For many applicants, the PAGCOR Walkthrough is the part of accreditation that is hardest to picture. You know it is coming, you know PAGCOR representatives will visit and look at your operation, and you know it stands between you and your Certificate of Accreditation.
At Arden Consult, we help clients move through PAGCOR accreditation with clarity and confidence. This article clarifies what a PAGCOR Walkthrough involves in practical terms, written for the game aggregators, game content providers, and support-service providers required to be accredited under PAGCOR’s B2B regime.
If our earlier guide, Fit and Proper: What Probity Checks Mean for PAGCOR Licensing and Accreditation, looked at whether you and the people behind your company are trustworthy, the Walkthrough asks the companion question. It is the operational counterpart to probity: does the business you have described on paper genuinely exist, and does the system you are offering actually do what you say it does?
What a Walkthrough actually is
At its simplest, a Walkthrough is a live, guided demonstration and inspection of your company and its system, conducted by PAGCOR representatives as part of the accreditation process. Rather than relying only on your documents, PAGCOR sees your operation firsthand. It is the regulator’s opportunity to inspect your Philippine office and your team, and to examine, in a live environment, how you actually intend to provide your services.
The Walkthrough is where your application stops being paperwork and becomes something PAGCOR can see, test, and question in real time.
Who is required to undergo a walkthrough
Accreditation is mandatory for a broad range of B2B providers under PAGCOR’s Regulatory Framework for the Accreditation of Gaming Affiliates and Support Service Providers (Rev. 1), which took effect on 2 October 2025 and is administered by PAGCOR’s Electronic Gaming Licensing Department (EGLD). Only SEC-registered corporations may apply, and they must fall within one of the recognized categories:
- Gaming Affiliates, which include Game Aggregators (entities that integrate and offer game content from multiple developers to operators) and Game Content Providers (GCP, developers or studios supplying electronic game software or live game streams, accredited per game offering).
- Support Service Providers (SSP), covering payment channel providers, marketing and promotional service providers, customer-service providers, KYC and membership-system providers, and independent gaming testing laboratories.
Where does the walkthrough fit into this? The framework provides that, as part of accreditation, PAGCOR may conduct an ocular inspection of the applicant’s facilities and an evaluation or testing of any gaming system or platform to verify technical competence. The walkthrough is how those powers are exercised in practice — the ocular inspection at the initial stage, and system testing at the final stage. Applicants across the covered categories should expect to be walked through both.
One distinction follows naturally from that language. The system-testing element applies most directly to providers that have a platform to demonstrate, such as aggregators and content providers. A provider with no game to run — a marketing or customer-service provider, for example — will find its walkthrough weighted toward the facility side, and toward questions about how its service operates and reports.
Foreign-based Gaming Content Providers and Gaming Aggregators have an option to appoint a Philippine-registered Game Aggregator or Game Content Provider as its exclusive distributor, with each local distributor representing up to five principals. In that structure, it is the local distributor’s office that anchor the ocular inspection. However, PAGCOR will still need to see and inspect the platform of the foreign provider.
The two stages, in brief
A walkthrough comes in two parts: an initial walkthrough and a final walkthrough. The initial stage establishes that you are a real business with a credible system. The final stage tests that system in detail before PAGCOR recommends your accreditation for final Board approval.
➺ The initial walkthrough: establishing the entity
The initial walkthrough is conducted on-site at your registered Philippine office and usually lasts a maximum of two hours. Expect three to six PAGCOR representatives, drawn from different departments.
PAGCOR conducts the inspection to confirm that you have a registered office address in the Philippines, and that the office and organizational team you declared in your application genuinely exist. For a foreign company with a local representative, the company’s authorized representatives must be present to facilitate the visit. That said, PAGCOR permits representatives located abroad to join by video conference; the platform need not be hosted on-site, and the live demonstration may likewise be conducted from abroad.
You should come prepared to deliver two things: a presentation of your company profile, covering your services and your valued clients; and an overview of your system, accompanied by a printed system manual for the representatives to keep. You must be ready for questions at any point during the presentation or discussion. Because Gaming Affiliates and Support Service Providers differ in nature, the questions differ too, but at this stage they tend to center on your system’s credibility and on how your back-office reports are collected.
The visit may not be the end of the conversation. After the initial walkthrough, PAGCOR may send a further list of questions for your company to address.
➺The final walkthrough: proving your system works
The final Walkthrough is one of the final steps before PAGCOR takes up the matter of your accreditation before the Board. By this point, your requirements should be substantially complete. Note, however, that PAGCOR may still request documents at any time, especially where there are outstanding issues. In practice, PAGCOR uses the final Walkthrough to confirm that the issues identified in the previous Walkthrough have been resolved. It is conducted on-site by default, though it may be done online or virtually upon request .This stage is more technical than the first and may involve more live demonstration. Typically, PAGCOR runs through your system step by step, as though it were your user or client. Representatives may test or try your games directly; for aggregators, they may examine your system integration hands-on. Expect functional, detailed questions, such as:
- How is back-office data recorded, stored, or accessed?
- How are player transactions and activity recorded and retrieved?
Game Aggregators, in particular, should expect technical questions on system integration.
You cannot reach the final walkthrough without having been in good standing from the very beginning. PAGCOR looks for consistency across everything you have submitted, and discrepancies earlier in the process can hold you back here.
What it costs
The walkthrough itself carries no separate charge. You will not pay PAGCOR anything for it, because it is already covered by your application fee.
After accreditation: the visits do not stop
Accreditation is not the end of PAGCOR’s oversight. Once you are accredited, PAGCOR conducts random office visits and surprise inspections. The standards you demonstrate during your walkthroughs a genuine local presence, an accurate system, and consistent records are part of your continuing obligations to PAGCOR as an accredited entity.
Approach it with confidence
The difference between a smooth visit and a stressful one usually comes down to work done beforehand: readying a genuine, staffed office; preparing clear company and system presentations; making sure your live environment is genuinely ready to be tested; and ensuring that what you demonstrate matches, to the letter, what you have already submitted.
For further clarification and guidance, connect with us via email at info@ardenconsult.org .
REFERENCES:
Philippine Amusement and Gaming Corporation. (2025). Regulatory framework for the accreditation of gaming affiliates and support service providers (Rev. 1). https://www.pagcor.ph/regulatory/pdf/GSRM/Regulatory%20Manuals/Regulatory-Framework-for-the-Accreditation-of-Gaming-Affiliates-and-Support-Service-Providers-Rev-No-1.pdf
Philippine Amusement and Gaming Corporation. (2017). Gaming site regulatory manual for electronic games (Version 3.0). https://www.pagcor.ph/regulatory/pdf/GSRM/Regulatory%20Manuals/Gaming%20Site%20Regulatory%20Manual%20for%20Electronic%20Games%20v3.0.pdf
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