Under PAGCOR’s system, online B2B companies that serve licensed Internet operations must seek full accreditation by March 31, 2026. After that, their services, impacted by the lack of accreditation, can be considered “unauthorized,” enabling the authority to demand cessation from operators using these services.
What this changes in practice is not the date itself, but the practice around that date. Instead, emphasis has fallen on the operator’s reporting. This involves sending over a list of suppliers, which allows the regulator to cross-match those who are accredited and those who are not. And if unaccredited ones are identified within the system, then there can be cease and desist actions against this operator relationship – that is, the relationship with the operator that puts the vendor in the market.
Arden Consult Warns the “Wait It Out” Approach Can Backfire
According to Arden Consult, a legal advisory firm focused on helping companies navigate licensing and compliance in Phillipines, the window is narrowing for any would-be supplier who hopes that the market will be lenient on any extensions. Commentaries from the firm’s leadership that are related to PAGCOR’s October presentation and the follow-up from late January indicate that there is little basis on which one can assume leniency after April.
The effect of switching off a given supplier is not contained within the confines of a given game launch. Operators stand to be deprived of the ability to use library content, tools, or integrations overnight. This means the focus does not fall on the suppliers; hence, a defensive approach by the licensed businesses emerges even before the deadline.
Commercial Damage May Hit Faster Than Any Formal Sanction
Long before the regulators get involved, however, the contracts between the operator and the suppliers may. For many contracts, especially operator contracts with suppliers, the agreements have “compliance” provisions that allow suspension or termination in the event a supplier is no longer in regulatory compliance. As a result, a supplier that doesn’t secure accreditation may see its access to revenue removed in just a matter of years.
There is, of course, spillover risk as well. In a global industry where files move around, and everyone compares notes, being blacklisted in one of the regulated jurisdictions could cause difficulty elsewhere, when the original event was “only” a failure to comply with local regulation.
Early Accreditation Has Become a Market Signal
The framework is already influencing supplier behavior. The framework is cited in how public early movers are using it to demonstrate their credentials in engagement discussions. An example is Light & Wonder, who were cited as the first international systems aggregator/content supplier to be accredited by PAGCOR in 2025, alongside other industry activities such as the IAG EXPO in Manila.
However, for new entrants or smaller ones, Arden has identified another option where the operation through an accredited aggregator or distributor may also be considered. That again depends on the accredited entity being the accountable party within the framework.
Expert Takeaways
The new marketplace message is binary: be an accredited and safe-to-use player within the existing regulatory framework by March 31, 2026, or be a risk to be avoided at all costs by the operator. Perhaps the most likely outcome is that the space becomes a more limited supplier spectrum, more reliance on accredited aggregator/distributor models, and more stringent procurement controls from licensees. Compliance is not simply a secondary agenda but now an enabler of uptime.
