Overview
The Philippines runs two parallel crypto licensing regimes. The Bangko Sentral ng Pilipinas (BSP) has licensed Virtual Asset Service Providers (VASPs) since BSP Circular No. 1108 took effect on 26 January 2021 — but BSP has frozen new VASP licences since September 2022 and extended that moratorium indefinitely from 1 September 2025. The Securities and Exchange Commission (SEC) issued the new CASP Rules (MC 04-2025 and Operational Guidelines MC 05-2025) on 30 May 2025, effective 5 July 2025, capturing crypto-asset service providers offering tokens that are securities or conducting public offering or marketing.
The 2026 reality: a new BSP VASP file is not being accepted. The viable routes for new entrants are SEC CASP, or acquisition of one of the 13 BSP-licensed VASPs (PDAX, Coins.ph, Maya, UnionBank, GCrypto and others) on the BSP register.
Regulators
The BSP licences VASPs under BSP Circular No. 1108, amending the Manual of Regulations for Non-Bank Financial Institutions. Activities in scope include exchange between VAs and fiat, exchange between VAs, transfer of VAs, safekeeping or administration of VAs and provision of financial services related to issuer offers. The SEC licences CASPs under the SEC Rules on Crypto-Asset Service Providers (MC 04 / 05-2025). An exchange dealing in crypto-assets that are securities and converting to or from PHP needs both BSP VASP and SEC CASP registration.
Track 1 — BSP VASP under Circular 1108
Capital tiers
| Tier | Activities | Min paid-up capital |
|---|---|---|
| Type A | With safekeeping and/or administration of VAs (custody) | PHP 50,000,000 |
| Type B | Without safekeeping/administration of VAs | PHP 10,000,000 |
BSP Circular 1108 also requires fit-and-proper directors and senior officers, an AML/CFT programme aligned with AMLC rules and BSP issuances, the Travel Rule, technology-risk management, and a robust customer-protection framework.
BSP moratorium — extended indefinitely
BSP imposed a 3-year freeze on new VASP licences from 1 September 2022. The freeze was extended indefinitely by BSP Memorandum dated 20 August 2025, effective from 1 September 2025, citing consumer-protection and cybercrime concerns. The Monetary Board approved the extension and BSP indicated it will “periodically review” in line with industry and global trends. New BSP VASP applications are not being accepted.
Practical market-entry options:
- Acquire an existing BSP-licensed VASP — the BSP register currently lists about 13 VASPs.
- Operate under SEC CASP if the activities fall under SEC remit and do not require BSP licensure (e.g., security-token offerings without PHP fiat conversion).
- Wait for the periodic review — and stage a file ready for the moment the freeze lifts.
Track 2 — SEC CASP under MC 04-2025 and 05-2025
SEC Memorandum Circular No. 04, Series of 2025 (Rules on Crypto-Asset Service Providers) and No. 05, Series of 2025 (Operational Guidelines) were issued on 30 May 2025 and took effect on 5 July 2025.
Key requirements
- Entity: SEC-registered domestic stock corporation.
- Minimum paid-up capital: PHP 100,000,000 in cash or property — excluding crypto-assets.
- Physical office in the Philippines.
- Robust AML/CFT programme aligned with AMLC rules.
- Public offering and marketing of crypto-assets subject to CASP Rules — disclosures, risk warnings, no misleading marketing.
High-level checklist
- Domestic stock corporation registered with the SEC; physical office in the Philippines.
- Capital satisfied: PHP 10M (BSP Type B), PHP 50M (BSP Type A), or PHP 100M (SEC CASP).
- Fit-and-proper directors and key officers; controlling-shareholder review.
- AML/CFT programme aligned with AMLC, BSP Manual or SEC CASP rules.
- Travel Rule integration for VA transfers.
- Customer-protection framework — disclosures, complaints, suitability assessment.
- Technology-risk management framework, custody architecture, segregation.
- Three-year business plan, financial projections, AML risk assessment.
- File application — BSP via the Manual of Regulations process (currently frozen) or SEC via the new CASP rules.
- Post-licensing: ongoing reporting, periodic on-site inspections, AMLC compliance.
Process and timeline
| Step | BSP VASP | SEC CASP |
|---|---|---|
| Pre-application — entity, capital, AML programme | 3–6 months | 4–6 months |
| Regulator review | 6–12+ months (frozen) | 5–12+ months (settling) |
| Total realistic | Frozen | 9–18+ months |
Taxation
- Corporate income tax: 25% (domestic corporations), or 20% under the CREATE Act for small domestic corporations with net taxable income ≤ PHP 5M and total assets ≤ PHP 100M.
- VAT: 12% — may apply to crypto services depending on classification.
- No bespoke crypto tax regime; the BIR treats crypto gains under general income-tax principles.
FAQ
Can I file a new BSP VASP application?
No. BSP extended the moratorium indefinitely from 1 September 2025. The route is acquisition of an existing BSP VASP or SEC CASP if the activity fits.
What capital does SEC CASP require?
PHP 100,000,000 in cash or property excluding crypto-assets.
Are BSP and SEC overlapping?
Sometimes. Crypto-assets that are securities and converted to or from PHP can require both BSP VASP and SEC CASP. Many activities sit cleanly in one regulator's remit.
How does PH compare with neighbours?
For a fresh-start exchange in 2026, Thailand and Malaysia are easier paths than waiting on BSP. Labuan works for offshore profiles.
Will the BSP moratorium lift?
BSP committed to periodic review in line with global trends. There is no public timeline. Plan against it remaining in force, with a contingency to file quickly if it lifts.