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When the Bangko Sentral ng Pilipinas (BSP) confirmed that Apple Pay and Google Pay could launch in the Philippines without registering as Operators of Payment Systems (OPS), it quietly set a precedent—one that should not go unnoticed by the Web3 community, regulators, and policymakers alike.
Eliezer Rabadon is a versatile tech entrepreneur and innovator, serving as the CEO of DvCode Technologies Inc. and Co-Founder of Web3 Bulacan. With expertise in app, web, and game development, he is a Certified Smart Contract Developer and an ethical hacker recognized by a leading global tech company. Beyond his technical pursuits, he also leads a local Rotary club and contributes to national tech publications. He sits on the board of a blockchain-focused organization, where he heads its Education and Training Committee.
The logic was clear: these platforms do not hold or process user funds. They simply act as facilitators—bridging the user to their existing credit cards or e-wallets. The money doesn’t flow through them; it flows through the banks and regulated financial institutions to which users are already connected.
This distinction matters.
Now consider the world of Web3. Many non-custodial wallets and decentralized finance (DeFi) tools operate on exactly the same principle. These platforms do not store user funds, nor do they act as intermediaries in the traditional financial sense. Instead, they provide interfaces for users to interact with blockchain protocols, where control of assets remains firmly in the hands of the user.
Yet under the Securities and Exchange Commission’s (SEC) recently implemented Crypto Asset Service Provider (CASP) Guidelines, these non-custodial platforms may be required to register—particularly if they interact with smart contracts.
This creates a regulatory mismatch.
We now have a situation where two sets of technologies—both non-custodial, both facilitators, both technically neutral—are being treated in very different ways.
This is not a call for deregulation. On the contrary, regulation plays a vital role in protecting consumers and maintaining financial integrity. But regulation must be appropriate to the risk. Platforms that never touch user funds should not be burdened by the same requirements as those that do.
Under the CASP rules, registration demands include a ₱100 million paid-up capital requirement, a physical presence in the Philippines, and an extensive set of documentation for approval. These are significant hurdles, especially for open-source, non-custodial tool providers. Many of these platforms are community-driven, protocol-based, and don’t follow a traditional corporate model. Applying the same standards meant for centralized custodial services misses the mark.
To its credit, the SEC has built in a mechanism for registration exemptions, allowing certain entities to apply for relief if they can demonstrate that their operations pose minimal risk and serve the public interest. This is promising. But for the exemption route to be meaningful, it must be clear, accessible, and consistently applied.
If we want the Philippines to lead in the digital economy, we must adopt a principled and technologically neutral approach to regulation. We need to draw a clear line between custody and access, between risk and interface.
The BSP’s decision on Apple Pay and Google Pay offers the blueprint. The same clarity and nuance must now be extended to Web3. If a platform does not hold your money, it should not be regulated as if it does.
This is more than a policy issue—it’s a chance to demonstrate forward-thinking governance. A signal to innovators that the Philippines understands the technology, respects its nuances, and is willing to build a future-ready regulatory environment.
Let’s get this right—not just for compliance, but for competitiveness.
This Op-Ed is published on BitPinas: OPINION | A Case for Regulatory Consistency in the Digital Economy
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