Gibraltar’s 2025 Gambling Act: Details, New Opportunities, and Challenges

For decades, the peninsula has served as a headquarters for many of the world’s gaming brands. The Gambling Act 2025 marks a full refresh of the local framework. The old 2005 statute was replaced, and a clearer course for the next chapter was set. The new regulation took effect on October 1, with a six-month transition period to ensure maximum urgency. The objective is to adapt to modern rules, stronger accountability, and a visible economic presence on the ground.

Reasons for Adoption

Gibraltar aims for its framework to align with the current industry standards. The territory is leaning into credibility, clearer accountability, and measurable economic presence. The regulator is equipped to supervise the entire value chain and maintain a pragmatic, risk-based approach. Serious firms are welcome, but visibility, responsibility, and consumer protection must be evident.

The previous statute dated from 2005. A fast-moving market, Brexit dynamics, and a renewed pace of reputational change created the window for change. The new regime commenced on October 1, with a six-month transition period to bring existing licensees across. Coverage is broader than before; managed and controlled ins or outs of Gibraltar are used as the anchor to determine who falls within the net.

The perimeter is defined by control and management. Any gambling enterprise based in or operating from Gibraltar can be captured, even if parts of the operation are located elsewhere. The emphasis shifts from product labels to the decision-making process and the location of leadership.

Headline metrics that frame Gibraltar’s industry profile:

• ~3,200 people employed across licensed companies;
• 54 operator groups active on the peninsula;
• about one-fifth of local GDP generated by the sector;
• ~$145 million paid in corporate tax last year;
• ~$53 million in PAYE contributions over the same period;
• 83 total licensees appointed;
• 49 B2C permissions currently in force;
• 34 B2B permissions currently in force.

Oversight stretches across the chain. B2C brands, B2B technology vendors, and functions that underpin day-to-day activity all come under the lens. Marketing hubs, CRM teams, managed trading desks, hosting centres, and similar units may require permissions in their own right.

This wider view closes gaps that previously allowed complex group structures to sit partly outside supervision. The intention is to align permissions with actual activity, draw shared-service teams into clear regulatory oversight, and ensure that governance aligns with the reality of modern, multi-jurisdictional models.

The Act moves from principles on paper to measurable obligations. It links permission to operate with visible presence, clearer roles, and stronger oversight. The aim is to align licences with how modern groups actually function.

The core shifts that define the new regime:

1. Economic substance on the ground. Licensees must demonstrate genuine activity in Gibraltar through the presence of people, premises, infrastructure, and local tax contributions. Brass-plate companies are no longer acceptable.
2. A wider licensing perimeter. Distinct permissions now cover B2C, B2B, and operator support services. Marketing, CRM, managed trading, hosting, and similar functions may need their own consents.
3. Approved Persons regime. Senior decision-makers face personal vetting and ongoing fitness checks. Accountability now attaches to individuals, not just corporate entities.
4. Marketing under supervision. Promotion “in or from Gibraltar” falls within the scope. Affiliates, group marketing hubs, and creative teams can be captured where activity is directed from the territory.
5. Stronger enforcement tools. The Gambling Commissioner can issue administrative fines, compel changes, order suspensions, and conduct inspections. The toolkit supports consistent and timely interventions.
6. Digital reporting uplift. More structured returns will apply across AML, financial disclosures, technical standards, and safer gambling. Data pipelines are expected to be timely, accurate, and auditable.

Appeals and Stakeholders

A stronger rulebook needs a credible pathway to challenge decisions. Gibraltar introduces an independent tribunal to examine regulatory actions and ensure that enforcement remains fair, consistent, and reviewable. This layer is designed to give operators and individuals confidence that oversight comes with balanced adjudication.

Key features of the Gambling Appeals Tribunal:

• independent review of the commissioner’s decisions;
• appeals on refusals, suspensions, revocations, and fines;
• transparent process and reasoned outcomes;
• procedural safeguards for operators and approved persons;
• signal of legal accountability to the market.

The Act touches every layer of the ecosystem, from group headquarters to frontline teams. The immediate effect is structural and has a direct impact on map activities, assigned responsibility, and evidence substance.

The main implications for each stakeholder type:

Operators

Large groups must clearly define where management and control reside, then align licences with actual functions. Expect multiple applications across B2C, B2B, and support units, plus updates to governance, reporting lines, and local footprint plans. Internal playbooks should clearly define who owns risk, who is responsible for signing off on regulatory returns, and how shared services interact with licensed entities.

B2B and Third-Party Support

Vendors and service hubs face clearer visibility. Hosting centres, managed trading desks, marketing and CRM units, and RNG or platform teams may need their own permissions. Contracts should reflect licence status, data flows, and audit rights, while SLAs must include regulatory response times, incident reporting, and change control.

Senior Managers

Personal accountability moves to the front. Approved Persons will undergo vetting, maintain fitness, and evidence decision-making discipline. Role descriptions, delegation matrices, and board papers should show a clean chain of responsibility across compliance, AML, safer gambling, finance, and technology.

Regulator and Players

Supervision gains sharper tools and a wider lens, but also a duty to apply rules consistently. For consumers, the outcomes include more stringent standards, clearer pathways to remediation, and enhanced data for proactive, safer gambling measures.

Grey Areas to Consider

The framework sets clear intent, but several touchpoints still need official clarification. Early practice notes, secondary rules, and case outcomes will shape how businesses implement the new perimeter.

The topics where stakeholders are seeking further direction:

1. Marketing “in or from Gibraltar.” Where the activity sits within a group matters. It is unclear when central brand teams, affiliates, or agencies require their own approvals and when intra-group work can be carved out.
2. Definition of support services. Managed trading, RNG provision, hosting, advertising, and CRM are named, but the boundaries are not fully drawn. Guidance is needed on when mixed teams or embedded units cross the line into licensable activity.
3. Hybrid value chains. Some models blend B2B supply with B2C influence. Operators want to know how these cross-border structures will be categorised in practice.
4. Single tailored licence and dual permissions. Groups ask whether one bespoke permit can cover intertwined functions or if separate approvals are mandatory.
5. Shared services spanning hubs. Centralised risk, AML, or marketing units that straddle Gibraltar and other locations need rules on control tests, reporting lines, and accountability.
6. Precedents and timelines. Early decisions by the commissioner and the tribunal will set markers on scope, proportionality, and acceptable evidence of substance.

Comparison with Rival Hubs

Gibraltar presents a clear proposition. The territory leans into credibility and proportional oversight rather than easy entry or light-touch paperwork. That stance targets brands that value predictable supervision over short-term speed.

How Gibraltar sets out its proposition in 2025:

Brand and Regulation

The country’s model sits between Malta’s flexibility and the Isle of Man’s stricter template. Supervisors apply a risk-based approach with room for measured discretion. This means that serious firms are welcome, but visibility, governance, and consumer safeguards must be real.

A “no-questions-asked” path is off the table. Licensees are expected to respect laws in other markets and obtain local permissions where necessary. This is a rules-first approach that prioritises long-term trust over convenience.

Competitive Edge in a Crowded Field

The reform replaces a 2005 statute with a contemporary framework and a dedicated appeals route. The tribunal strengthens due process and helps calibrate enforcement over time. Recent reputational gains, including removal from the European Commission’s high-risk list, support the pitch to multinational groups.

Historic links to the UK continue to matter. Market access, experienced talent, and established infrastructure provide the territory with a solid foundation to build upon, while the new Act brings shared services into clearer regulatory focus.

Practical Hurdles

Change creates friction before benefits land. Implementation will absorb management time and budget, especially for multi-entity groups.

Near-term challenges most teams should expect:

1. Cost uplift. Multiple licence streams, personal approvals, and enhanced reporting will add fees and internal workload, with smaller operators feeling the pressure most.
2. People and footprint. New rules mean more local presence. Recruitment may be tight in a compact labour market, even as cross-border access from Spain improves with anticipated UK-EU arrangements.
3. Transitional mechanics. Existing licensees are exempt from the new rules, but new applications must be filed within a six-month window from October 1, 2025. Documentation and sequencing will need disciplined project plans.
4. Complex group mapping. Marketing hubs, managed trading, hosting, and CRM units may require stand-alone permissions. Hybrid supply models will need careful categorisation as they await further guidance.
5. Data and controls build-out. Digitised returns across AML, finance, safer gambling, and technical standards demand reliable pipelines, audit trails, and defined ownership for submissions.

What to Watch Next

The Gibraltar framework is in force, but its shape will be defined by practice. Early signals will help teams plan resourcing, structure licences, and develop the trajectory with confidence.

Key developments to track:

1. Secondary rules and guidance. Practice notes on marketing, support services, and intra-group carve-outs will set the perimeter and reduce guesswork.
2. First enforcement patterns. Initial inspections, fines, or remedial orders will show how proportionality is applied in real cases.
3. Early tribunal outcomes. Appeals will test reasoning, calibrate sanctions, and establish standards for future decisions.
4. Licensing precedents. Approvals for hybrid models, shared services, and cross-border teams will indicate when single tailored licences are sufficient and when dual permissions are required.
5. Labour market dynamics. Recruitment capacity, frontier worker flow from Spain, and the pace of local hiring will determine how quickly firms can meet substance expectations.

The Main Things about Gibraltar’s 2025 Gambling Act

The country’s rulebook has been revised to align with the actual operations of modern gaming businesses. Expectations are higher, but the direction is clear, and the pathway is defined.

Key takeaways to keep in mind:

• The 2025 Act replaces the 2005 law and anchors the scope to activity managed or controlled in or from Gibraltar.
• Licences now cover B2C, B2B, and support services, with senior managers brought under an Approved Persons regime.
• The presence is mandatory, with people, premises, and taxes required to move beyond brass-plate structures.
• Enforcement powers are strengthened, while an independent tribunal adds due process and transparency to the review.
• Year one involves costs, staffing, and transition work, but guidance, precedents, and early cases will help reduce uncertainty.