The Memorandum was released on 7 May by the Philippine Amusement and Gaming Corporation through the Electronic Gaming Licensing Department. It concerns gaming venue operators, gaming system administrators, integrated resort licensees, gaming affiliates, and support service providers.
Incentives Are Now Subject to Close Supervision
Under the new system, cash rebates based on player turnover or deposits are limited to 1.5%, applying only to slots, electronic bingo, numeric games, and sports betting. Casino table games and arcade-type games are not covered by that specific 1.5% turnover/deposit cap.
Operators can also give cash back depending on the player’s net loss. This maximum rate for all types of electronic games is set at 15%. For games not included in the listed categories, PAGCOR’s Electronic Gaming Licensing Department will review the proposed rate by considering the RTP of each game.
Operators Must Submit Program Details First
The directive also changes how these offers are to be approved and documented. Prior to launch, operators must submit a marketing or promotional form to PAGCOR for approval. PAGCOR wants operators to disclose various aspects of their programs, such as:
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Tiers;
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Minimum deposit requirements;
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Wagering rules;
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Rebate or cashback rates;
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Maximum amount;
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Coverage;
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Settlement conditions;
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General terms.
Cash rebates and cashback must be considered as an expense under marketing promotion and shall not be categorized as gaming loss or deducted from GGR computation. In addition, no combination of cash promotions shall result in exceeding the rate limit. Programs launched without prior approval, or above the prescribed rate, may face regulatory action.
There is a transition period for any non-compliant promotions approved prior to this guideline. The program may run up to the end date of its validity as approved or May 15, 2026, whichever is earlier.
Digital Growth Raises Policy Pressure
According to the PAGCOR’s 2025 industry data, the total GGR was PHP396.14 billion. Other licensees, a segment led by electronic games, generated PHP201.12 billion in GGR. The contribution of electronic games alone came in at PHP185.26 billion. These figures show that electronic games have become one of the main revenue drivers in the Philippine market.
This helps explain the newfound focus on incentives. In a fast-growing online sector, sizable cashback incentives can be a tool for user acquisition. Smaller operators may find it difficult to compete in such a manner. The regulator appears to be trying to differentiate between normal promotion and market distortion.
Limiting cashback can be viewed as part of a wider cycle. PAGCOR has already introduced stricter KYC procedures, such as the use of government-issued IDs and live selfies during deposits. The Philippine central bank, Bangko Sentral ng Pilipinas, also ordered e-wallets, banks, and other supervised financial institutions to remove in-app links that redirected users to online gambling platforms in 2025.
The Expert Read
The measure does not amount to a ban on incentives. What the regulator is trying to do is make bonuses more quantifiable and auditable. The next likely challenge for operators will be to ensure compliance discipline. As for the market, the cap might reduce the competition based on bonuses and help shift focus back to products and retention quality.
