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Gibraltar

Open in full (free)National jurisdiction

Strong first-tier hub with low tax, but rising substance/compliance cost and no EU passport — enter with genuine local presence and clear UK/EU market strategy.

18 open · 2 uncertain → 20 classes
Regulator: Gibraltar Gambling Commissioner (GGC) — Gambling Division, HM Govern… · Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 25 Oct 2026 PDF Compare

Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

Player products

  • Casino
    Open
  • Poker
    Open
  • Bingo
    Open
  • LotteryExpert confirmed
    Open
  • Sports betting
    Open
  • Other event betting
    Open
  • Horse and greyhound racing betting
    Open
  • Esports betting
    Open
  • Exchange betting
    Open
  • Pool betting
    Open
  • Virtual event betting
    Open
  • Fantasy sports
    Open
  • Skill games
    Open
  • Prediction markets
    Open
  • SweepstakesGrey zone
    Uncertain
  • Free play
    Open

Supply roles

  • Software / B2B
    Open
  • Affiliate marketingExpert confirmed
    Open
    Varies by form · 3
    • Marketing or advertising for a gambling business not carried on by a gibraltar licence holder: prohibited
    • Exempt advertising or marketing: outside_perimeter
    • Intra-group or self-supply to a licence holder: outside_perimeter
  • Payments for gamblingExpert confirmed
    Open
    Varies by form · 2
    • Customer funds held by a licensed credit institution: outside_perimeter
    • Intra-group or self-supply to a licence holder: outside_perimeter

Settlement rail

  • Crypto gamblingGrey zone
    Uncertain

Class-level certainty is graded for 3 of 20 classes.

Board briefing

Gibraltar's Gambling Act 2025 has restructured licensing into up to six licence categories (including a new standalone marketing affiliate/agency licence) and expanded Commissioner enforcement powers, but the dominant commercial pressure this cycle is external: the UK Remote Gaming Duty rise from 21% to 40% (1 April 2026) on Gibraltar-domiciled UK-facing operators.

What has changed

  • Gambling Act 2025 (Act No. 2026-04) commenced 1 April 2026, replacing the 2005 Act; regulator role split retained (Minister as Licensing Authority; Gambling Commissioner as supervisory/AML regulator).
  • Licence categories reclassified/expanded — pipeline intelligence now identifies up to six licence categories, including a standalone Marketing Affiliate/Agency Licence bringing affiliates and marketing agencies within the licensing perimeter for the first time; the Schedule 8 transitional licence for newly captured activities ends at the end of 30 September 2026.
  • A statutory register of licence holders is now mandated.
  • Commissioner's enforcement toolkit widened from a binary suspend/revoke power to administrative fines, cease-and-desist orders, inspections and suspensions, alongside a new Gambling Appeals Tribunal. The Tribunal's jurisdiction is not general: under section 141(2) it hears appeals only where a right of appeal is bestowed by the Act, section 143 excludes several decisions from appeal altogether — among them the refusal of an application for a licence under Part 4 — and a further appeal to the Supreme Court lies on a point of law only under section 144.
  • New Duties and Licence Fees Regulations 2026 introduce a £10,000 per-licence-type application fee and a staged Change-of-Control fee of up to £30,000, layered on top of existing tiered annual licence fees (£50k–£200k B2C; from £85k B2B).
  • UK Remote Gaming Duty rose from 21% to 40% (1 April 2026) — the dominant margin pressure on UK-facing operators domiciled in Gibraltar this cycle; this is a UK, not Gibraltar, tax.
  • Diversification signalled via Gibraltar's first prediction-market operator licence (issued under the outgoing 2005 Act) and the Property (Digital Assets etc) Act 2026 (Act No. 2026-09, in force 23 March 2026) recognising crypto-assets as personal property.

What to do now

  • Map current group activities (marketing, affiliate management, CRM, hosting, fund management) against the expanded licensing perimeter and apply for or regularise any newly captured licensing by 30 September 2026, the last day of the transitional period. From 1 October 2026 the position depends on which applies: no application made (exposed to the general prohibition and enforcement; no published forbearance); application made in time (the transitional licence continues until the application is determined and, if granted, until the new licence takes effect); licence or exemption confirmed.
  • Model UK Remote Gaming Duty at 40% into UK-facing revenue forecasts and stress-test margins for Gibraltar-domiciled operators with high UK-revenue concentration.
  • Budget for the new £10,000 per-licence-type application fee and up to £30,000 staged Change-of-Control fee under the Duties and Licence Fees Regulations 2026, and seek T1 confirmation of how these interact with existing tiered annual fees.
  • Track Commissioner guidance on GOSS/marketing-affiliate categorisation and Part 5 (personal management licence) commencement before finalising senior-management structures.

What to watch

  • Separate commencement notice for Part 5 (Regulated Individuals / personal management licences).
  • End of the Schedule 8 transitional period for newly captured activities at the end of 30 September 2026; from 1 October 2026 a provider without a licence, an exemption or an application made in time is exposed.
  • Ratification of the Gibraltar-EU Treaty and the probable phased transaction tax (15%/16%/17%) however this will not impact gambling services as the tax is on goods only.
  • Further UK fiscal measures affecting Remote Gaming Duty or the point-of-consumption tax base.
  • Uptake and regulatory treatment of prediction-market and digital-asset products as diversification plays.

11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

01 · What kind of market is this?

Overview

Favourable

Gibraltar's gambling sector is governed by the Gambling Act 2025, which came into operation on 1 April 2026 and replaced the Gambling Act 2005 as the controlling statute for new applications. The Act widened the licensing perimeter beyond operators themselves to capture B2B suppliers, contracted-out…

Full analysis · 138 words

Gibraltar's gambling sector is governed by the Gambling Act 2025, which came into operation on 1 April 2026 and replaced the Gambling Act 2005 as the controlling statute for new applications. The Act widened the licensing perimeter beyond operators themselves to capture B2B suppliers, contracted-out service providers, marketing affiliates and controllers holding more than 25 percent of a licensed company, with a six-month transitional filing window under Schedule 8 that closed on or about 1 October 2026. Existing 2005 Act licence holders continue under automatic grandfathering. Alongside the main gambling perimeter, the Prediction Market Regulations 2026 create a separate, non-gambling authorisation track for prediction market activity, with its own fee structure. Gibraltar-incorporated operators remain separately exposed to UK Gambling Commission oversight where they hold GB point-of-consumption licences, as illustrated by regulatory settlements announced between August and October 2026.

  • Substance requirements under the 2025 Act eliminate 'brass plate' setups; higher compliance/staffing cost
  • Loss of EU passporting post-Brexit
  • Higher annual licence fees under the new regime
  • Tight local labour market for compliance staff
Not reviewed Information added after the 26 Sep 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

Gibraltar's gambling regulatory architecture underwent its most substantial reform in two decades this cycle. The Gambling Act 2025 came into force on 1 April 2026, replacing the 2005 Act and restructuring the regulatory model into separate licensing and supervisory functions, a British Overseas Territory framework historically aligned with UK-style gambling regulation but operating under its own enabling statute. Related fee regulations under the new Act and a linked digital-property law, the Property (Digital Assets etc) Act 2026, dated 23 March 2026, also took effect. The reform establishes a materially different institutional model from the single-authority approach that preceded it, and sets the baseline against which every other category in this brief should be read this cycle.

ConfirmedNot reviewed1 post-review update · Not reviewedRead full analysis & tables →
02 · Can we get a licence?

Licensing and regulation

Favourable

The Gambling Act 2025, in force from 1 April 2026, governs licensing in Gibraltar and is administered by the Gambling Commissioner. Schedule 8 of the Act gave businesses newly captured by the widened licensing perimeter, specifically B2B suppliers, contracted-out service providers, marketing affilia…

Full analysis · 168 words

The Gambling Act 2025, in force from 1 April 2026, governs licensing in Gibraltar and is administered by the Gambling Commissioner. Schedule 8 of the Act gave businesses newly captured by the widened licensing perimeter, specifically B2B suppliers, contracted-out service providers, marketing affiliates and persons controlling more than 25 percent of a licensed company, a six-month transitional licence window running from the 1 April 2026 commencement. That window closed on or about 1 October 2026: a business in one of those categories had to file a full and complete application by that point to retain trading rights, and failure to do so removes the transitional protection Schedule 8 provided. Businesses that already held a licence under the 2005 Act are automatically grandfathered under Schedule 8 and are not subject to this filing deadline. The practical effect of the window closing is a materially wider population of businesses now holding, or needing to hold, a direct licence from the Commissioner rather than operating under cover of an operator's licence.

Not reviewed Information added after the 26 Sep 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

The Gambling Act 2025 (Act 2026-04) is the governing instrument for licensing in Gibraltar. Schedule 8 of the Act established a six-month transitional licence for businesses newly brought into the licensing perimeter by the GOSS activity category (affiliate and marketing services; holding or managing customer funds connected to gambling), running from the Act's 1 April 2026 commencement. That transitional window closed on 1 October 2026 as a matter of the statute's own fixed term. A business that became newly licensable under this category and did not file a full licence application before the deadline no longer holds transitional protection and must proceed, if it continues the activity, through the full application process, which is now the only route available for this category. No development was evidenced this cycle regarding licensing conditions for the established gambling activity classes.

Not reviewedRead update

The Gambling Act 2025 splits licensing authority from supervision and enforcement, a structural departure from the single Licensing Authority model under the 2005 Act. Licensing now sits with the Authority while investigation, sanction and enforcement functions vest in the Commissioner. A tiered B2B licensing framework replaces the prior approach, allowing suppliers to apply for licences calibrated to the scale of their operations rather than a one-size-fits-all category. Sections 55 to 77 of the Act, covering the regulated-individuals regime, were expressly excluded from the 1 April 2026 commencement, and no commencement notice for those sections has yet been located. Operators should treat the personal-licensing sub-regime as not yet in effect pending that notice.

ConfirmedNot reviewed2 post-review updates · Not reviewedRead full analysis & tables →
03 · How hard is entry, really?

Market entry in practice

Mixed

Entry requires a Gibraltar company, effective control and a local office, fit-and-proper checks and product testing. Approvals historically take c.2–6 months. The 2025 Act raises substance requirements (staff, offices, local tax contribution), increasing entry cost and demanding local leadership acr…

Full analysis · 56 words

Entry requires a Gibraltar company, effective control and a local office, fit-and-proper checks and product testing. Approvals historically take c.2–6 months. The 2025 Act raises substance requirements (staff, offices, local tax contribution), increasing entry cost and demanding local leadership across compliance, risk, AML, finance and often trading/product. The tight local labour market is a practical bottleneck.

ProbableNot reviewedRead full analysis & tables →
04 · What do the licences cost?

Licence fees

Mixed

Gibraltar's remote licence fees are set by the Gambling (Duties and Licence Fees) Regulations 2026 (LN.2026/065), made under sections 155(1) and 175 of the Gambling Act 2025 and in force from 1 April 2026, which revoke the 2018 Regulations that earlier guidance relied on. Annual B2C fees are banded …

Full analysis · 456 words

Gibraltar's remote licence fees are set by the Gambling (Duties and Licence Fees) Regulations 2026 (LN.2026/065), made under sections 155(1) and 175 of the Gambling Act 2025 and in force from 1 April 2026, which revoke the 2018 Regulations that earlier guidance relied on. Annual B2C fees are banded on annual gross yield per licence rather than charged at a flat rate: £50,000 below £20m, £100,000 between £20m and £300m, and £200,000 above £300m (Schedule 3). An operator holding both a betting and a gaming licence pays the sum of the two, not a single combined fee. Betting intermediaries pay £100,000 annually and betting agents £50,000. B2B annual fees are tiered by the supplier's exposure to the Gibraltar market: gaming aggregators and platform suppliers pay £85,000 for a single vertical plus £15,000 for each additional one - with no double charge where a supplier performs both platform and aggregation functions, the higher principal fee applying instead - while direct-integration suppliers pay £85,000 (Tier 1), £50,000 (Tier 2) or £20,000 (Tier 3) according to gross sales to Gibraltar licence holders and the number of approved integrations - so the commonly-quoted £85,000 B2B figure is the ceiling, not the entry point. Contracted-out fraud and risk, CDD and compliance, identity-verification and CRM functions attract £50,000 each. Application fees (Schedule 2) are charged per principal activity and are non-refundable: £30,000 for B2C betting or gaming, £20,000 for lottery, £15,000 for a betting intermediary or agent, £20,000 for gaming aggregation or platform supply and £10,000 for direct integration. Annual fees fall due on 1 April and must be paid by 30 April, apportioned from the start of the calendar quarter in which the licence takes effect (regulation 6(4)-(5)). Separate schedules price change of control at £3,000 rising to a complexity-assessed maximum of £30,000 (Schedule 4), content-provider approval at £1,000 (Schedule 5), regulated-individual approval at £500 for a five-year first approval and £200 per material change (Schedule 6), and duplicate documentation at £50 (Schedule 7). Non-remote operations are priced separately by LN.2026/088 (in force 7 May 2026, revoking the Gambling (Fees) Regulations 2016): a £150,000 application fee, £100,000 annually for non-remote gaming and £50,000 for the making or acceptance of bets, £5,000 for a material change to an approval, and £250 per approved betting premises per licensing year on top of the annual fee. No published annual fee cap exists under the current instruments; the £425,000 cap quoted in pre-2025 guidance was a feature of the now-revoked 2018 Regulations. Prediction markets are charged separately under the Prediction Market (Fees and Duties) Regulations 2026 (LN.2026/316), in force 13 August 2026: a £30,000 application fee, a £100,000 annual fee, and a general prediction market duty of 0.15% of commission charged with no exemption threshold.

Not reviewed Information added after the 26 Sep 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

New fee and duty regulations made under the Gambling Act 2025's fee-setting power set betting and gaming duty at 0.15% of gross gambling profit, with the first £100,000 of gross profit exempt from duty. Intermediary duty is set at the same 0.15% rate, but the regulations show no equivalent exemption threshold for intermediary duty, an asymmetry that increases the effective cost of intermediary-structured arrangements relative to direct betting and gaming operations. The headline duty rate itself is unchanged from the prior structure; the cost picture this cycle is shaped by the institutional transition around it rather than by a change in the rate.

ConfirmedNot reviewed1 post-review update · Not reviewedIn expert review scopeRead full analysis & tables →
05 · What is the tax take?

Tax

Mixed

Gambling duties are set by Schedule 1 to LN.2026/065 and charged under section 175 of the Gambling Act 2025 at 0.15% - a deliberately low rate by international standards - but on three distinct statutory bases rather than a single measure of yield. General betting duty is charged on gross betting pr…

Full analysis · 213 words

Gambling duties are charged under section 175 of the Gambling Act 2025 and Schedule 1 to the Gambling (Duties and Licence Fees) Regulations 2026, LN.2026/065, at 0.15% on three bases: general betting duty on gross betting profit, general gaming duty on gross gaming profit, and betting-intermediary or agency duty on gross intermediary profit (commission received). The first £100,000 is exempt for general betting and general gaming duty, but not for intermediary or agency duty. Free bets, free spins, bonuses and other promotional incentives are not deductible in computing gross profit. Duty is paid in four quarterly instalments due on 1 April, 1 July, 1 October and 1 January, each payable by the last day of the month in which it falls due, and the Regulations contain an anti-avoidance rule for artificial arrangements. For non-remote operations, LN.2026/088 (regulation 5) charges B2C premises operators a duty of £1,000 per gaming machine made available per licensing year, whether supplied by the licence holder or a connected person; B2B machine suppliers pay £250 per licensing year plus £1,000 per machine supplied for use on premises to which the public have access, with no fee for equipment used solely for placing bets; and machine-only premises licences pay £250 per premises and £100 per machine. Gibraltar has no VAT.

ConfirmedNot reviewed · changed since expert reviewIn expert review scopeRead full analysis & tables →
06 · Can we move player money?

Payments and banking

Favourable

Gibraltar operates an open, UK-aligned financial system. Customer funds must move through company-controlled bank and merchant accounts. The Gambling Commissioner is the AML/CFT regulator for the sector under the Proceeds of Crime Act 2015 (Gibraltar). Banking access is generally available but opera…

Full analysis · 59 words

Gibraltar operates an open, UK-aligned financial system. Customer funds must move through company-controlled bank and merchant accounts. The Gambling Commissioner is the AML/CFT regulator for the sector under the Proceeds of Crime Act 2015 (Gibraltar). Banking access is generally available but operators must maintain disciplined controls; the Gibraltar Authorisation Regime (GAR) supports PSP/EMI access to the UK market post-Brexit.

Not reviewed Information added after the 26 Sep 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

Holding or managing customer funds in connection with gambling was brought into the Gambling Act 2025's licensing perimeter as part of the GOSS activity category from the Act's 1 April 2026 commencement. Businesses newly caught by this change were given a six-month transitional licence under Schedule 8 of the Act, and that window closed on 1 October 2026. A business holding or managing customer funds for a Gibraltar-licensed gambling operator that did not file a full licence application before the deadline no longer holds transitional protection for that activity and must now proceed through the full application process to continue lawfully.

ProbableNot reviewed1 post-review update · Not reviewedRead full analysis & tables →
07 · Can we advertise?

Marketing

Mixed

Under the Gambling Act 2025, all marketing activities conducted 'in or from Gibraltar' fall within regulatory scope, bringing affiliates, group marketing hubs and creative agencies into the GOSS licensing perimeter. Marketing requires a support-service licence unless provided by a group company alre…

Full analysis · 69 words

Under the Gambling Act 2025, all marketing activities conducted 'in or from Gibraltar' fall within regulatory scope, bringing affiliates, group marketing hubs and creative agencies into the GOSS licensing perimeter. Marketing requires a support-service licence unless provided by a group company already licensed in Gibraltar. The regulator has signalled that marketing carried out from minimal-presence Gibraltar subsidiaries (often for VAT savings) would likely be refused a marketing support licence.

ProbableNot reviewedRead full analysis & tables →
08 · What must the platform meet?

Technical compliance

Favourable

Operators must use tested systems and approved test-house certifications; even cloud-hosted operators need robust, tested controls. Geolocation/age-verification (PASS scheme) and product testing form part of licensing. The 2025 Act's technical-standards and digitised-reporting requirements (AML, fin…

Full analysis · 42 words

Operators must use tested systems and approved test-house certifications; even cloud-hosted operators need robust, tested controls. Geolocation/age-verification (PASS scheme) and product testing form part of licensing. The 2025 Act's technical-standards and digitised-reporting requirements (AML, financial disclosures, safer gambling) are being phased in.

ProbableNot reviewedRead full analysis & tables →
09 · Can we ship through apps and platforms?

Distribution and platforms

Mixed

The Gambling Act 2025 introduces a new GOSS licence category covering owners and marketing activity, sitting alongside the existing B2C and B2B categories. This is a direct expansion of the distribution and platform-rules perimeter: businesses whose role is ownership or marketing of gambling product…

Full analysis · 94 words

The Gambling Act 2025 introduces a new GOSS licence category covering owners and marketing activity, sitting alongside the existing B2C and B2B categories. This is a direct expansion of the distribution and platform-rules perimeter: businesses whose role is ownership or marketing of gambling products, rather than direct operation, now fall within a dedicated licensing category rather than being addressed indirectly through operator-facing licences. GOSS fees are set by LN.2026/065, with application fees in Schedule 2 and annual fees in Schedule 3. No further detail on GOSS-specific conditions or marketing-restriction mechanics was evidenced this cycle.

ProbableNot reviewedRead full analysis & tables →
10 · How hard does the regulator enforce?

Enforcement

Favourable

Gibraltar's enforcement landscape is being reshaped this cycle by the Gambling Act 2025's split of licensing from enforcement, effective 1 April 2026: the Commissioner and the new Gambling Division now hold the active supervisory and enforcement function, distinct from the Authority's licensing role…

Full analysis · 174 words

Gibraltar's enforcement landscape is being reshaped this cycle by the Gambling Act 2025's split of licensing from enforcement, effective 1 April 2026: the Commissioner and the new Gambling Division now hold the active supervisory and enforcement function, distinct from the Authority's licensing role. This is a durable, primary-legislation change, assessed Probable given convergent T3 secondary sourcing but no T1 Gambling Division primary confirmation this cycle. Separately, a GBP 100,000 regulatory settlement over sanctions-screening deficiencies at an unnamed Gibraltar-licensed B2C operator was reported as published 29 April 2026, but this claim is assessed only Uncertain: it rests solely on a T3 secondary compliance guide, and the Commissioner's own decision notice was not located this cycle. No other enforcement events surfaced. The gaps register also notes that the seed-injected regulator URL intended for the Gambling Division resolved instead to the UK Gambling Commission, structurally limiting this cycle's ability to reach Gibraltar's own primary enforcement sourcing. Enforcement risk should therefore be read as structurally rising (new architecture, new Division) while the one reported case-level outcome remains unconfirmed.

Not reviewed Information added after the 26 Sep 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

The Gambling Act 2025 introduces a materially expanded enforcement toolkit, replacing the 2005 Act's reliance on licence suspension or revocation as the Commissioner's principal instrument. The Act provides for proportionate sanctions and structured investigation processes, and establishes a new Gambling Appeals Tribunal to hear challenges to Commissioner decisions. This gives the Commissioner a graduated range of responses to compliance failures rather than a binary suspend-or-revoke choice, a change that generally reduces existential risk for operators facing a moderate compliance issue. No case register for the Gambling Appeals Tribunal has yet been located, so its practical operation remains untested this cycle. The expansion of regulated scope to prediction markets, sweepstakes and marketing services also widens the population of activity now subject to the Commissioner's enforcement remit.

ProbableNot reviewed1 post-review update · Not reviewed2 enforcement eventsRead full analysis & tables →
11 · What is coming?

Outlook

Favourable

The outlook is positive-to-stable on Gibraltar's own regulatory settings but increasingly shaped by external tax pressure: the 2025 Act modernises the licensing and enforcement framework and repositions Gibraltar as a top-tier hub following its removal from the European Commission's high-risk list, …

Full analysis · 234 words

The outlook is positive-to-stable on Gibraltar's own regulatory settings but increasingly shaped by external tax pressure: the 2025 Act modernises the licensing and enforcement framework and repositions Gibraltar as a top-tier hub following its removal from the European Commission's high-risk list, while the pending Gibraltar-EU Treaty (Schengen access) could reshape labour and market-access economics via a probable phased transaction tax (15%/16%/17%) however this will not impact gambling services as the tax is on goods only. The dominant commercial driver this cycle, however, is external: the UK Remote Gaming Duty rose from 21% to 40% with effect from 1 April 2026, materially compressing margins for the many Gibraltar-domiciled operators with high UK-revenue dependency (reportedly ~75% for some incumbents), and is a more immediate threat than the 2025 Act itself. Gibraltar's response includes visible diversification signals — the jurisdiction's first prediction-market operator licence (issued under the outgoing 2005 Act, operator not named on current sourcing) and the Property (Digital Assets etc) Act 2026 (Act No. 2026-09, in force 23 March 2026) recognising crypto-assets as personal property — pointing to a deliberate strategic pivot toward non-UK, product-diversified revenue. Compliance costs are rising (new tiered annual fees, a £10,000 per-licence-type application fee and a staged Change-of-Control fee of up to £30,000 under the Duties and Licence Fees Regulations 2026) and the GOSS/marketing-affiliate perimeter remains partly unclear pending Commissioner guidance and the awaited Part 5 (personal management licence) commencement.

Not reviewed Information added after the 26 Sep 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

The Property (Digital Assets etc) Act 2026, dated 23 March 2026 and passed in the same legislative session as the Gambling Act 2025, grants certain digital assets, including crypto-tokens, statutory personal-property status under Gibraltar law. This mirrors equivalent UK legislation that entered into force on 2 December 2025. The Act is a forward-looking structural development rather than a gambling-specific rule change, but it is relevant to blockchain-based prediction and gaming products, giving Gibraltar a statutory property-law basis for such products ahead of most comparator jurisdictions. Separately, the commencement notice for the regulated-individuals regime under the Gambling Act 2025 remains an open item on the reform horizon.

ProbableNot reviewed · changed since expert review1 post-review update · Not reviewedIn expert review scopeRead full analysis & tables →
Evidential record & source register 1 enforcement · 8 red flags · 14 sources · Expand full record

Enforcement record

What the regulator has actually done, newest first. 1 recorded event.

  1. 1 Apr 2026
    Gambling Commissioner · All licensees
    Confirmed

What gets operators fined

8 red flags (3 high, 3 medium, 1 low) and 5 controls that address them.

  • high
    Operating support services (marketing, CRM, hosting, fund management) in/from Gibraltar without the relevant GOSS or Marketing Affiliate/Agency licence
    The 2025 Act's expanded perimeter now captures marketing affiliates and agencies directly; non-compliant firms risk enforcement once the six-month transition window closes.
  • high
    Brass-plate Gibraltar entity with minimal local staff/office presence
    Schedule 2 substance requirements can lead to licence refusal or revocation under the 2025 Act.
  • high
    B2B supply into a Gibraltar-licensed operator from abroad without a Gibraltar licence
    §30 extends the licensing perimeter to any-location supply into Gibraltar-licensed operators.
  • medium
    VAT-saving Gibraltar marketing subsidiary with minimal presence
    Likely to be refused a Marketing Affiliate/Agency licence under the new standalone marketing licensing category.
  • medium
    Application and change-of-control fee exposure under the Gambling (Duties and Licence Fees) Regulations 2026: application fees run to £30,000 for a new B2C betting or gaming licence (Schedule 2), and a change-of-control notice carries a £3,000 base fee rising to a maximum of £30,000 on the Licensing Authority's complexity assessment (Schedule 4)
    Application fees are non-refundable and payable on submission, and the change-of-control balance must be paid before the notice is treated as complete — so both land as unbudgeted cash exposure on entry and on any restructuring or M&A. Earlier commentary reported a flat £10,000 per licence type; Schedule 2 sets no such flat fee, and £10,000 is only the B2B direct-integration line, so a B2C applicant budgeting from that figure is short by £20,000.
  • medium
    Part 5 (regulated functions and regulated individuals) is the only Part of the Gambling Act 2025 left uncommenced — LN.2026/064 brought the Act into force on 1 April 2026 "All except – ss.55- 77", and Part 5 is exactly ss.55–77
    Key function holders perform regulated functions with no commenced statutory personal-licensing framework, while LN.2026/065 (in force 1 April 2026) already sets application fees for Regulated Individuals at regulation 9 — the fee machinery for approvals is live before the approval regime it serves. Licence holders cannot obtain Commissioner approval under ss.64–74 and must manage significant-influence appointments on undertakings rather than statutory approval until a further commencement notice is made.
  • low
    Sweepstakes and social-casino platforms remain outside Gibraltar's licensing perimeter
    Growing competitive-distortion risk for licensed incumbents now facing higher fees, AML obligations and 40% UK duty exposure, while unlicensed adjacent products face no equivalent cost base.
  • critical
    High UK-revenue concentration among Gibraltar-domiciled operators
    UK Remote Gaming Duty rose from 21% to 40% (1 April 2026); operators with high UK-revenue dependency face material margin compression independent of Gibraltar's own tax settings.

Controls

  • 001
    GOSS perimeter mapping
    Map marketing/CRM/hosting/fund functions against GOSS scope and license accordingly.
  • 002
    Substance demonstration
    Maintain staff, office, infrastructure and local tax contribution per Schedule 2.
  • 003
    Dual-regulation compliance
    Maintain UKGC compliance for UK-facing books and local EU licences for EU markets.
  • 004
    AML/CFT programme (POCA 2015)
    Maintain AML/CFT controls under the Commissioner's supervisory role.
  • 005
    Product testing / certification
    Obtain approved test-house certification pre-launch.

Worked scenarios

5 entry scenarios, each with the move we would make.

UK-facing sportsbook seeking GI base

Needs B2C licence, substance, UKGC dual regulation, 0.15% GI duty plus UK POC tax.

Do this: Apply for B2C licence; build local team; confirm UKGC alignment.

Games studio supplying GI-licensed casinos from Malta

§30 requires a GI licence even for abroad-based supply into GI licensees.

Do this: Obtain B2B licence or operate sheltered under a licensed operator.

Group marketing hub in Gibraltar

Marketing in/from Gibraltar requires GOSS licence unless intra-group from a licensed entity; minimal-presence VAT-saving hubs likely refused.

Do this: Assess intra-group exemption; otherwise license and add substance.

Operator targeting EU consumers from GI

No EU passporting post-Brexit; local EU licences required.

Do this: Obtain host-state EU licences; do not rely on GI licence for EU access.

Senior manager appointment pending Part 5

Part 5 personal management licence regime not yet commenced; monitor for separate notice.

Do this: Prepare approved-persons documentation; track Part 5 commencement.

What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Market opportunity. No separately published domestic-consumer GGR or USD market-size point estimate; only sector GDP-contribution (~20-25%) and headcount figures available.
  • searched: Gibraltar online gambling GGR market size 2025
  • searched: Gibraltar gambling sector revenue annual report
  • searched: Gambling Division Gibraltar GGR statistics
  • checked: gamblingdivision.gov.gi
Competitive landscape. Exact licensed-operator count under the new 2025-Act categories not yet republished; historical figures only.
  • searched: Gibraltar licensed gambling operators count 2026
  • searched: Gambling Division Gibraltar licence register
  • searched: Gibraltar B2C B2B GOSS licensees number
  • checked: gamblingdivision.gov.gi

Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.

14 sources · 7 tier 1 · 2 tier 2 · 5 tier 3

No.SourceTierVerification
GI-GAMBLING-ACT-2025T1 of 4
GI-GAMBLING-ACT-2005T1 of 4
Gambling (Duties and Licence Fees) Regulations 2026 (LN.2026/065)T1 of 4
GI-PROPERTY-DIGITAL-ASSETS-ACT-2026T1 of 4
GI-PREDICTION-MARKET-REGS-2026T1 of 4
GI-PREDICTION-MARKET-FEES-REGS-2026T1 of 4
Gambling (Non-Remote Licence Fees and Duties) Regulations 2026 (LN.2026/088)T1 of 4
gov.ukT2 of 4
yogonet.comT2 of 4
GI-HASSANS-SCOPET3 of 4
GI-RAMPARTS-STRUCTURALT3 of 4
GI-IGB-NEWERAT3 of 4
GI-PWC-TAXT3 of 4
GI-RAMPARTS-BILLT3 of 4

Claims with their own provenance

Gambling Act 2025 replaced the 2005 Act with most provisions in force 1 April 2026.

GI-CP-001 · T1 of 4 · published 6 Apr 2026 · Confirmed
Pipeline-sourced · From Advennt research · Rule detail not yet extracted

Gaming duty is 0.15% on gross profits with the first GBP 100,000 exempt.

GI-CP-002 · T1 of 4 · published 10 Mar 2026 · Confirmed
Pipeline-sourced · From Advennt research · Rule detail not yet extracted