Philippines: Artificial Intelligence Challenges Online Gambling Rules
Philippines – 11 November 2026 – www.zonadeazar.com Legal advisory firm Arden Consult has warned of regulatory gaps in the Philippines concerning the use of artificial intelligence (AI) in gambling promotions and the emergence of new digital products, including prediction markets.
The firm highlighted that existing rules issued by the Philippine Amusement and Gaming Corporation (PAGCOR) do not specifically address the risks associated with algorithmic player targeting, a technology that can personalise commercial offers but may also identify and target vulnerable consumers.
The analysis raises new challenges for gambling operators, technology suppliers and the authorities responsible for supervising the Philippine market.
Artificial Intelligence and Promotional Risks
The report was prepared by Tonet Quiogue, founder and Chief Executive Officer of Arden Consult, and Jasmin Althea A. Siscar, a legal associate at the firm, as part of a review of Philippine gambling legislation.
The specialists explained that algorithms used to personalise promotions, establish betting limits and determine notification timing can also identify players at greater risk of developing problematic gambling behaviour.
They also warned that automated decisions can be difficult to explain or audit, raising questions about the transparency of the technologies deployed by operators.
PAGCOR Has Yet to Introduce Specific Algorithmic Targeting Rules
Arden Consult noted that PAGCOR’s advertising and player protection regulations currently contain no specific provisions governing the use of artificial intelligence for consumer targeting.
However, these technologies remain subject to existing responsible advertising obligations and personal data protection requirements.
Philippine legislation establishes a minimum gambling age of 21, alongside restrictions affecting individuals included in PAGCOR’s National Database of Restricted Persons.
Advertising controls and limits on certain cash rebate promotions are also in place.
Data Protection Becomes a Central Consideration
Using artificial intelligence to analyse player behaviour involves processing personal information and consumer activity patterns.
For this reason, Arden Consult emphasised that algorithm-driven marketing campaigns must comply with the Philippines’ Data Privacy Act of 2012.
The firm believes operators should properly document how their automated systems function and demonstrate that safeguards are in place to prevent harm to vulnerable consumers.
These precautions could help businesses comply with future regulatory requirements specifically addressing artificial intelligence.
PAGCOR Explores New Technological Tools
The Philippine regulator has also recognised the need to adapt its supervisory mechanisms to emerging technologies.
During an address on 14 September, Jessa Mariz Fernandez, Assistant Vice President of PAGCOR’s Electronic Gaming Licensing Department, highlighted how artificial intelligence could strengthen fraud detection and improve regulatory compliance.
However, she also warned that the technology could enable new forms of fraud that are more difficult to identify.
PAGCOR is currently testing an AI-powered system designed to detect illegal online gambling websites in real time.
The regulator is also considering applications that could identify signs of problem gambling and manipulated identity documents.
Prediction Markets Create Legal Uncertainty
Arden Consult’s review also identified difficulties in classifying emerging digital products, particularly prediction markets, loot boxes and collectible trading card platforms.
These activities can combine payments, elements of chance and prizes with monetary value, making it difficult to determine whether they should be classified as gambling, financial instruments or commercial promotions.
Classification is particularly important because it determines which authority has regulatory jurisdiction.
Products classified as gambling require PAGCOR authorisation, while financial instruments may fall under the supervision of the Securities and Exchange Commission (SEC).
Certain commercial promotions may instead require permits from the Department of Trade and Industry (DTI).
Polymarket Provides a Regulatory Precedent
Regulatory uncertainty surrounding prediction markets has already produced tangible consequences in the Philippines.
In May 2026, Polymarket became inaccessible to users of the Globe Telecom network, with a notice indicating that the platform did not hold a PAGCOR licence.
However, tests conducted at the time suggested that the service remained accessible through other telecommunications networks.
Arden Consult noted that the Philippines currently lacks a specific regulatory framework for contracts based on the outcomes of future events.
The firm believes that some of these products could eventually fall under financial regulation, although new legislation or regulatory provisions would probably be necessary.
International Experience and Potential Reforms
The review also examined international regulatory developments that could provide useful reference points for the Philippines.
These include proposed restrictions in New York on the use of artificial intelligence to personalise sports betting promotions.
The report also referenced US legal disputes over prediction-market regulation and Belgium’s treatment of certain paid loot boxes as gambling products.
These examples demonstrate how technological innovation can create similar regulatory challenges across different jurisdictions.
Industry Impact and Next Steps
Arden Consult recommended that operators and technology suppliers introduce preventive compliance measures before new regulations are implemented.
Key priorities include improving algorithmic transparency, documenting automated decisions, protecting personal information and assessing the risks associated with emerging digital products.
The firm warned that relatively minor changes in platform design could substantially alter a product’s legal classification.
The challenge for the Philippines will be to support technological innovation without weakening consumer protection safeguards or creating uncertainty over permitted activities.
The continued development of these technologies could encourage further regulatory reforms and reshape compliance obligations for companies operating in the online gambling market.
Editó: @fonta
