Regional Round-Up: Philippines Q3 2025

PCC and NTC Collaborate to Strengthen Competition in the Data Transmission Industry

On 19 September 2025, the Philippine Competition Commission (PCC) and the National Telecommunications Commission (“NTC“) entered into a Memorandum of Agreement (“Agreement“) aimed towards the promotion of fair competition and regulatory coordination in the data transmission industry.

The Agreement was designed to implement Republic Act No. 12234, otherwise known as the “Konektadong Pinoy Act”, in line with the State’s commitment to pursue an open-access policy that provides an accessible and competitive environment to qualified participants in all segments of the data transmission network and encourage investments in the digital infrastructure for the development of reliable and affordable data transmission networks.

In particular, the Agreement enables collaborative mechanisms on joint market supervision, policy development, enforcement procedures, capacity-building strategies, protocols for information exchange, coordination on merger reviews and investigations, and the joint task forces when necessary. NTC Commissioner Ella Blanca Lopez declared that the Agreement “sets the stage for strong interagency collaboration and responsible data sharing, enabling us to fulfill our mandates and better serve Filipino consumers.

BSP Sets Maximum Limit of PHP500,000 for Large Value Payouts

The Bangko Sentral ng Pilipinas (“BSP“) issued Circular No. 1218, series of 2025 (“Circular“) dated 18 September 2025, which sets forth new regulations on large value cash transactions. In a press release published on 19 September 2025, BSP explained that these new regulations were established with the objective of reducing money laundering and other risks associated to the use of cash.

Under the Circular, large value payouts exceeding PHP500,000 (approximately US$8,929) or its equivalent in foreign currencies in a single transaction or series of transactions within one banking day shall only be made, facilitated, or transacted through check payment, fund transfer, direct credit to deposit accounts, and/or other forms using the digital payment platforms of the BSP-supervised financial institutions (“BSFls“).

The Circular likewise requires BSFIs to conduct the appropriate enhanced due diligence (“EDD“) measures provided under section 921/921Q of the Manual of Regulations for Banks/Manual of Regulations for Non-Bank Financial Institutions for cash transactions exceeding the threshold. Following the EDD, BSFIs may allow large value payouts in cash of more than PHP 500,000 or its equivalent in foreign currency if customers can submit additional identification information and/or proof of legitimate business purpose or transaction.

If the BSFI fails to satisfactorily complete the EDD procedures or reasonably believes that performing the EDD process will tip-off the customer, it shall file a suspicious transaction report and closely monitor the account.

The Circular also allows BSFIs to adopt lower cash transaction limits based on their institutional money laundering, terrorism financing, or proliferation financing risk assessment and/or customer financial profiles.

DOLE-NCR Implements New AEP Processing Timeline and Scheduled Release System

The Department of Labor and Employment–National Capital Region (“DOLE-NCR“) issued two new advisories, AEP Advisory No. 25-03 and AEP Advisory No. 25-04, introducing updated procedures for the processing and release of Alien Employment Permits (“AEPs“).

Under AEP Advisory No. 25-03, DOLE-NCR introduced an appointment system for the scheduling of AEP releases. Once their AEP cards are printed, clients will be notified of their assigned pick-up dates. AEP cards will be released to clients either through pick-up or delivery by courier. Clients are encouraged to coordinate with the AEP Releasing Team via email or mobile. DOLE-NCR will also implement a “No Face-to-Face Inquiry” policy. As such, follow-ups and related communications must be sent via email.

AEP Advisory No. 25-04 reiterates that the processing timeline for AEP issuance is now set at 15 working days from the date of payment, as per Department Order No. 248, Series of 2025. This replaces the previous five-working day period and reflects DOLE-NCR’s aim to ensure a more comprehensive evaluation process. The 15-day timeline includes all procedural steps, such as evaluation of documents, endorsement for approval, inspection, card printing, and release scheduling. As a result, requests for expedited processing are no longer necessary.

DOLE-NCR reminds all clients to ensure the completeness and accuracy of submitted documents to avoid unnecessary delays. These advisories are part of the agency’s continuing efforts to enhance the efficiency, transparency, and integrity of the AEP process in the region.

DICT Mandates Telecommunication Entities to Comply with Philippine National Standards ISO/IEC 2700

The Department of Information and Communications Technology (“DICT“) has issued Department Circular No. HRA-003 dated 28 July 2005 (“Department Circular“), which prescribes the International Organisation for Standardisation (“ISO“) Standards on Information Security for entities engaged in the telecommunications business. The Department Circular was issued pursuant to:

  1. Republic Act (“RA“) No. 11659, otherwise known as the Public Service Act, which requires entities engaged in the telecommunication business to obtain and maintain certifications from an accredited certification body attesting to their compliance with ISO standards; and
  1. RA No. 11934 or the Subscriber Identity Module (“SIM“) Registration Act which requires Public Telecommunications Entities (PTE) to comply with the minimum information security standards prescribed by DICT, consistent with internationally accepted cybersecurity standards and relevant laws and regulations.

The Department Circular covers natural and juridical persons engaged in the telecommunications business, except those classified as micro, small, and medium enterprises (“MSMEs“) under RA No. 6977 or the Magna Carta for MSMEs. Covered entities shall obtain the relevant and applicable information security standards certification from a certification body accredited by the Philippine Accreditation Bureau of the Department of Trade and Industry.

The Department Circular expressly states that the maintenance of the relevant and applicable information security standards certification shall be a continuing qualification for the retention of franchise or the authority to operate issued by the National Telecommunications Commission.

SEC Cautions Filipino Public Against Unregistered Crypto-Asset Platforms

The Securities and Exchange Commission (“SEC“), through its Enforcement and Investor Protection Department, issued a strong public warning against unregistered entities and online platforms offering crypto-asset services to Philippine residents without the required SEC registration and authorisation. SEC reminded that these activities are in violation of SEC Memorandum Circulars No. 4 and No. 5, Series of 2025 which took effect on 5 July 2025.

SEC emphasised that these rules apply to any person or platform that “offers, promotes, or facilitates access to crypto-asset trading venues or intermediation services such as buying, selling, and derivatives trading of crypto-assets.” Following the geo-blocking of Binance’s website, SEC identified ten other similar platforms operating without registration.

SEC clarified that these platforms have no license, registration, or authorisation from SEC to operate in the Philippines or to solicit investments from the public. As such, engaging with them may expose the public to severe risks such as total loss of funds, lack of legal recourse, and exposure to fraud, market manipulation, and identity theft.

Another key concern raised by SEC is the risk of money laundering and terrorist financing. SEC stressed that Virtual Asset Service Providers are considered covered persons under the Anti-Money Laundering Act and must implement due diligence and monitoring systems. Unregistered platforms typically lack effective anti-money laundering systems and are not subject to monitoring by Philippine regulators.

SEC warned it will take enforcement actions against violators, including issuing cease and desist orders, blocking websites, filing criminal complaints, and coordinating with global platforms to remove unauthorised promotions, among others.

Please note that whilst the information in this Update is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as a substitute for specific professional advice

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