On a recent evening in Manila, a ballroom filled with nearly 2,000 Filipino professionals who had gathered to mark a milestone: the 10th anniversary of Entain’s Special Class BPO in the Philippines, NCH Customer Support Services, Inc. (Entain PH) – the first of its kind to be licensed by the Philippine Amusement and Gaming Corporation (PAGCOR). There were awards, applause and the kind of quiet pride that comes from a decade of showing up. But for those of us who work at the intersection of law, regulation and this particular industry, the evening was something more than a celebration. It was an occasion to take stock of a sector that has built real, skilled employment for thousands of Filipinos – and that still has to fight, harder than it should, to be properly understood.
PAGCOR Chairman Alejandro Tengco’s remarks that evening captured exactly why that fight matters. There is a particular kind of clarity that only a regulator can offer – not the clarity of a court ruling or a legislative fiat, but the kind that comes from a person in authority standing in a room full of workers and saying, plainly: you belong here, and what you do is lawful. For those of us who know what it took to build – and defend – the legal framework he was standing behind, it was not a small moment. Because the people in that room – managers, customer care specialists, graphic designers, risk analysts, payments officers, compliance leads, nearly all of them Filipino – are not employed by a gambling company. They are employed by a Special Class BPO. And that distinction, as this article will argue, is everything.
First, the terminology – because it matters enormously
SCBPOs are not POGOs. That is not a technicality. It is a legal distinction with consequences measured in thousands of jobs.
Philippine Offshore Gaming Operators (POGOs) were entities licensed to offer online gambling services to players outside the Philippines. They were the subject of sustained and well-documented controversy: alleged links to organized crime, human trafficking, money laundering and national-security vulnerabilities. Executive Order No. 74 (s. 2024) rightly ordered their comprehensive shutdown and wind-down. That ban was justified, necessary and overdue.
Special Class BPOs are an entirely different regulatory creature. Under PAGCOR’s Offshore Gaming Regulatory Manual (OGRM), an SCBPO is defined as a Philippine-based service company that supports legitimately licensed gaming operators abroad, does not handle bets or solicitations, and is required to maintain a workforce that is at least 90% to 95% Filipino. The work they perform is operationally indistinguishable from what any BPO does: human resources, customer service, accounting, marketing, compliance, responsible gaming controls. The only things that distinguish them from an ordinary BPO are the industry of their foreign clients and the fact that PAGCOR, accordingly, regulates them.
A question I am asked constantly – by clients, legislators and journalists alike – is: who exactly is covered? The OGRM definition covers companies servicing Business-to-Consumer (B2C) gaming operators: that is, companies whose foreign clients offer gaming services directly to end-users or players abroad. What the framework does not cover, by default, are Business-to-Business (B2B) companies – entities that supply technology platforms, software or infrastructure to other gaming businesses rather than to players directly. The distinction tracks how the Philippines legally defines gambling itself. Under Philippine law, gambling involves the staking of money on an uncertain outcome for a prize. A B2C operator sits closest to that definition – it is the entity facing the player, accepting the wager. A B2B supplier is several steps removed.
That said, B2B gaming companies are not entirely outside PAGCOR’s reach – if they choose otherwise. In a legal opinion our firm recently secured directly from PAGCOR, the regulator clarified that B2B gaming companies may voluntarily seek SCBPO accreditation – whether because they wish to operate under PAGCOR’s regulatory umbrella as a matter of good governance or because other jurisdictions require them to demonstrate that their Philippine operations are formally regulated. This is a sensible and pragmatic position: it preserves the mandatory framework for B2C operators while leaving an accessible, structured pathway for B2B companies with legitimate reasons to seek regulatory recognition. It is not a loophole – it is optionality by design, with oversight as its price of entry.
The regulatory architecture didn’t happen by accident
For those unfamiliar with how this framework was built: it took years and it took deliberate effort.
The scaffolding begins with Executive Order No. 13 (s. 2017), which intensified anti-illegal gambling enforcement and defined illegal gambling broadly enough to sweep in activities “directly or indirectly related to or in support of“ offshore gambling. That definition, while appropriate for its target, created genuine legal ambiguity for support-only service providers operating in the Philippines whose clients happened to be overseas gaming operators.
PAGCOR responded by establishing a distinct accreditation pathway. Its Offshore Gaming Licensing Department began accepting applications for “Special Class of BPOs“ – entities that serviced licensed gaming operators abroad, explicitly did not handle betting and did not service POGO licensees. The 2018 OGRM institutionalized the definitions and the regulatory scaffolding. In January 2024, PAGCOR further streamlined the process by removing the Letter of No Objection (LONO) requirement for SCBPO applications – a meaningful signal that the regulator understood the distinction it was drawing and was committed to making it operationally workable.
The boring truth of good regulation is this: lists, renewals and compliance requirements matter as much as speeches. As of February 2026, PAGCOR’s regulatory site still maintained a current official list of accredited SCBPOs – on which Entain PH appears. A company holding that listing after a decade is not a footnote. It is a legal fact with employment consequences.
2024: When the industry almost lost everything
Then came the storm.
When the POGO shutdown gathered political momentum in mid-2024, the public narrative moved fast – and it moved imprecisely. “Offshore gaming“ became a single phrase capable of erasing legal nuance. Operations that had nothing to do with gambling – no betting, no players, no odds – were suddenly at risk of being swept into the same enforcement net as the criminal enterprises that had triggered the ban. For thousands of Filipinos working in SCBPOs, the threat was not abstract. It was a potential termination letter.
This is when those of us in the legal community who had built this space felt compelled to act as advocates.
We went to the Senate. We requested meetings, submitted position papers and made the legal case in committee rooms for why the SCBPO classification was not a loophole but a deliberate, well-constructed regulatory category. We brought senators and their staff directly to the offices of our SCBPO clients – walking them through operations floor by floor, function by function, so that the distinction between “support services” and “gambling” was not theoretical but viscerally visible. Compliance teams at their desks. HR officers onboarding employees for offices in the UK. Graphic designers producing marketing materials for international markets. No betting terminals. No players.
We engaged the media – speaking to editors, reporters and columnists who were understandably confused by the acronym soup, explaining what an SCBPO actually does and why collapsing it into the POGO category would be both legally inaccurate and economically damaging.
But the damage was not zero. Even as the advocacy succeeded in preserving the framework, the uncertainty of 2024 exacted a quiet toll that never made the headlines. We heard, directly and through the industry, that some accredited SCBPOs made the painful decision to close down – not because they were non-compliant or had lost their clients, but because the regulatory ambiguity became too great a business risk to absorb. Others who had been seriously exploring the Philippines as a location for SCBPO operations quietly shelved those plans. Investor confidence, once shaken, does not return on the day a senator gives an assurance. Each closed operation and each shelved expansion represented jobs that existed or could have existed – hundreds, possibly thousands of Filipino workers who either lost employment or never got the opportunity. Regulatory uncertainty has a body count that never appears in any official report.
I raise this because the industry needs to understand that its survival in 2024 was not automatic. It required people who knew the law, knew the operations and were willing to spend political capital explaining both. It will require the same vigilance going forward, because the next period of uncertainty, if it comes, will cost even more.
Why the Philippines makes strategic sense for global gaming companies
Let us now ask the question from the other side: why do legitimate overseas gaming companies choose to set up SCBPOs in the Philippines? The answer lies in a convergence of cost, regulation and – most durably – talent.
Start with the cost pressure. The global gaming industry, particularly in the United Kingdom, is operating under an increasingly punishing tax environment. The UK’s Autumn 2025 Budget announced the most substantial overhaul of gambling taxation in decades: Remote Gaming Duty will nearly double from 21% to 40%, effective 1 April 2026. A new remote betting rate of 25% within General Betting Duty follows in April 2027. Together, these measures are projected to raise over £1 billion annually from the sector. Operators are expected to absorb much of this increase, with real pressure on margins, headcount and operational costs across the board.
In that environment, the business logic for outsourcing non-core functions to a compliant, lower-cost jurisdiction is not just defensible – it is rational. Customer service, HR, risk management, responsible gaming compliance and payments processing can all be performed with equal or greater quality outside the United Kingdom, without compromising regulatory integrity. The Philippines, with its SCBPO framework, offers a legal, structured and PAGCOR-regulated pathway to do exactly that.
But cost is only part of the story – and frankly, not the most compelling part.
The more durable argument for the Philippines is talent. Ian Dunning, Country Head of Entain PH, has said that the Philippine office produces some of their best, most productive and happiest employees anywhere in their global operations. That is not a recruitment tagline. It is an operational assessment from someone with the comparative data to back it up. Chairman Tengco put it plainly from the stage when he said, “The talent and dedication of every Filipino has helped build and maintain reputation across the global gaming and technology services industry … you in fact serve as the vital backbone of amazing international operations.“
Backbone. Not peripheral. Not supplementary. The infrastructure on which global operations run. When Chairman Tengco pointed out that NBA Finals and Super Bowl marketing materials are produced by these teams, he was not being sentimental. He was describing a market reality: world-class outputs, produced here, exported globally.
What the Chairman said – and why each word was hosen
Chairman Tengco’s workforce argument is worth reading through a legal lens:.
“The presence of close to 2,000 Filipino employees managed by a few foreigners just shows us that truly the SCBPO sector … should really be given the support. I am very clear that you have made a great effort for us Filipinos to continue to do our work, to make every single one of you proud.”
A 95% Filipino workforce threshold is not a suggestion. It is a licensing condition. An SCBPO that fails to meet it loses its accreditation. The composition of Entain PH’s workforce is therefore not incidental – it is evidence of ongoing regulatory compliance. The Chairman was not just being gracious. He was pointing to a verifiable licensing condition being met, publicly, in real time.
Then came the operational description that a legal reader should study most carefully: “You manage … critical functions across multiple markets … from human resources supporting offices in the United Kingdom and other countries, to customer service, risk and payments, responsible gaming, and customer due diligence. These are not just support roles – they are essential to ensuring that the gaming operations remain efficient, secure and compliant.”
Responsible gaming involves player protection protocols, self-exclusion systems and spending controls. Customer due diligence is an anti-money laundering obligation. The Filipinos performing these functions are, in a very real sense, the compliance layer of international gaming regulation. They are not enabling gambling. They are constraining and governing it.
PAGCOR’s February 2025 public statement placed the SCBPO sector’s total employment at close to 5,000 local workers, with above-industry salaries and a 95% Filipino workforce mandate. Against the economic backdrop of early 2026 – slowing hiring, rising prices and intensifying global headwinds – the question for policymakers is not philosophical. It is immediate: which compliant, employment-generating industries are we willing to protect, and which are we willing to lose to definitional confusion?
A personal note
I should disclose that I am not a disinterested observer. Entain, back when Ladbrokes was the more familiar name in our local conversations, was the first SCBPO engagement I worked on directly. I sat with colleagues and mapped, function by function, what the Philippines was actually providing: not bets, not players, not gaming floors – trained, compliant professionals exporting services. We walked into PAGCOR and argued for a framework that would say, in plain operational language: this is BPO work, regulated because of the client’s industry, but not gambling.
Under Chairman Tengco’s administration, that framework didn’t just survive the POGO ban – it matured. More explicit safeguards. More visible public support. A more consistent willingness to tell other agencies: this is not what you think it is. Do not misclassify it. And in 2024, when misclassification became an existential threat, our firm stood in that gap – not because it was easy, but because the jobs were real and the legal argument was right.
What needs to happen now
Surviving 2024 was a reprieve, not a finish line. The work of building durable institutional support for the SCBPO sector is unfinished, and there are specific, concrete steps that government, legislators and the private sector must take together.
PAGCOR is already leading. The agency strengthens its regulatory framework regularly, conducts inspections of accredited SCBPOs and maintains ongoing compliance monitoring. PAGCOR is also currently studying proposed revisions to the SCBPO framework that would allow multiple gaming companies to be serviced under a single SCBPO entity – essentially a multi-client BPO model. If adopted, it would lower the barrier to entry for smaller operators seeking compliant Philippine-based support, broaden the employment base and bring more of the industry under formal regulatory oversight. One important caveat: the fee structure must make sense. A multi-client model only works if regulatory fees are calibrated to reflect the shared arrangement – not structured as if each client relationship were a separate, full-cost licensing event.
But PAGCOR cannot do this alone.
First, SCBPOs must be given equal access to investment incentive regimes. There is no principled reason why an accredited SCBPO should be excluded from the benefits available to any other BPO under existing frameworks – whether through PEZA, the BOI or other applicable programs. These entities perform the same functions as any export-oriented service provider. They generate foreign exchange. They employ Filipinos at competitive wages. They comply with regulatory requirements more stringent than most. The only thing distinguishing them is the industry of their overseas client – and that should not be grounds for exclusion from incentive regimes designed precisely to reward the kind of employment and export activity that SCBPOs generate. This is a policy gap that Congress and the relevant investment promotion agencies must close.
Second, other government agencies – particularly local government units – must be educated and aligned. There are LGUs that continue to classify SCBPOs as “gambling” operations despite PAGCOR’s clear regulatory classification to the contrary. Some have refused to allow accredited SCBPOs to operate within their jurisdictions. Others have done something worse: conditioning local clearances or Letters of No Objection on fees that have no legal basis – what can only be described as regulatory extortion.
The stigma runs deeper than local government. We regularly receive reports that foreign nationals working for accredited SCBPOs have been denied visas, subjected to heightened scrutiny or required to go through restrictions meant for actual gambling operators. People working in HR, finance, compliance and technology – roles that would raise no eyebrows anywhere else in the BPO sector – find themselves treated as if they were running a casino. That is not just an inconvenience. It is a signal to the international talent and investor community that the Philippines cannot distinguish between its regulated service providers and the offshore gambling operations it has banned. For global companies evaluating whether to expand their Philippine SCBPO footprint, that signal carries real weight.
We are committed to bringing these cases to light – through legislative engagement, regulatory advocacy and the media when necessary. Employment cannot be held hostage to local misinformation, rent-seeking or inter-agency inconsistency. The workers inside these offices – Filipino and foreign alike – deserve better from their government.
The bigger picture
In the ballroom that evening, the tangible thing was not policy – it was people. The applause was for awardees, for teams, for a decade of showing up. And the clearest argument for SCBPOs was something Chairman Tengco said quietly but forcefully: these are “quality jobs … created supporting Filipino families.“
That argument is more urgent now than ever – because the Philippines is, at this very moment, in the middle of a defining debate about how it wants to regulate online gaming domestically. In Congress, competing bills have emerged: some calling for an outright ban on online gambling, others pushing for stricter regulation within the existing PAGCOR framework. PAGCOR has been consistent: a total ban would only drive players to illegal operators, reduce government revenues and cost jobs. The answer is not prohibition – it is smarter, tighter regulation.
There is one more argument that has not yet been made loudly enough, and it may be the most practical of all. As the Philippines moves toward framing and passing an Online Gambling Regulatory Act – legislation that our firm has had the privilege of contributing to as a resource – lawmakers and regulators will need to understand in granular detail how the world’s most advanced gaming jurisdictions actually operate: what their compliance frameworks look like, how responsible gaming is enforced in practice, what technology underpins player protection and how regulators in the UK, Malta and Gibraltar have learned –often painfully – what works and what does not. That knowledge does not live in textbooks. It lives in the operations of companies like Entain and the other SCBPOs currently accredited by PAGCOR.
These companies are not just employers. They are repositories of international regulatory best practice, staffed by people who implement those practices every single day. Their compliance officers, technology teams and risk managers have firsthand experience with standards the Philippines is now aspiring to codify into law. They should be invited to the table – as resource persons, as technical consultants, as partners in building the regulatory architecture the Philippines needs. The expertise that global gaming companies have embedded in their Philippine operations is, in a very real sense, a national asset.
Protect the jobs that are clean enough to deserve protecting. Regulate hard enough that the country never again confuses legitimate work with the harms it rightly banned. And build the institutional support – incentives, inter-agency alignment, local government education – that allows this sector not just to survive the next political storm, but to serve as the template for how the Philippines governs gaming in the decade ahead.
It would be a profound irony if, in the effort to regulate online gaming properly, the Philippines overlooked the very people already doing it properly within its own borders.