Fintech Company Registration in the Philippines (BSP)

Fintech is one of the Philippines’ fastest-growing investment sectors — but it also has one of the more layered regulatory environments. Getting the right licence before launch is critical: operating regulated payment or e-money services without BSP authorisation carries serious penalties.

Two tracks: tech vs. licensed financial activity

The first decision for any foreign fintech investor is which track applies:

Track 1 — Technology / SaaS: Building software, APIs, or platforms that financial institutions use (core banking tech, fraud tools, KYC software). This is not a regulated financial activity. A 100% foreign-owned Philippine corporation can do this with standard business registration and no BSP licence required. Export-enterprise structures apply if the clients are primarily overseas.

Track 2 — Licensed financial activity: Issuing e-money, operating a payment system, facilitating fund transfers, lending, or dealing in virtual assets. These require BSP authorisation and involve specific capital, governance, and AML/CTF compliance requirements.

BSP licences relevant to foreign fintech operators

• Electronic Money Issuer (EMI) — Issues stored value instruments (e-wallets). Two categories: EMI-Bank (BSP-supervised banks) and EMI-Non-Bank (non-bank entities). Non-bank EMIs have foreign equity considerations under banking-adjacent regulations.
• Virtual Asset Service Provider (VASP) — Entities that exchange, transfer, or custody virtual assets must register with BSP under Circular 1108. Important: BSP extended the VASP registration moratorium indefinitely from September 1, 2025 — new VASP licences are not currently being issued. Foreign operators considering a virtual asset business should explore the SEC’s Crypto Asset Service Provider (CASP) pathway or acquiring an existing VASP. AML/CTF compliance obligations are extensive in all cases.
• Payment System Operator (PSO) / Operator of Payment System (OPS) — Entities operating payment infrastructure must notify or register with BSP under the National Payment Systems Act (RA 11127).
• Lending Company / Financing Company — SEC-registered and subject to the Lending Company Regulation Act or Financing Company Act; foreign ownership may be restricted depending on activity scope.

Foreign ownership limits in BSP-licensed entities are not uniform — they depend on the specific licence type and how the entity is classified under banking and investment laws. We map your activity to the correct licence before you incorporate.

The registration process

1. Activity classification — confirm whether BSP licensing is required and which licence applies.
2. Corporate incorporation — SEC registration of the Philippine entity, with capital structured to meet BSP minimums.
3. BSP application — preparation of the licence application, business plan, AML/CTF manuals, governance documents, and IT security assessments.
4. Pre-licensing compliance — BSP may conduct an examination or require a proof-of-concept period.
5. Local registrations — BIR, Mayor’s permit, AMLC registration for covered institutions.
6. Ongoing compliance — BSP Circulars impose continuing capital adequacy, reporting, and audit obligations.

Timeline varies significantly by licence type — from 3 months for a VASP registration to 12+ months for an EMI-Bank licence.

Fintech registration is one of our most complex engagement types. We work with experienced BSP-facing compliance counsel and won’t underquote the work involved. Book a consultation to map your licence path, or see our pricing for corporate incorporation and compliance retainers. For ownership structure questions, see 100% foreign ownership rules.