Analysis
Philippine Crypto Exchanges May Not List Privacy Coins Under New BSP Token Rules
What Memorandum M-2026-023 requires before a VASP lists a coin or token.
The short version: Philippine VASPs may not list or support privacy coins, and must check every coin and token against six due-diligence pillars before listing it, under BSP Memorandum M-2026-023, signed on 5 June 2026 (M-2026-023). The rules apply to the 8 active VASPs on the BSP's list.
The Six Pillars
- Issuer's background
- Market maturity
- Use cases
- Transparency, traceability and security
- Redemption, liquidity and reserves
- Legal and compliance
VASPs may build their own listing frameworks, taking these guidelines into account. They must also keep monitoring the listing criteria and set thresholds that trigger a delisting (M-2026-023).
Background
- Who needs a licence. BSP Circular No. 1108, dated 26 January 2021, replaced the earlier rules for virtual currency exchanges. It covers exchange between virtual assets and fiat currency, exchange between virtual assets, transfer of virtual assets, and safekeeping or administration of virtual assets (BSP FAQ). Providers need a BSP Certificate of Authority; those already operating had to apply within three months of the circular taking effect (Circular No. 1108).
- Travel rule. Every virtual asset transfer is treated as a cross-border wire transfer; for transfers of P50,000 or more, VASPs must obtain and pass on originator and beneficiary information (BSP FAQ).
- Licence moratorium. The regular application window for new VASP licences closed for three years from 1 September 2022. Applications that had passed Stage 2 by 31 August 2022 were still processed, and existing BSP-supervised financial institutions with a composite rating of at least “stable” may still apply (M-2022-035). From 1 September 2025 the BSP continued the moratorium on new VASP licences, subject to reassessment (M-2025-031).
- Token listings. Under Memorandum M-2026-023 (signed 5 June 2026), VASPs must run due diligence on coins and tokens under six pillars, monitor listed assets and define delisting triggers. Privacy coins may not be listed or supported (M-2026-023).
Summary of the BSP documents linked. The Securities and Exchange Commission's separate rules for crypto-asset service providers are not covered: sec.gov.ph blocks our network. Not legal advice.
Sources
- BSP list of VASPs www.bsp.gov.ph
- BSP Circular No. 1108 www.bsp.gov.ph
- BSP FAQ on Circular No. 1108 www.bsp.gov.ph
- BSP Memorandum M-2022-035 www.bsp.gov.ph
- BSP Memorandum M-2025-031 www.bsp.gov.ph
- BSP Memorandum M-2026-023 www.bsp.gov.ph