Overview
The Philippines has established one of Southeast Asia's most structured regulatory frameworks for virtual asset service providers. The Bangko Sentral ng Pilipinas (BSP), the country's central bank, oversees VASP registration under BSP Circular No. 1108, Series of 2021, replacing the earlier Circular No. 944, Series of 2017.
The Philippines ranks as the third-largest remittance recipient globally with USD 38.34 billion in inflows in 2024, and approximately 12.79 million projected crypto users by 2026. However, the BSP has imposed an indefinite moratorium on new VASP license applications as of August 2025, with only nine active licensed VASPs currently operating.
The Securities and Exchange Commission (SEC) introduced a separate Crypto Asset Service Provider (CASP) licensing regime in May 2025 for crypto assets classified as securities. The Cagayan Economic Zone Authority (CEZA) also offers an offshore-focused license that does not permit serving Philippine residents.
Regulatory Framework
The Philippine crypto regulatory landscape involves multiple agencies:
Bangko Sentral ng Pilipinas (BSP) is the primary VASP regulator. BSP Circular No. 1108, Series of 2021, amended Section 902-N of the Manual of Regulations for Non-Bank Financial Institutions (MORNBFI) and introduced FATF-aligned definitions, the Travel Rule, enhanced capital requirements, and a mandate to transact only with licensed entities.
Securities and Exchange Commission (SEC) regulates crypto assets deemed securities under SEC Memorandum Circulars No. 04 and No. 05, Series of 2025, overseeing CASPs, ICOs, and security token offerings.
Anti-Money Laundering Council (AMLC) receives transaction reports and exercises enforcement authority. VASPs are covered persons under Republic Act No. 9160 (AMLA).
Cagayan Economic Zone Authority (CEZA) issues the FTSOVC license for offshore-only operations. CEZA licensees cannot serve Philippine residents without a BSP VASP license.
License Types and Categories
The Philippines offers several licensing pathways for crypto businesses:
BSP VASP Registration (Circular 1108)
The primary license for domestic crypto services. VASPs must obtain a Certificate of Authority to Operate as a Money Service Business (MSB). Two capital tiers exist:
- •Non-Custodian VASP -- for exchange and transfer services only
- •VA Custodian VASP -- for entities providing safekeeping and administration of virtual assets
SEC CASP License (2025)
Covers offering crypto assets to the public, operating trading venues, and intermediation. Requires PHP 100 million minimum paid-up capital (approximately USD 1.76 million) for entities dealing with crypto assets that qualify as securities.
CEZA FTSOVC License
Permits international crypto exchange operations from the Cagayan Special Economic Zone. Does not authorize serving Philippine residents.
Capital Requirements
Capital requirements vary by license type and scope of activities:
BSP VASP License:
- •Non-Custodian VASP: PHP 10 million minimum paid-in capital (approximately USD 210,000)
- •VA Custodian VASP: PHP 50 million minimum paid-in capital (approximately USD 1.05 million)
SEC CASP License:
- •Minimum paid-up capital: PHP 100 million in cash or property, excluding crypto assets (approximately USD 1.76 million)
Applicants must demonstrate adequate financial capacity to meet ongoing obligations and provide for foreseeable liabilities. Proof of capitalization is verified through bank certification or audited financial statements submitted during the application process.
For large value payouts exceeding PHP 500,000 (approximately USD 10,500), VASPs must settle via check payment, direct credit to deposit accounts, or electronic fund transfer. Cash payouts above this threshold are not permitted.
Application Process
The BSP VASP application follows a three-stage process with an estimated total timeline of approximately 40 working days (roughly two months), excluding delays for clarification requests:
Stage 1: MSB Approval (~20 working days)
The applicant submits a comprehensive application package to BSP's Financial Supervision Sector, including a detailed business plan with financial projections, Articles of Incorporation, organizational structure and governance policies, list of directors and officers with resumes and beneficial ownership details, AML/CFT policies, cybersecurity framework documentation, risk management and operational manuals, proof of capitalization, and IT architecture diagrams.
Stage 2: Letter of No Objection (~7 working days)
Following initial approval, the BSP issues a Letter of No Objection (LNO). SEC confirmation may also be obtained during this stage.
Stage 3: Certificate of Authority (~13 working days)
Upon securing the LNO, the final Certificate of Authority to Operate as a VASP is issued after on-site or off-site examination by BSP to verify operational readiness and compliance.
A pre-application consultation with BSP's Financial Supervision Sector is recommended before formal submission. If the information provided is inaccurate, incomplete, or inconsistent, BSP may revert with clarification requests that extend the timeline.
Fees and Costs
BSP VASP License Fees:
- •Initial filing fee: PHP 1,000 (approximately USD 21)
- •Registration fee (one-time): PHP 100,000 (approximately USD 2,100)
- •Annual supervision/service fee: PHP 300,000 (approximately USD 6,300)
SEC CASP License Fees:
- •Registration fee: PHP 50,000 (approximately USD 880)
- •Supervision fees: Based on gross revenue, determined by the SEC
- •Late/non-filing penalties: PHP 10,000 plus PHP 500 per day of delay
Additional Costs to Consider:
Beyond regulatory fees, applicants should budget for company incorporation, legal and compliance advisory, IT infrastructure and cybersecurity implementation, external audit, AML/CFT system implementation, office establishment in the Philippines, and ongoing compliance staffing. The corporate income tax rate in the Philippines is 25%.
Permitted Activities
Under the BSP VASP license, registered entities may conduct the following activities:
- •Fiat-to-crypto exchange: Conversion between virtual assets and Philippine pesos or other fiat currencies
- •Crypto-to-crypto exchange: Exchange between one or more forms of virtual assets
- •Virtual asset transfer: Facilitation of VA transfers between wallets and accounts
- •Custody and safekeeping: Administration of virtual assets or instruments enabling control over virtual assets (requires PHP 50 million capitalization)
VASPs are restricted to transacting only with other VASPs, financial institutions, and remittance and transfer companies that are duly authorized and licensed by the appropriate regulatory authorities. This means peer-to-peer transactions with unlicensed counterparties are not permitted.
The BSP does not regulate the issuance or offering of crypto assets as securities. Entities wishing to conduct ICOs, operate security token trading venues, or offer crypto assets to the public as investment products must obtain a separate SEC CASP license.
Compliance and Ongoing Obligations
AML/CFT Requirements:
VASPs are classified as covered persons under the AMLA. They must implement Customer Due Diligence (CDD) for transactions exceeding PHP 5,000, Enhanced Due Diligence (EDD) for transactions or payouts exceeding PHP 500,000, Covered Transaction Reports (CTRs) for all transactions over PHP 500,000 submitted to AMLC, and Suspicious Transaction Reports (STRs) to AMLC. Real-time sanctions screening against PEPs and sanctioned entities is mandatory.
Travel Rule:
For VA transfers of PHP 50,000 or more, VASPs must obtain and transmit originator information (name, account number, address or national ID, date of birth) and beneficiary information (name, account number). All VA transfers are treated as cross-border wire transfers under BSP rules.
Reporting Obligations:
- •External audited financial statements within 120 calendar days after the close of each fiscal year
- •Quarterly transaction volume and value reports within 10 working days after the end of each quarter
Personnel Requirements:
VASPs must appoint a resident Compliance/AML Officer with experience in AML and financial regulation, a Head of IT/Operations, and ensure fit and proper board members overseeing compliance, information security, audit, and anti-money laundering functions. Regular AML/CFT training for all staff is required.
IT and Cybersecurity:
Ongoing obligations include maintaining a cybersecurity framework with multi-factor authentication, conducting regular penetration testing, operating incident response and business continuity/disaster recovery plans, and complying with BSP IT Risk Management regulations.
Advantages of Philippines VASP Licensing
Large Remittance Market:
As the third-largest remittance recipient globally with USD 38.34 billion in inflows in 2024, the Philippines presents a strong use case for crypto-powered cross-border payment solutions. Licensed platforms such as Coins.ph have already established stablecoin corridors to reduce remittance costs for Overseas Filipino Workers (OFWs).
High Crypto Adoption:
The Philippines ranks ninth globally in crypto adoption, with a young, English-speaking, and digitally connected population. Mobile wallet platforms like GCash serve approximately 94 million active users, creating a large addressable market for crypto services.
Growing Fintech Ecosystem:
The BSP Digital Banking Framework has enabled six licensed digital banks, and digital payment adoption has expanded financial inclusion to approximately 70% of the population. This infrastructure creates natural onramps for regulated crypto services.
Regulatory Clarity:
The Philippines offers a well-defined dual regulatory framework with BSP overseeing payments and exchange services while the SEC handles securities-type crypto activities. The framework is FATF-aligned, providing international credibility.
Strategic Regional Position:
The Philippines serves as a gateway to the broader Southeast Asian market, with a common-law influenced legal system and strong demand for cross-border payment innovation.
Important Considerations: Moratorium and Market Access
Indefinite Moratorium on New VASP Applications:
The BSP imposed a moratorium on new VASP license applications effective September 1, 2022, originally for three years. In a memorandum dated August 20, 2025, this moratorium was extended indefinitely, citing heightened risks in the virtual asset market, ongoing consumer protection concerns, and cybercrime threats. The BSP stated the moratorium will be subject to periodic review aligned with industry developments and enhanced monitoring capabilities.
Limited Market Entry Options:
Currently, only existing BSP-supervised financial institutions (BSFIs) that wish to expand operations by offering VASP services may still apply. As of May 2025, only nine active VASPs hold BSP registration: Betur Inc. (Coins.ph), Bloomsolutions Inc., Direct Agent 5 (SurgePay), Maya Philippines Inc., Moneybees Forex Corp., Philippine Digital Asset Exchange (PDAX), TopJuan Technologies Corp., XenRemit Inc., and Union Bank of the Philippines Inc.
SEC Enforcement Actions:
In August 2025, the SEC publicly identified ten unlicensed crypto exchanges operating illegally in the Philippines, including Bybit, OKX, KuCoin, Bitget, and Kraken. Binance was ordered to cease operations in 2024. These enforcement actions signal the regulators' commitment to market discipline.
Alternative Entry Strategies:
Prospective entrants may consider acquiring or partnering with an existing licensed VASP, applying for a CEZA FTSOVC license for offshore-only operations, or pursuing the SEC CASP license for securities-type crypto activities. Any entity serving Philippine residents with exchange or transfer services must hold a BSP VASP license, and operating without one carries significant legal risk.