BSP’s Digital Payments Economic Indicator Isn’t Audited Yet

What It Means

• BSP is treating bank-reported transaction growth as a digital payments economic indicator before it has run its own systemic count.
• Deputy Governor Mamerto Tangonan said transaction volumes rose 10 to 50 percent after banks waived transfer fees, based on what banks told him directly.
• The banks supplying that growth data are the same institutions BSP is separately reviewing over fee pricing compliance.
• Smaller banks without comparable digital volume are being measured against a growth story set by the largest players’ own numbers.
• A formal systemic measurement is due at the end of July, the first point where the current figures meet independent verification.

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BSP Deputy Governor Mamerto Tangonan told reporters this week that digital transaction volumes have climbed anywhere from 10 to 50 percent since banks began waiving fund transfer fees. He said BSP will take a more systemic measurement at month end. Until then, the closest thing the central bank has to a digital payments economic indicator comes from what banks are telling him directly, on volumes they have every incentive to report favorably.

A Number Built on Phone Calls, Not on a Count

Tangonan’s figures did not come from a survey, a settlement system report, or an audited transaction ledger. They came from banks describing their own volume increases in conversation. That is a reasonable first read of a fast moving trend, and Tangonan was straightforward that a fuller measurement is still weeks away. But in the interval, his comments are already circulating as evidence that BSP’s fee pricing rules are working, that informality is falling, and that the digital payments economic indicator BSP has long wanted is finally moving in the right direction. That reading gets repeated as fact before BSP has checked the underlying digital payments economic indicator against its own records.

The distinction matters because the same circular that produced these fee waivers, Circular 1238, also set a cost-basis pricing rule that BSP has been separately enforcing against banks and e-wallets. The institutions reporting strong volume growth right now are not neutral observers. They are also the subjects of an active compliance review over whether their transfer pricing actually reflects real costs, the same review whose outcome the digital payments economic indicator is now being used to preempt.

The Compliance Story and the Growth Story Share the Same Source

A bank under scrutiny for its fee structure has an obvious reason to emphasize rising transaction volumes. Higher volume reads as proof the fee waiver is working as intended, which is a useful data point to have on record while regulators are still checking whether the underlying pricing complies with BSP’s own formula. This does not require any bank to misstate a number. It only requires BSP to rely, for now, on figures supplied by parties who benefit from a favorable growth narrative landing before the compliance question is settled.

This is not the first time BSP has shifted the burden of proof onto banks rather than waiting for its own verification before acting on a policy assumption. Tangonan’s own framing ties the stakes directly to macro policy. He has said that wider digital payment use can raise GDP per capita and cut informal employment, citing a Bank for International Settlements estimate. That is the policy logic behind treating transaction volume as a digital payments economic indicator in the first place. It is also exactly why the source of the interim numbers deserves more scrutiny than a passing television remark usually gets.

Smaller Institutions Carry a Different Kind of Exposure

BSP has already shown, through rules built to protect the banking system’s own liability position, that it will design policy around the interests of the institutions it supervises when the two align. Rural banks, thrift banks, and cooperative institutions that have not yet waived fees, or whose digital volumes are too small to move a national percentage, do not get to contribute to this early growth story. They remain under the same cost-basis compliance expectations as the larger banks, without the offsetting narrative benefit of being cited as evidence that BSP’s policy is succeeding. A digital payments economic indicator built mostly on the reporting of dominant banks quietly writes smaller institutions out of the picture. They still face the same regulatory obligations, without any of the credit.

The Month End Count Tests the Digital Payments Economic Indicator Itself

The systemic measurement Tangonan referenced is not a formality. It is the first point at which the current 10 to 50 percent range gets checked against BSP’s own data rather than bank self-reporting. If the formal count lands meaningfully below the range banks have been describing, the gap becomes its own story, one about how quickly informal figures got folded into a national growth narrative. If it lands within range, the interim reliance on bank reporting will look reasonable in hindsight. Neither outcome is knowable yet, which is the point. The digital payments economic indicator currently being cited in public commentary has not been tested against anything except itself, and every week that passes before the count is published is a week the untested version keeps circulating as settled fact.

The banks that waived fees first get to be the evidence for a policy win before BSP has independently confirmed the scale of that win, and the institutions still working through compliance carry the same obligations without any of the same credit. Until the month end count lands, the digital payments economic indicator belongs to the banks that supplied it.

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