Philippines
Retail_Trading_Status
- Analysis ID
- #759
- Version
- Latest
- Created
- 2025-12-12 05:08
- Run
- e23bdbac...
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- Workflow Stage
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Executive Summary
Retail cryptocurrency trading is legal and heavily regulated in the Philippines under a dual-agency framework involving the Bangko Sentral ng Pilipinas (BSP) and the Securities and Exchange Commission (SEC). The BSP regulates payment-focused Virtual Asset Service Providers (VASPs) under Circular No. 1108, while the SEC recently implemented a comprehensive Crypto Asset Service Provider (CASP) framework in May 2025 to oversee trading platforms and securities-like assets. Unregistered offshore exchanges face strict enforcement, including website blocking and removal from app stores, while compliant local entities offer retail access.
Key Pillars
Bangko Sentral ng Pilipinas (BSP) regulates VASPs facilitating transfers, payments, and exchange services.
Securities and Exchange Commission (SEC) oversees Crypto Asset Service Providers (CASPs) and securities-related crypto activities.
Mandatory registration for all crypto exchanges serving Filipino users; offshore entities must establish a local corporation.
Strict Anti-Money Laundering (AMLA) compliance, including the Travel Rule for transactions over PHP 50,000.
Minimum capital requirement of PHP 100 million for SEC-registered CASPs.
Landmark Laws
SEC Rules on Crypto-Asset Service Providers (CASP Rules) (SEC Memorandum Circular No. 4, Series of 2025) - Enacted: 2025-05-30
- Establishes the registration and operational framework for CASPs, requiring a physical office, PHP 100M capital, and strict consumer protection measures. Unregistered entities are banned.
- Source
Guidelines for Virtual Asset Service Providers (VASP) (BSP Circular No. 1108) - Enacted: 2021-01-26
- Amends BSP regulations to cover a broader range of virtual asset activities beyond just exchanges, imposing rigorous AML/CFT, consumer protection, and liquidity requirements.
- Source
Guidelines for Virtual Currency Exchanges (BSP Circular No. 944) - Enacted: 2017-02-06
- The foundational regulation that first recognized virtual currency exchanges as remittance and transfer companies, requiring them to register with the BSP.
- Source
Considerations
Strict enforcement against unregistered offshore exchanges (e.g., Binance, OKX) involves IP blocking and app store removal.
Dual licensing may be required: BSP VASP license for payments/remittance and SEC CASP registration for trading platforms.
Capital gains from crypto trading are subject to tax (up to 15%), and play-to-earn income is taxable as ordinary income.
The 'Travel Rule' is strictly enforced for transactions exceeding PHP 50,000.
A 3-year moratorium on new BSP VASP licenses (started Sept 2022) limited market entry, though the new SEC rules provide a different pathway for trading platforms.
Notes
The analysis reflects the regulatory environment as of December 2025. The '2025' dates in the legislation (SEC Circulars) indicate recent major regulatory updates that have shifted the market from a BSP-centric model to a dual-regulator model with stricter capital requirements.
Remaining Uncertainties
- The exact interplay between the BSP's VASP license and the SEC's CASP license for entities offering both payments and trading is complex and may require further case-by-case clarification.
- Long-term tax reform specifics are still under discussion, specifically whether a flat tax rate for crypto will be legislated.
Detailed Explanation
Detailed Explanation
Retail cryptocurrency trading is legal and heavily regulated in the Philippines under a dual-agency framework involving the Bangko Sentral ng Pilipinas (BSP) and the Securities and Exchange Commission (SEC). The regulatory landscape is defined by two primary pillars: the BSP, which regulates payment-focused Virtual Asset Service Providers (VASPs) under Circular No. 1108, and the SEC, which implemented a comprehensive Crypto Asset Service Provider (CASP) framework in May 2025 to oversee trading platforms and securities-like assets. This structure mandates that all cryptocurrency exchanges serving Filipino users must be registered, with offshore entities required to establish a local corporation. The BSP's framework, initiated by Circular No. 944 in 2017, focuses on virtual currency exchanges as remittance and transfer companies, while the newer SEC CASP Rules establish stringent operational standards for trading platforms. A key aspect of the regulatory environment is strict enforcement against unregistered offshore exchanges, such as Binance and OKX, which face measures including website blocking and removal from app stores. Compliant local entities are therefore the primary means for retail access. The framework imposes rigorous Anti-Money Laundering (AMLA) compliance, including the 'Travel Rule' for transactions exceeding PHP 50,000. Furthermore, capital gains from crypto trading are subject to tax, and play-to-earn income is taxable as ordinary income. The BSP implemented a three-year moratorium on new VASP licenses starting in September 2022, which limited market entry; however, the new SEC rules provide an alternative pathway for trading platforms. Mandatory registration for all crypto exchanges serving Filipino users is a cornerstone of the policy, with the SEC requiring a minimum capital of PHP 100 million for registered CASPs. This dual-regulator model, with recent updates in 2025, represents a significant shift from a BSP-centric approach to a more comprehensive system with stricter capital and consumer protection requirements.
Summary Points
I. Regulatory Status
* Retail cryptocurrency trading is Allowed-Regulated.
* Operates under a dual-agency regulatory framework.
II. Key Regulatory Bodies
* Bangko Sentral ng Pilipinas (BSP): Regulates payment-focused Virtual Asset Service Providers (VASPs).
* Securities and Exchange Commission (SEC): Oversees Crypto Asset Service Providers (CASPs) and securities-related crypto activities.
III. Important Legislation
* SEC Rules on Crypto-Asset Service Providers (CASP Rules) (SEC Memorandum Circular No. 4, Series of 2025)
* Enacted: 2025-05-30
* Establishes a comprehensive registration and operational framework for CASPs.
* Requires a physical office, PHP 100 million capital, and strict consumer protection measures.
* Bans unregistered entities.
* Guidelines for Virtual Asset Service Providers (VASP) (BSP Circular No. 1108)
* Enacted: 2021-01-26
* Amends BSP regulations to cover a broader range of virtual asset activities beyond exchanges.
* Imposes rigorous AML/CFT, consumer protection, and liquidity requirements.
* Guidelines for Virtual Currency Exchanges (BSP Circular No. 944)
* Enacted: 2017-02-06
* The foundational regulation that first recognized virtual currency exchanges as remittance and transfer companies, requiring BSP registration.
IV. Compliance Requirements
* Mandatory registration for all crypto exchanges serving Filipino users.
* Offshore entities must establish a local corporation.
* Strict Anti-Money Laundering (AMLA) compliance, including the Travel Rule for transactions over PHP 50,000.
* Minimum capital requirement of PHP 100 million for SEC-registered CASPs.
* Dual licensing may be required: BSP VASP license for payments/remittance and SEC CASP registration for trading platforms.
* Capital gains from crypto trading are subject to tax (up to 15%).
* Play-to-earn income is taxable as ordinary income.
V. Notable Restrictions or Limitations
* Strict enforcement against unregistered offshore exchanges (e.g., Binance, OKX), including website blocking and removal from app stores.
* A 3-year moratorium on new BSP VASP licenses (started September 2022) has limited market entry.
VI. Recent Developments or Notes
* The regulatory environment reflects updates as of December 2025.
* The '2025' dates in the legislation (SEC Circulars) indicate a recent major shift from a BSP-centric model to a dual-regulator model with stricter capital requirements.
Full Analysis Report
Full Analysis Report
The regulatory landscape for cryptocurrency in the Philippines has matured into a rigorous 'Allowed-Regulated' regime as of late 2025. The framework is characterized by a dual-regulator approach where the Bangko Sentral ng Pilipinas (BSP) oversees payment and remittance aspects, while the Securities and Exchange Commission (SEC) governs trading platforms and investment contracts. This division was solidified with the SEC's issuance of Memorandum Circular Nos. 4 and 5 in May 2025, which established the Crypto Asset Service Provider (CASP) rules. These rules mandate that any platform servicing Filipino users must register as a domestic corporation, maintain a physical office, and hold at least PHP 100 million in paid-up capital.
Prior to the 2025 SEC rules, the BSP was the primary regulator under Circular No. 1108 (2021), which expanded the definition of Virtual Asset Service Providers (VASPs) and imposed strict AML/CFT standards. The BSP maintains a list of licensed VASPs, which includes major local players like PDAX, Coins.ph, and Maya. However, a moratorium on new BSP VASP licenses imposed in 2022 created a bottleneck, which the new SEC framework partially addresses by providing a clear, albeit high-bar, entry for trading-focused entities.
Enforcement has been aggressive and visible. Throughout 2024 and 2025, the SEC, in collaboration with the National Telecommunications Commission (NTC), actively blocked access to unregistered offshore exchanges, including high-profile targets like Binance, OKX, and Bybit. The regulator's stance is clear: 'No license, no operation.' This has forced retail traders to migrate to locally licensed platforms or risk losing access to their funds on blocked offshore sites.
Taxation remains a critical compliance pillar. The Bureau of Internal Revenue (BIR) treats cryptocurrency as a property/asset, subjecting trading gains to capital gains tax and income from activities like play-to-earn gaming to ordinary income tax. While specific crypto-tax legislation is still evolving to provide finer clarity, the obligation to report and pay taxes on crypto income is explicitly stated by government agencies.
The regulatory landscape for cryptocurrency in the Philippines has matured into a rigorous 'Allowed-Regulated' regime as of late 2025. The framework is characterized by a dual-regulator approach where the Bangko Sentral ng Pilipinas (BSP) oversees payment and remittance aspects, while the Securities and Exchange Commission (SEC) governs trading platforms and investment contracts. This division was solidified with the SEC's issuance of Memorandum Circular Nos. 4 and 5 in May 2025, which established the Crypto Asset Service Provider (CASP) rules. These rules mandate that any platform servicing Filipino users must register as a domestic corporation, maintain a physical office, and hold at least PHP 100 million in paid-up capital. Prior to the 2025 SEC rules, the BSP was the primary regulator under Circular No. 1108 (2021), which expanded the definition of Virtual Asset Service Providers (VASPs) and imposed strict AML/CFT standards. The BSP maintains a list of licensed VASPs, which includes major local players like PDAX, Coins.ph, and Maya. However, a moratorium on new BSP VASP licenses imposed in 2022 created a bottleneck, which the new SEC framework partially addresses by providing a clear, albeit high-bar, entry for trading-focused entities. Enforcement has been aggressive and visible. Throughout 2024 and 2025, the SEC, in collaboration with the National Telecommunications Commission (NTC), actively blocked access to unregistered offshore exchanges, including high-profile targets like Binance, OKX, and Bybit. The regulator's stance is clear: 'No license, no operation.' This has forced retail traders to migrate to locally licensed platforms or risk losing access to their funds on blocked offshore sites. Taxation remains a critical compliance pillar. The Bureau of Internal Revenue (BIR) treats cryptocurrency as a property/asset, subjecting trading gains to capital gains tax and income from activities like play-to-earn gaming to ordinary income tax. While specific crypto-tax legislation is still evolving to provide finer clarity, the obligation to report and pay taxes on crypto income is explicitly stated by government agencies.
Source Evidence
Primary and secondary sources cited in this analysis
"Virtual Asset Service Provider (VASP) refers to any entity that offers services or engages in activities that provide facility for the transfer or exchange of VA."
"The CASP Rules do not prohibit cryptocurrency trading or investment. Rather, they require platforms to obtain the appropriate registration and licenses before offering their services in the Philippines."
"List of Virtual Asset Service Providers (VASPs) with Certificate of Authority."
"Since July 5, 2025, unregistered crypto exchanges have been blocked, fined, and forced out of the Philippine market."
"Under the new framework, CASPs will need to be physically incorporated in the Philippines and maintain a minimum paid-up capital of ₱100 million."
Web Sources (8)
Sources discovered via web search grounding
Search queries used (5)
- Philippines crypto tax rules 2024
- SEC Philippines crypto regulation securities 2025
- Bangko Sentral ng Pilipinas list of licensed virtual asset service providers 2024
- BSP Circular No. 1108 summary
- Philippines crypto regulation retail trading status 2024 2025
https://fintechnews.ph/67175/crypto/sec-philippines-crypto-asset-service-provider-casps-rules/
https://www.bworldonline.com/corporate/2025/08/18/692095/sec-says-no-ban-on-crypto-trading/
https://www.aureadalaw.com/post/a-new-era-for-crypto-in-the-philippines-sec-tightens-rules-on-crypto-asset-service-providers-casps
https://www.arabictrader.com/en/news/cryptocurrencies/185726/the-philippines-tightens-regulation-of-the-cryptocurrency-market-and-imposes-mandatory-licensing-on-companies
https://sumsub.com/media/news/the-philippines-issue-new-crypto-rules/
https://www.sanctionscanner.com/blog/cryptocurrency-regulations-in-the-philippines-1140
https://insightplus.bakermckenzie.com/bm/technology-media-telecommunications_1/philippines-sec-issues-rules-and-guidelines-on-crypto-asset-service-providers-casp
https://fintechnews.ph/65038/blockchain/bsp-virtual-asset/