Stablecoin issuer / redeemer in Philippines
Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.
Stablecoin issuer is conditionally permitted in Philippines with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- VASP/BSP registration — issuers must register as VASPs under BSP Circular 1108 and maintain PHP 100M minimum paid-up capital (SEC CASP requirement) with physical incorporation in the Philippines
- Strict compliance with AML procedures is mandatory under AMLC oversight
- Crypto asset service providers (CASPs) must register with SEC and submit regular reports to the SEC and the AMLC with detailed documentation 30 days prior to any activity
- Issuers must report operations to BSP on an ongoing basis
- Issuers must publish proof-of-reserve reports and conduct regular audits
- Consumer protection rules under BSP require full redeemability at 1:1 peg with reserves in domestic bank accounts
Key Restrictions
- New VASP licenses are frozen indefinitely as of 2025, prioritizing existing licensees — a new entrant likely cannot obtain a license outside the sandbox
- Pilots must operate under BSP Regulatory Sandbox Framework (as Coins.ph's PHPC did, exiting sandbox June 2025)
- 60% Filipino ownership requirement may apply
- Issuers must maintain 1:1 backing with cash and cash equivalents in Philippine bank accounts via compliant banks
- Algorithmic (uncollateralized) stablecoins face no specific rules but heightened risk scrutiny from BSP
- Stablecoins are not considered fiat or e-money but are permitted under BSP-supervised VASP regimes, not under the e-money licensing framework
Key Risks
- VASP license moratorium may be a hard barrier to entry — only existing licensees or sandbox participants can operate
- SEC may classify a stablecoin as a security under Section 3 SRC if marketed with profit expectations, shifting oversight to SEC and creating dual-regulator complexity
- No standalone CGT framework; crypto gains treated as ordinary income (progressive rates 0-35% individuals, 25% corporations) with 12% VAT on goods/services sold for crypto
- Upcoming CARF implementation (2027-2028) adds future reporting burden and tax transparency risk
- BSP and SEC have overlapping jurisdiction — issuer may need both VASP license and SEC CASP registration (PHP 100M capital each)
- No specific stablecoin legislation — regulatory framework is unfolding via pilots, leaving ambiguity on reserve segregation, custody, and bankruptcy remoteness
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
SEC Philippines — Securities token oversight, warnings against unlicensed offerings
BSP Circular 1108 (2021) — VASP licensing framework
VASP: VASP License from BSP (Circular 1108/2021). PHP 50M (~$900K USD) minimum capitalization. 6-12 months. BSP imposed moratorium on new VASP licenses in 2022 to assess existing licensees; partially lifted 2024. Coins.ph and PDAX are major licensed operators. 60% Filipino ownership may apply.
Stablecoins are not considered fiat or sovereign currency but are permitted under BSP-supervised VASP regimes.
They are not explicitly classified as e-money or payment tokens; regulation is unfolding via BSP pilots and VASP rules rather than e-money laws.
Potentially securities under Section 3 of the Securities Regulation Code (SRC) if they involve investment contracts with profit expectations; purely pegged, collateral-backed, or algorithmic stablecoins without profit elements fall outside SRC and default to BSP oversight.
Oversight splits: BSP handles custody, exchanges, on/off-ramps, and payment roles via Circular 1108; Securities and Exchange Commission (SEC) governs issuance, marketing, and trading under its Crypto-Asset Service Provider (CASP) regime.
Issuers must register as VASPs with BSP, maintaining PHP 100 million minimum paid-up capital (SEC CASP), adequate reserves, cybersecurity, and a local office.
New VASP licenses are frozen indefinitely as of 2025, prioritizing existing licensees.
Pilots operate in BSP's Regulatory Sandbox Framework, as with Coins.ph's PHPC approval on May 9, 2024 (exited sandbox June 2025).
1:1 backing with cash and cash equivalents in Philippine bank accounts, managed via compliant banks.
Issuers must publish proof-of-reserve reports, conduct regular audits, and report operations to BSP.
Full redeemability at 1:1 peg ensured by reserves in domestic accounts, protecting holder rights under BSP consumer protection rules.
Crypto asset service providers (CASPs) must register with the Philippine Securities and Exchange Commission (SEC) and maintain a minimum capital of ₱100 million with physical incorporation in the Philippines
Strict compliance with anti-money laundering (AML) procedures is mandatory
CASPs must submit regular reports to the SEC and the AML Council with detailed documentation 30 days prior to any activity
No specific rules mentioned; algorithmic (uncollateralized) stablecoins likely not deemed securities under SRC due to lacking profit expectations or collateral, falling under general VASP/BSP oversight with heightened risk scrutiny.
Evidence fact ph.tax not found (may have been renamed).
Crypto Asset Service Providers (CASPs) must register with SEC (Memorandum Circular Nos. 4 & 5), maintain ₱100M capital, comply with AML/KYC, and submit reports to SEC/AML Council (https://www.sec.gov.ph/ for SEC regs; no direct BIR URL in results).
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a stablecoin issuer must operate via the BSP sandbox or as an existing-licensee VASP (with PHP 100M minimum capital, SEC CASP registration, 1:1 cash reserves in domestic accounts, proof-of-reserve audits, and full redeemability), but the indefinite VASP license moratorium makes new entry infeasible outside the sandbox pilot pathway.
Questions this verdict aims to answer
- What e-money or banking license is required to issue?
- What reserve composition, segregation, and audit rules apply?
- What redemption rights must be granted to holders?
- Are foreign-issued stablecoins permitted for use locally?