The dawning potential of digital banking

Maria Margarita D. Mallari-Acaban

Owing to the significant role of digital platforms especially during the pandemic, the Bangko Sentral ng Pilipinas (BSP) recently recognized “digital banks” as a separate and distinct bank category with the issuance by the Monetary Board of the Digital Banking Framework on Nov. 26, followed by the issuance of the Guidelines on establishment of digital banks (BSP Circular 1105) on Dec. 2. BSP Governor Benjamin E. Diokno has also acknowledged the role of these banks “as additional partners in further promoting market efficiencies and expanding access of Filipinos to a broad range of financial services” consistent with the BSP’s financial inclusiveness agenda.


Does merely having an online banking platform, app or website (which most banks currently have) make a bank a digital bank? Not necessarily.

An online banking facility merely supplements the operations of traditional banks by allowing alternative ways to transfer money, check account balances or pay bills. A digital bank, on the other hand, is essentially an online-only bank.

Under the amended Manual of Regulations for Banks (MORB), a “digital bank” refers to an entity that 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 financial products and services. This essentially requires the entire banking and service delivery process to be digitized — not just parts of it.

While a physical branch is not required, regulations still mandate that digital banks maintain a principal or head office in the Philippines. This houses the offices of management and serves as the main point of contact for stakeholders that include the BSP, other regulators and customers.


Under the BSP Circular 1105, digital banks essentially operate and are regulated the same way as bricks and mortar banks. It has a similar license to grant loans, accept savings, time deposits, and foreign currency deposits, as well as invest in readily marketable bonds and other debt securities, commercial paper and accounts receivable, drafts, and bills of exchange. It can also act as a correspondent for other financial institutions, issue money products and credit cards, buy and sell foreign exchange, and present, market, sell and service microinsurance products.

However, digital banks are quite different in many ways from their traditional counterparts and in many cases, offer more convenient banking solutions.


Without the requirement of going to a physical branch, digital banks will allow clients to save time and effort in all transactions such as account opening, Know Your Customer (KYC) procedures and depositing cash or checks. Digital banks invest significantly in technology to allow facial recognition in conducting KYC and Anti-Money Laundering (AML) procedures or the use of fingerprint or digital signatures (instead of the traditional wet signatures) to transact — all by simply using a mobile phone or laptop. This is especially useful during the pandemic as it practically eliminates the need to physically go to a bank branch for face-to-face contact with bank personnel.

This platform also benefits the banks as they are able to save time and resources due, in large part, to the reduction in manpower costs, supplies (no need for deposit slips and other forms) and rent among others. Theoretically, the savings from these expenses would allow them to invest and constantly upgrade their IT infrastructure to ensure a safe and secure banking experience for its clients. Moreover, these savings on overhead costs may allow them to offer higher interest rates and possibly remove minimum maintaining balance requirements or service fees.

Digital banks may also offer true 24-hour/7 days a week accessibility on all banking transactions. While the online banking services of current bricks and mortar banks allow round-the-clock access to bank accounts for money transfers and billing payments, access to loan applications or certain financial products will still require clients to visit the bank.


Because of the obvious advantage digital banks can offer, numerous banks have been showing interest in applying for a digital license. But what does it take to secure a digital bank license?

According to the BSP Circular 1105, the qualifications in terms of stockholdings cite that (1) foreign individuals or foreign non-bank corporations may own or control up to a combined 40% of the voting stock of the digital bank; and (2) Filipino individuals or domestic non-bank corporations may each own up to 40% of the voting stock of a digital bank. Qualified foreign banks may also own or control up to 100% of voting stock.

An applicant must submit a detailed review and assessment of the supporting IT systems and infrastructure vis-à-vis the digital banking model, and the applicable requirements in offering Electronic Payments and Financial Services (EPFS) under Section 701 of the BSP Circular. In addition, at least one member of the Board of Directors (BoD) and one senior management office should have a minimum of three years of experience and knowledge in operating a business in the field of technology or e-commerce.

Existing bricks-and-mortar banks are also allowed to convert to digital banks under certain conditions. The Circular specifically requires the bank to meet the minimum P1-billion capital requirement and transition plan (including the divestment or closure of branches or branch-lite units) within three years from approval of conversion. Once approved for conversion, however, the bank may no longer engage or renew transactions not associated with those allowed for a digital bank and within six months, shall phase out all inherent powers and activities under special authorities not normally associated with a digital bank.

Given these requirements under the BSP Circular 1105, it appears that existing banks that are commonly known or marketed as “digital banks” or meet all the qualifications of a digital bank but have not converted must secure a digital bank license from the BSP before they can officially operate as a digital bank.


What remains to be seen, however, is whether bricks-and-mortar banks will immediately choose to convert to a full digital bank or retain their current license with some digital bank or online platform features to offer the best of both worlds to their clients. While digital banks may make the banking experience more convenient, the absence of a physical branch may not necessarily be ideal for some as it often translates to lack of physical and personal connection. Admittedly, many long-time banking clients still prefer a personal relationship with their banks and in the banking world, an established relationship between a bank and its client clearly goes a long way for both parties.

Regardless, it is safe to say that digital banking in the Philippines is finally online and here to stay. While our progress in the digital banking space has not been that swift, it is hoped that the financial inclusiveness agenda of the BSP will accelerate the expansion of digital banks to reach the unbanked and unserved population.

At the end of the day, it is always better to have inclusive choices available for everyone to encourage financial literacy and security. For as long as the market is assured of the integrity of the bank’s IT infrastructure and full compliance with the BSP Circular 1105 as well as strict adherence to BSP Corporate Governance Guidelines, digital banks can serve as a true alternative to traditional banks.

With the New Normal likely to remain in the foreseeable future, remote and virtual access to banks will not only be convenient to all but also essential for public health and safety.

This article is for general information only and is not a substitute for professional advice where the facts and circumstances warrant. The views and opinions expressed above are those of the author and do not necessarily represent the views of SGV & Co.

Maria Margarita D. Mallari-Acaban is a Tax Partner of SGV & Co.

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