Payment System Operator Registration with the BSP: A Step-by-Step Guide

If your business maintains a platform that enables payments or fund transfers, operates a network for payments through a payment instrument, or processes payments on behalf of others, you are likely an Operator of a Payment System (OPS) and must register with the Bangko Sentral ng Pilipinas (BSP). Registration is required under Section 10 of Republic Act No. 11127, the National Payment Systems Act, and BSP Circular No. 1049. The path is straightforward: confirm you qualify as an OPS, prepare your application documents, submit them to the BSP's Payment System Oversight Department, pay the registration fee, and secure your Certificate of Registration.

Who Must Register as an Operator of a Payment System

Under BSP Circular No. 1049, an OPS is a person that performs any of the following functions:

• Maintains the platform that enables payments or fund transfers, whether or not the source and destination accounts are held with the same or different institutions;
• Operates the system or network that enables payments or fund transfers through a payment instrument;
• Provides a system that processes payments on behalf of any person or the government; or
• Performs similar activities as may be determined by the Monetary Board.

This definition tracks Section 4(l) of RA 11127, which describes an operator as any person who provides clearing or settlement services in a payment system, or who defines, prescribes, designs, controls, or maintains the operational framework for the system. Examples include owning or operating a computer application that enables payments, setting the rules by which funds may be transferred, or enabling merchants and billers to accept a specific payment instrument.

The Registration Requirements

The documents required depend on whether the OPS has already commenced operations.

For OPS that have yet to commence operations, submit the following to the appropriate BSP department:

1. A duly accomplished Application for Registration (Form 1), signed by the president, chief executive officer, or a senior officer holding an equivalent position;
2. A Business Plan describing the existing business, business model, and target markets; and
3. A copy of the business registration or permit indicating the line of business, issued by the city or municipality with territorial jurisdiction over the principal place of business for the current period.

For OPS already operating at the effectivity of the Circular, the same three documents are required, except the business permit must cover the place of establishment and operation. The BSP may require additional documents during evaluation.

Deadline for Registration

An OPS that has not commenced operations must register within one (1) month from the start of operations. Registration is required prior to commencement in three instances: when a regulator or government agency requires appropriate action from the BSP before the business starts; when the OPS offers remittance services or similar money service business activities; and in such other circumstances as the Monetary Board may determine.

An OPS already operating at the effectivity of the Circular was required to register not later than three (3) months from that effectivity.

Registration Fees and the Certificate of Registration

Upon issuance of the Certificate of Registration (COR), an OPS pays a registration fee of P20,000.00. A fee of P1,000.00 is collected for replacement of a COR for any reason.

After receiving a complete application or notification, the BSP issues a provisional COR (PCOR), valid for the period stated in it unless indicated otherwise in the list of PCORs published on the BSP website. The BSP then issues the COR if warranted and if the submitted documents satisfy regulatory requirements.

Special Rules for Banks and Electronic Money Issuers

Banks and EMIs that operate as an OPS do not go through the full application process. They submit a notification of their activities as an OPS to the appropriate BSP department, including a description of the existing business, business model, and target markets, signed by the president, chief executive officer, or an equivalent senior officer. The notification and supporting documents are due not later than three (3) months from the effectivity of the Circular, or within one (1) month from the start of operations as an OPS, as appropriate.

Reporting Obligations After Registration

Registered OPS, except banks and EMIs registered as OPS, must notify the appropriate BSP department of certain events within five (5) business days from occurrence. These include commencement of operations (for OPS required to register prior to operations); a change of ownership or control resulting in ownership or control of at least twenty percent (20%) of voting shares, or enabling a person to elect or be elected as a director; suspension or revocation of permits, licenses, or other authorities issued by other government agencies; a change in key officers or authorized representatives; and a change of registered or business name.

For a change of registered or business name, the BSP issues a new COR upon payment of the P1,000.00 replacement fee, submission of the amended Articles of Incorporation or equivalent document, and return of the old COR.

Consequences of Operating Without Registration

When an OPS required to register is found operating without registration, the Monetary Board issues a directive to comply. If the OPS remains unregistered, the Monetary Board issues an order to stop operating and to take immediate action to register. The BSP may also inform other regulators and government agencies that the entity is operating without registration. Violations may subject the OPS and its directors, officers, or employees to sanctions under Section 19 of RA 11127.

Frequently asked questions

Do I need to register my payment app with the BSP? If your app maintains a platform that enables payments or fund transfers, operates a network for payments through a payment instrument, or processes payments for others, it is likely covered and must register as an OPS.

How much is the BSP registration fee for an operator of a payment system? The registration fee is P20,000.00, payable upon issuance of the Certificate of Registration. Replacing a COR costs P1,000.00.

How long do I have to register my payment system business? An OPS that has yet to commence operations generally registers within one (1) month from the start of operations, but must register before operating if it offers remittance services, if a regulator requires BSP action beforehand, or in other cases the Monetary Board determines.

Practical takeaways

• Confirm whether your business performs any OPS function under BSP Circular No. 1049 before launching.
• Prepare Form 1, a Business Plan, and a current business permit for submission to the BSP.
• Budget P20,000.00 for the registration fee and P1,000.00 for any COR replacement.
• Banks and EMIs register by notification, not full application.
• Calendar the five-business-day notice requirement for ownership changes, key officer changes, and name changes.

Primary sources

The rules discussed above are drawn from the following primary sources. Where the firm's library holds the document as a PDF it is embedded here in full; the rest are cited by title.

Governance Policy for Operators of Payment SystemOpen in Law LibraryDownload PDF

Rules and Regulations on the Registration of Operators of Payment SystemsOpen in Law LibraryDownload PDF

• REPUBLIC ACT NO. 11127 - AN ACT PROVIDING FOR THE REGULATION AND SUPERVISION OF PAYMENT SYSTEMS

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.