Global FinTech Guide
Country Name
Financial advisory and broking services including robo advisory and auto-trading
FinTechs belonging to this category offer advisory and broking services for investments usually via an internet platform.

Robo advisory services usually offer an investment proposition following a series of questions concerning the personal financial background and the risk-bearing capacity of the user. Sometimes the respective platform also enables the user to directly execute the proposed investment. 

Auto-trading concerns all services which automatically trade on behalf of the customer according to his or her specifications.

Apart from that some FinTechs collect and offer merely or as an ancillary service market information or operate comparison portals to increase the transparency of the capital markets and to help the investor with his decision-making. 

There are also FinTech-advertising-services which advertise various financial services or products.


Attitude of the country towards modern financial advisory and broking services

Generally, regulations applicable to more traditional payment channels are applicable to FinTech companies providing the same kind of products and services via a platform or application.

Legal affairs

Obligations and requirements to provide financial advisory and broking services, or ancillary services described above

Providing financial advisory services to Philippine residents would be considered doing business, thus, entities that render financial advisory services, brokerage services and adjacent services (which cater to Philippine clients) must register and obtain a license from the SEC. This entails submission of documentary requirements depending on the corporate vehicle (subsidiary or branch) to be registered.

Offering and Sale of Securities

Entities engaging in advisory and brokering services would need to ensure that they are not effectively offering securities in the Philippines. Securities cannot be sold or offered for sale or distribution to the public in the Philippines unless they have been registered with and approved by the SEC, unless these are exempt, or offered via transactions considered exempt, from the registration requirement.

Dealing in Securities

The business of buying or selling securities in the Philippines is also a regulated activity. No person is allowed to engage in the business of buying or selling securities in the Philippines as a broker or dealer, or act as a salesman, or an associated person of any broker or dealer unless registered as such with the SEC. A person engaged in the offering or selling of mutual funds or pooled funds must be registered as a certified investment solicitor with the SEC. 

Dealing in securities includes the making or offering to make with any person or inducing or attempting to induce a person to enter into or to offer to enter into any agreement for or with a view to acquiring, disposing of, or subscribing for securities.   

Incidental to its function as a buyer and seller of securities, a broker dealer can provide its clients information regarding the securities being offered, manage its clients’ investment portfolio, and provide advisory services.

Trust Business or Investment Management Activities

Lastly, providers of financial advisory and adjacent services will need to ensure that the services do not fall under trust business or investment management activities, which only certain type of entities are allowed to undertake and render such services. Please see related discussion on Asset and Portfolio Management above.

Additional comments regarding the legal situation for financial advisory and broking services, or adjacent services or what FinTech’s must be aware of in this business area

If a FinTech company will only be conducting market research, create and provide market information or operate comparison portals in the Philippines, it may not need to obtain the registrations described above except to secure primary registration or the license to do business from the SEC. We do note that insofar as a FinTech entity allows third parties to use its platform to provide information to users or advise and help third parties advertise their financial services or securities, the FinTech entity may be viewed as engaging in mass media in the Philippines (which is 100% reserved to Philippine nationals) and/or advertising (which is 70% reserved to Philippine nationals). 

In terms of potential directions, the SEC has launched the Philifintech Innovation Office (PIO) with a primary mandate to: 

    (a) serve as the first point of contact for FinTech companies that are applying for registration, or existing FinTech companies that have been operating or are introducing new FinTech products, in navigating the SEC regulatory landscape;
    (b) document, analyse, and understand FinTech business models and their possible impacts on the market and its participants; and
    (c) formulate and execute regulatory responses that temper the promotion of the growth of FinTech firms with policy geared at protecting investors and market participants through the policy development functions of the SEC.

Economic conditions

Market size for financial advisory and broking services as well as adjacent services and biggest companies in this business area

There is no publicly available information regarding the number of brokerage firms, dealers in securities and financial advisory services providers. Similarly, there are no publicly available information as regards the revenues, customers, and market shares of these entities.

Additional comments regarding the economic situation for financial advisory and broking services as well as adjacent services or what FinTech’s must be aware of in this business area




© 2022, SyCip Salazar Hernandez & Gatmaitan. All rights reserved by SyCip Salazar Hernandez & Gatmaitan as author and the owner of the copyright in this chapter. SyCip Salazar Hernandez & Gatmaitan has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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