CFT ControlsAdopt strict AML/CFT frameworks as mandated by BSP Memorandum M-2026-017.
- 4Register with SEC for CryptoIf offering crypto services, register as a CASP with SEC and meet PHP 100m capital.
- 5Obtain Merchant Acquisition LicenseSecure Merchant Acquisition License (MAL) if engaging in merchant payment acceptance.