Philippines: Clarification on the Definition of Digital Bank 

November, 2021 - Segolene Leffy

The Bangko Sentral ng Pilipinas (“BSP”) in Memorandum No. M-2021-053 dated 13 October 2021 clarified the definition of “digital banks”. A digital bank refers to a bank which offers financial products and services that are processed end-to-end through a digital platform and/or electronic channels with no physical branch/sub-branch or branch-lite unit offering the same.

The BSP noted that certain banks belonging to other categories use the phrase “digital bank” in their marketing campaigns even if these banks do not fall under the definition of a digital bank as provided above. Considering this, the BSP has reminded these entities that under Circular No. 1105 dated 2 December 2020, only a bank that is granted the license to operate as a digital bank may represent itself to the public as such in connection with its business name. In this respect, a bank should represent itself consistent with its bank classification and the products and/or services that it is authorized to offer.

Banks belonging to other categories may offer financial products and services through a digital platform and/or electronic channels. If such is the case, these banks may market itself as a bank offering “digital banking products or services” or other equivalent terms, provided that such banks have secured the requisite BSP license on electronic payment and financial services for these digital banking products or services.


The information provided here is for information purposes only, and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.



Jude Ocampo
Partner, Ocampo & Suralvo Law Offices
[email protected]

Abigael Demdam

Abigael Demdam
Senior Associate, Ocampo & Suralvo Law Offices
[email protected]


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