Total gambling ad ban seen handing market back to illegal operators, data from five countries show

MANILA, Philippines — Market data, the experience of foreign regulators, and the government’s own enforcement record all point to the same risk in a Senate bill that would ban all gambling advertising: the measure could reverse three years of gains against illegal online gambling and push Filipino players to offshore operators outside Philippine law.

Senator Francis “Chiz” Escudero filed Senate Bill No. 2347, the Gambling Advertising Prohibition Act (GAPA), on 26 July 2026. The bill prohibits gambling advertising and sponsorship in all media: broadcast, print, outdoor, websites, applications and social media. It also bans celebrity and influencer endorsements and gaming sponsorship of sports and cultural events. Licensed operators may advertise only inside their own premises and on their own websites and apps. Penalties reach ₱500,000, three years in prison, license revocation, liability for corporate officers, and deportation for foreign nationals. Operators get one year to comply.¹

Every country that has enacted a total gambling advertising ban, starting with Italy in 2018, ended up with a larger illegal market. Italy is now unwinding its ban. A prohibition binds only licensed operators; the offshore sites that already advertise illegally to Filipinos keep their channels and inherit the audience. And the ban would cut licensed gaming revenue and PAGCOR remittances, the same funds that pay for the government’s campaign against illegal sites.

Legislators also have an alternative already on the table. Senate Bill No. 57, the Online Gambling Regulatory Act filed by Senator Sherwin Gatchalian in July 2025, is pending in committee. It looks at the industry as a whole: operators, payments, player protections and advertising in one framework, rather than banning one piece of it. Industry groups say the advertising rules GAPA seeks, plus an outright ban on advertising by illegal operators, can be written into that bill with enforcement teeth.

Escudero says the measure follows the Tobacco Regulation Act of 2003 (Republic Act No. 9211): “It’s about time that we regulate the gambling industry the same way we regulated tobacco two decades ago.” Nobody disputes the objective of protecting minors and vulnerable players, and the licensed industry has publicly backed stricter advertising rules. The question the data raises is whether a total ban advances that objective or sets it back.

Three years of migration from illegal to legal play

Independent estimates describe the same trajectory from different methods. In 2022, industry estimates placed the offshore market at nearly four times the size of the licensed one. In August 2025, PAGCOR Chairman Alejandro H. Tengco told the House that more than 60 percent of online gambling remained illegal. By December 2025, monitoring figures from Yield Sec, which Tengco cited, put licensed operators above 50 percent for the first time, and Blask, a demand-side analytics firm, estimated the legal share at about 58 percent by March 2026. The estimates differ in method, but they point the same way: most Filipino online wagers now run through licensed platforms, and the share is rising.²

The shift did not happen by accident. Regulators call it “channelization”: moving players from illegal sites to licensed ones. PAGCOR engineered it. The regulator cut e-games license fees from over 50 percent of gaming revenue to 30 percent, required KYC-verified payments and real-time wager monitoring, accredited the full supply chain from operators to marketing affiliates, and escalated enforcement against illegal sites. Licensed e-games revenue more than tripled, from ₱58.16 billion in 2023 to ₱201.12 billion in 2025, and online overtook land-based casinos for the first time. Read against those estimates, the tripling mostly reflects existing wagers moving from illegal platforms to legal ones, not a threefold increase in gambling. What tripled was not the vice but the State’s visibility into it.³

The Casino Plus fine: what regulation can reach, and what it cannot

A July 2026 episode illustrates both sides of the debate. Actress Ivana Alawi, a brand ambassador of the licensed platform Casino Plus, gave away 100 high-end phones worth more than ₱4 million. To join, users had to like the platform’s Facebook page. PAGCOR acted within days. It fined the operator ₱1 million for running the promotion without prior approval, ordered it stopped, and warned that a repeat could bring suspension or cancellation of the license. “We already implemented that; they paid ₱1 million, and we instructed them to stop the said promotion,” Tengco said.⁴

The episode shows the kind of celebrity promotion that alarms legislators. It also shows enforcement that works only on licensed operators. The license gave PAGCOR something to act on: it collected a fine, the operator obeyed the stop order, and the franchise can be revoked. If any of the more than 1,000 illegal sites the CICC has identified had run the same giveaway, none of those tools would apply. PAGCOR cannot fine, suspend or sanction an unlicensed operator; it can only refer sites for blocking while mirror domains multiply. Illegal operators already run the same kind of promotions through influencers, to audiences that include the young and the financially vulnerable. They ask no permission, pay no fines, and hold no license to lose. A total advertising ban will not stop these promotions. It will make them the only ones left.

A total ban puts legal and illegal on the same level, in the one arena where the illegal side adapts fastest

A license carries heavy obligations: a 30 percent fee on gaming revenue, KYC checks on every player, real-time monitoring, pre-screened advertising, capped promotions. In exchange it gives one commercial advantage: the right to build a brand lawfully, in public. GAPA removes the advantage and keeps every obligation. Industry executives now ask a blunt question: if a licensed operator can no longer market, what is the license for? A permit that costs 30 percent of revenue and gives no right to reach customers is a burden, not a franchise.

The leveling is not a stalemate, because the two sides adapt at different speeds. Illegal operators change domains faster than blocklists update, shift into group chats and private messages, and recruit new influencers as fast as old ones are exposed. Roland Cinco, CEO of Digirockstars, which runs performance marketing and affiliate programs for licensed operators in the Philippines, says the creator market is already repricing.

“Creators are pricing the ban in. They are not leaving the category; they are quoting higher rates to the illegal market for it. The reasoning they give is that association with gaming now carries more risk to their own brand, so the rate goes up. The creator market does not go quiet if this passes. It gets more expensive. And the buyers who can absorb a risk premium are the ones paying no license fee and no compliance.” — Roland Cinco, CEO at Digirockstars ⁵

A licensed operator cannot adapt around the law it operates under. When both sides are silenced on paper, the side that ignores paper wins. Licensed operators lose players, licensed gaming revenue contracts, and the government’s share contracts with it, while the same wagers continue offshore and produce nothing for the State.

What the tobacco ad ban achieved

The tobacco precedent is more qualified than commonly assumed. The Tobacco Regulation Act removed cigarette advertising from television, radio, cinema and billboards, and it could do that because every cigarette advertiser in the country was a Philippine-registered business. Even so, the ban suppressed marketing; it did not silence it. In 2009, the year after the full prohibition took effect, 74.3 percent of Filipino adults said they had noticed cigarette marketing in the past 30 days; in 2021 the figure was still 46.7 percent. Smoking fell from 29.7 percent of adults in 2009 to 19.5 percent in 2021, a decline credited mainly to the price increases of the 2012 sin-tax law.⁵ And vapes, the one nicotine product marketed the way online casinos are, still reach Filipino youth through social media despite the statutory ban.⁶

The economics literature explains why. Saffer and Chaloupka studied advertising bans in 22 OECD countries and found that bans reduce consumption only when they close every channel at once; partial bans achieve little, because marketing money moves to the channels that stay open.⁷ A gambling advertising ban is partial by nature. About 80 percent of gambling marketing is digital,⁸ and the biggest advertisers reaching Filipinos are offshore operators who already break the law by advertising: the CICC has identified more than 1,000 illegal sites and over 100 influencers promoting them.⁹ GAPA binds only advertisers inside Philippine jurisdiction. One industry analysis calls it “a partial ban wearing a total ban’s clothes: total for the licensed sector, partial for the market.”

Unlike cigarettes, the legal and illegal products differ

Two more differences separate the markets. Every cigarette, legal or smuggled, carries the same health risk, so a tobacco ad ban cost consumers no safety information. Legal and illegal gambling differ on every dimension a regulator measures, and in a regulated market, advertising is how players find the supervised product. Gaming lawyers put it this way: “the advertisement is the warning label: it is how a player tells the supervised platform from the trap dressed to look like one.” And where cigarettes still required an in-person purchase after the ad ban, an online gambling promotion links straight to registration and deposit. “The ad is the doorway.” The ad and the product arrive on the same screen, one tap apart.

International rules reflect the distinction. Tobacco is harmful at any dose and sits under a binding global treaty, the WHO Framework Convention on Tobacco Control, which drives consumption toward zero. Gambling has no such treaty. The World Health Organization estimates gambling disorder at 1.2 percent of adults and tells states to “closely monitor and effectively regulate gambling operations, products and activities.”¹⁰

What a license gives the player: the right to be refused

Licensed platforms must verify a player’s age and identity before any wager, use independently certified games, run under PAGCOR monitoring, offer deposit and loss limits, display the National Problem Gambling Helpline, and answer to PAGCOR when a player disputes a withheld payout. The system’s most distinctive feature is the right to be banned. Under PAGCOR’s exclusion programs, any person can bar themselves from gambling for six months, one year or five years. A spouse, a parent, or a child of legal age can petition to exclude a problem gambler in the family, without the gambler’s consent. Every name enters the National Database of Restricted Persons (NDRP), and all PAGCOR-regulated venues and platforms must enforce it.¹¹ A parent who fears a child is losing control, or a spouse watching the savings drain, has a legal remedy, but only against the licensed market. No illegal site consults the NDRP, honors a family petition, or refuses anyone. These protections reach only as far as the licensed market extends. That is what channelization measures.

Five countries have run the experiment

Italy went first. Its 2018 Dignity Decree imposed a total advertising and sponsorship ban, the same design as GAPA. Eight years later, Italy’s illegal online market is estimated at €20 billion a year, larger than the legal market’s €11.47 billion. A 2022 parliamentary inquiry found underage and illegal gambling kept growing after the ban, the Italian football federation calls the measure “largely ineffective,” and the Italian Senate and media regulator AGCOM are now softening it.¹²

Belgium went near-total in July 2023: within three months, players on illegal sites rose 6 percent and deposits rose 4 percent, and illegal operators targeting Belgium grew 4.4-fold that year.¹³ France never licensed online casino; its illegal sites now count 5.4 million players, more than the regulated sector’s 3.5 million, at an estimated €1.2 billion a year in lost taxes. The Netherlands banned untargeted advertising and capped deposits; channelization by revenue fell to 49 percent in the first half of 2025.¹⁴ The United Kingdom shows the other path: it permits gambling advertising under strict content, placement and targeting rules and keeps about 98 percent of online play inside the licensed market.¹⁵

Countries that silence their legal markets get bigger illegal ones. Countries that let the legal market be seen, under hard rules, get smaller ones.

Who stands to absorb displaced players

The operators positioned to absorb displaced players are documented. PAGCOR monitoring has linked detected illegal gambling sites to former POGO networks, and the PAOCC and PNP still run operations against successor groups of the scam compounds shut down in 2024.¹⁶ These sites register users with a phone number or e-mail, set no deposit or loss limits, run uncertified games, and pay no Philippine tax. France measured what happens to players on such sites: 62 percent showed excessive or pathological gambling, 70 percent suffered data theft, phishing or fraud, and 90 percent received unsolicited gambling advertising.¹⁷

None of the Philippine market’s protections follows a displaced player. Deposit limits, age checks and monitoring apply only to licensed platforms, and so does the NDRP. Illegal operators can market to every name on the exclusion list. Industry lawyers warn that “to an illegal operator, the self-exclusion list is not a barrier; it is a prospect database.” A shift from licensed to unlicensed play moves the most vulnerable players first, because they are the ones the licensed market currently restricts.

Harsher than the tobacco law it cites

GAPA is presented as a copy of the tobacco law. Side by side, the two differ on four points. Timing: the Tobacco Regulation Act gave the industry five years to phase out advertising; GAPA gives one. The remaining channel: the tobacco law permanently allowed ads inside stores that sell cigarettes; GAPA’s only remaining channel is the operator’s own website, which reaches only people who already know the brand. Standards: the tobacco law used numbers a company can measure, with print ads allowed at 75 percent adult readership and sponsorships at 75 percent adult attendance; GAPA uses a judgment call, whether something is “likely to appeal to persons below 21,” and makes getting that judgment wrong a crime. Penalties: the tobacco law’s fines ran from ₱100,000 to ₱400,000; GAPA’s run from ₱200,000 to ₱500,000 and add license revocation and deportation.¹⁸

There is also a gap in who the penalties reach. Imprisonment, officer liability and deportation apply only to people in the Philippines: licensed operators, local broadcasters, local ad agencies, and the foreign executives of accredited suppliers with offices here. None of it touches the offshore operators doing most of the illegal advertising, and the bill contains no provision aimed at them: no penalty for promoting an unlicensed site, no liability for platforms paid to carry illegal ads, no faster site-blocking, no added enforcement funding.

The stakes: revenue, remittances and the enforcement budget

The licensed market already operates under heavy new restrictions: e-wallet de-linking that cut licensed online transactions by about half, billboard removal, ad pre-screening, bans on credit-card and cryptocurrency betting, and capped rebates. PAGCOR revenue from eGames grantees fell 41.85 percent in the first half of 2026.¹⁹ A total ad ban on top of this would stop licensed operators from acquiring new players while illegal recruitment continues, slide channelization back toward its old levels, and shrink the PAGCOR remittances that fund enforcement: ₱30.16 billion went to nation-building in the first half of 2026, and the campaign behind it has referred 13,399 illegal sites, blocked 12,562, granted ₱50 million to the NBI, and cut off more than 3,200 illicit payment merchants.²⁰ One measurement caution: if licensed revenue falls after a ban, that shows less recorded gambling, not less gambling. Italy’s numbers show a legal market can shrink while the illegal one grows.

An alternative is already pending

Senate Bill No. 57 remains pending in committee²¹ and can house the advertising rules GAPA seeks. An advertising chapter built on the tobacco-law design would set content standards that bar any appeal to minors or vulnerable groups, placement rules and watershed hours, measurable audience thresholds in place of guesswork, and mandatory responsible-gaming messaging with the national helpline in every advertisement. Two more provisions would strike at the actual source of harm: mandatory accreditation and responsible-gaming training for every influencer, celebrity and affiliate who promotes gaming,²² and an absolute, criminally enforced ban on advertising by unlicensed operators, with liability for platforms and intermediaries paid to carry it. Industry groups support both. “On TikTok and Google, a gaming advertiser has to be certified and show a license before the account can run,” Cinco said. “Other networks have no equivalent check.” A position paper submitted to Congress during the 2025 prohibition debate framed the choice in terms that apply equally here: “A blanket ban would forfeit the control and transparency that come with regulation, and hand over the market to unscrupulous illegal operators who evade taxes, ignore rules, and offer no consumer protections.”²³

Regulated advertising also has an affirmative use: it is the State’s cheapest education channel. Rules can require each licensed ad to display the operator’s license number and point players to PAGCOR’s Guarantee portal, where anyone can check a brand and URL against the official registry.²⁴ Used this way, the industry’s own marketing budgets teach the public to tell a licensed platform from an illegal one, at no cost to government.

Every legal ad is a lesson in telling the licensed from the lawless. The State should write the curriculum, not cancel the class.

Three years forward, and the road back

PAGCOR built a turnaround few markets have managed: in three years it converted an online gaming market that was overwhelmingly illegal into one where, for the first time, most play is supervised. It cut license fees to make legality viable, accredited the supply chain down to the marketing affiliates, drew internationally regulated suppliers into Philippine-registered operations, launched a 24/7 helpline, and referred more than 13,000 illegal sites for blocking. Tengco summarized the approach at ICE Barcelona in January 2026: “The greatest threat to both regulators and licensed operators is not higher standards. It is the continued presence of illegal and unregulated actors that undermines trust and distorts competition.”²⁵

The data above describe the road back, because the Philippines has been there. As recently as 2022, the offshore market was estimated at nearly four times the size of the licensed one, and those wagers ran through operators that verified no ages, honored no self-exclusions, paid no taxes and answered to no one. Industry stakeholders say they are ready to put the channelization data, independent market estimates and enforcement record before legislators as the bill moves through committee.

On the evidence, the choice before the Senate is not between more gambling and less. It is between gambling the State can see and gambling it cannot.

NOTES AND SOURCES

1. Senate Bill No. 2347, the Gambling Advertising Prohibition Act, filed 26 July 2026. Provisions described are drawn from the filed measure as reported in the Philippine Daily Inquirer (31 July 2026), SunStar, Philstar.com (2 August 2026) and Asia Gaming Brief (19 August 2026), and should be verified against the enrolled text before publication.
2. On the 2022 baseline: industry estimates cited in the 2025 congressional deliberations placed grey or offshore gaming at nearly four times the size of the licensed domestic market. On the trajectory since: PAGCOR Chairman Alejandro H. Tengco, House testimony, August 2025 (more than 60% of online gambling illegal); Yield Sec monitoring figures cited by Tengco, December 2025 (licensed share above 50% for the first time); Blask demand-side model, Q1 2026 (about 51% in January, 58% by March). These are directional estimates, not regulator-reported transaction data.
3. PAGCOR reduced e-games license fees from above 50% of gaming revenue to 35% in April 2024 and 30% from January 2025. Electronic gaming GGR: ₱58.16 billion (2023) to ₱201.12 billion (2025), 50.77% of the industry’s ₱396.14 billion total (PAGCOR full-year 2025 data, as reported by Asia Gaming Brief, 16 April 2026).
4. Philippine Daily Inquirer, “Pagcor fines Ivana Alawi-linked gambling firm P1M over giveaway,” July 2026; the promotion, posted 15 July 2026, offered 100 phones worth over ₱4 million for liking the platform’s Facebook page.
5. Roland Cinco, CEO of Digirockstars and WOMO, interviewed August 25, 2026. Digirockstars operates the WOMO affiliate and influencer network, and runs marketing for PAGCOR-licensed operators. Observations on creator rate behavior reflect inbound rate quotations across the network in the Philippines, not a market survey.
6. Global Adult Tobacco Survey (GATS), Philippines, 2009, 2015 and 2021 comparison (Campaign for Tobacco-Free Kids fact sheet). The prevalence decline is generally attributed to the tobacco-control package as a whole, with the price increases of the 2012 Sin Tax Reform Act (RA 10351) credited with the largest single effect, alongside graphic health warnings (RA 10643) and the advertising restrictions.
7. Southeast Asia Tobacco Control Alliance (SEATCA) and partner monitoring, 2023–2025, on online marketing of vaporized nicotine products despite RA 11900’s restrictions.
8. Saffer & Chaloupka, “The effect of tobacco advertising bans on tobacco consumption,” Journal of Health Economics 19 (2000) 1117–1137; see also Blecher, Journal of Health Economics 27 (2008).
9. UK industry data cited in Asia Gaming Brief, 19 August 2026: approximately 80% of gambling marketing expenditure is directed online (48% direct internet, 19% affiliates, 10% social media).
10. Manila Bulletin, “CICC crackdown uncovers over 1,000 illegal online gambling sites, 100+ influencers involved,” 30 September 2025; Asia Gaming Brief, “PAGCOR flags surge in illegal online gambling via social media platforms,” 13 July 2025.
11. World Health Organization, “Gambling” fact sheet: gambling disorder affects an estimated 1.2% of the global adult population. The fact sheet lists ending gambling advertising among recommended measures, as one element of a package headed by effective regulation and well-resourced enforcement against providers; the jurisdictions that applied the advertising-ban element against licensed operators while illegal supply persisted (Italy, Belgium) are now reversing course.
12. PAGCOR exclusion programs and the National Database of Restricted Persons: self-exclusion available for 6 months (irrevocable), 1 year or 5 years; family exclusion available to a spouse, parent, or child of legal age; exclusion orders take effect in all PAGCOR-operated and PAGCOR-regulated gaming facilities. See PAGCOR, Exclusion Programs (pagcor.ph/regulatory) and the Responsible Gaming Code of Practice.
13. Observatory on Illegal Online Gambling, Data Room Nexus (2026); 2022 Parliamentary Commission of Inquiry; Italian football federation report as covered by iGaming Business (2026); SBC News (Senate review of the sponsorship ban); Portolano Cavallo (AGCOM guidelines softening the Decreto Dignità).
14. Gaming1 channelization report, citing Yield Sec data (2023–2024).
15. AFJEL, updating PwC’s 2023 study for the French regulator ANJ (2025 figures); Kansspelautoriteit (KSA) market monitoring, H1 2025.
16. Alvarez & Marsal, Online Gambling Regulation: International Precedent and Best Practice (September 2024).
17. Philippine Daily Inquirer, “Pagcor detects 276 illegal gambling sites, some linked to Pogo”; PAOCC and PNP enforcement reporting, 2025–2026.
18. AFJEL/PwC data for France on illegal-site player outcomes.
19. Republic Act No. 9211 (Tobacco Regulation Act of 2003), Secs. 16, 22, 25, 26 and 32(c), compared against the filed text of Senate Bill No. 2347 as reported (see note 1).
20. BSP Memorandum No. M-2025-029/M-2025-031 (August 2025); PAGCOR, “PAGCOR revenues down 26.64% in first half of 2026,” 30 July 2026.
21. PAGCOR testimony, late 2025 (13,399 illegal sites referred, 12,562 blocked); ₱50 million PAGCOR grant to the NBI (September 2025); GCash–CICC merchant cutoffs (March 2026).
22. Senate Bill No. 57, the Online Gambling Regulatory Act, filed by Senator Sherwin Gatchalian on 2 July 2025, pending in committee.
23. PAGCOR, Regulatory Framework for the Accreditation of Gaming Affiliates and Support Service Providers (Rev. No. 1).
24. Industry position paper submitted to Congress during the 2025 online gambling prohibition debate, as quoted in “Outright Ban vs Smart Regulation: A Legal Perspective on Online Gambling in the Philippines” (Arden Consult, 7 July 2025).
25. PAGCOR Guarantee portal (pagcor.ph), which allows the public to verify whether a gaming brand and website URL are authorized; existing PAGCOR rules already require responsible-gaming messaging and the National Problem Gambling Helpline in licensed advertising.
26. PAGCOR, “PH highlights regulatory reforms at ICE Barcelona 2026,” 21 January 2026.

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