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Gibraltar Gambling Act 2025 Goes Live – The End of Operator-Centric Licensing
On 1 April 2026, Gibraltar retired its 2005 Gambling Act and switched on the Gambling Act 2025 – the same morning the UK's 40% Remote Gaming Duty took effect. We tracked the parliamentary vote and the first fortnight: the Rock now licenses activities, not operators.
Timeline – From Consultation to Commencement
The Gambling Division under Commissioner Andrew Lyman spent 2023 to early 2025 consulting on a replacement for the 2005 Act. By June 2025, Hassans and Ramparts were briefing clients to expect a 1 October 2025 commencement. That date slipped.
On 4 December 2025, the UK Autumn Budget landed a 40% Remote Gaming Duty from 1 April 2026 – a fiscal event that reset every Gibraltar boardroom's 2026 planning. On 18 March 2026, the Gibraltar Parliament unanimously passed the Gambling Bill 2025 (B. 13/25). Minister for Justice, Trade and Industry Nigel Feetham led; Opposition GSD's Roy Clinton stated there was "no political divide" on gaming.
The Act was enacted on 23 March 2026. Commencement followed on 1 April 2026 – the same day UK RGD jumped from 21% to 40%. The first prediction-markets licence was issued 4 April 2026.
Key Takeaway
Gibraltar's new Act commenced the same day UK gambling tax doubled. Operators are repricing their cost stack for two structural shocks at once, not one.
What Actually Changed – Entity to Activity
The 2005 Act licensed the operator. The 2025 Act regulates activities, regardless of who performs them or where the entity is incorporated.
Section 17 lists the regulated activities and, at Section 17(1)(f), introduces Gambling Operator Support Services (GOSS): advertising and marketing, customer-fund custody by non-licensees, and group holding entities where the gambling business is carried on elsewhere. Section 19 widens "facilities for remote gambling" to include content aggregation, platform services, software, fraud prevention, and CRM – pulling B2B providers deeper into the perimeter.
Newly captured activity includes affiliate marketers in or from Gibraltar, group marketing hubs, shared-service teams, holding companies whose subsidiaries hold licences elsewhere, fund custodians outside an operator licence, B2B providers supplying Gibraltar licensees from abroad, and betting exchanges and intermediaries.
Part 5 adds a Regulated Individuals framework similar to the UKGC's Personal Management Licence regime. Part 8 hands the Commissioner graduated sanctions: administrative fines, public statements, cease-and-desist notices, and prohibition orders. A new Gambling Appeals Tribunal hears challenges.
Our work on casino licensing frameworks compared covers how GOSS compares to MGA, UKGC, and Curaçao's reformed framework.
The GOSS Licence – Scope, Fees, and Substance
The GOSS licence is the biggest single operational change. Scope under Section 17(1)(f) covers marketing services for gambling, group holding entities for foreign-licensed gambling business, customer-fund custody outside a licensee or regulated financial institution, and "such other activities" the Minister designates by order.
The numbers:
- Annual fee: £50,000
- Application fee: £8,000 non-refundable
- Term: 5 years
- Transitional window: 6 months from 1 April 2026
- Full application deadline: 1 October 2026
For a group like Entain, Bet365, or 888, the exercise is structural. Every group entity performing marketing, affiliate management, CRM, fund custody, or holding functions must be mapped to a licence category. B2C licensees can cover group marketing under an existing B2C licence at no extra fee; B2B licensees need a separate marketing licence (no additional fee per Feetham). Approved-Persons filings under Part 5 run in parallel.
Substance matters. The Gambling Division reviews management and control, not just server location. Intra-group carve-outs apply only by ministerial discretion. Bet365's triple-licence structure and 888's multi-jurisdictional stack are the reference cases for slotting GOSS into existing compliance architecture.
Key Takeaway
GOSS costs £58,000 to secure and £50,000 a year to keep. B2C licensees can absorb group marketing without a second fee. B2B licensees cannot. Map every group entity before 1 October 2026 or risk a prohibition order.
Affiliates and Marketing – Who Actually Needs a Licence
The trigger is advertising or marketing "in or from Gibraltar" – the phrase that will carry more regulatory weight than any other in the new Act. The exemption is narrow: an affiliate avoids GOSS only if (i) the marketing is primarily targeted at a Gibraltar audience, and (ii) the person is in the business of advertising and is not part of a Gibraltar-licensed gambling group.
Having substance on the Rock does not create an automatic right to GOSS – ministerial discretion applies to every grant. Affiliates that treated Gibraltar presence as neutral now face a licensing decision they did not face under the 2005 Act.
Penalties are serious. On summary conviction, up to six months' imprisonment plus the statutory maximum fine. On indictment, up to two years' imprisonment and an unlimited fine. The Commissioner can also impose administrative fines, suspend licences, and make prohibition orders under Part 8 without going to court.
For readers evaluating operator legitimacy during the transition, our guide on how to verify a casino licence covers the Gambling Division register lookup and status timing between April and October 2026.
The Cost Stack – New Fees Plus UK RGD
The existing tax regime survives the Act unchanged: remote gaming duty at 0.15% of GGY, gambling business tax at 1% of revenues (capped £425,000, floored £85,000 per year), corporate tax at 12.5%.
The licence-fee schedule is new:
- B2C / B2B: £100,000 per annum
- B2B Support Services: £85,000 per annum
- GOSS: £50,000 per annum plus £8,000 application
- Term: 5 years
The external pressure is the story. UK's Remote Gaming Duty hike to 40% landed the same day the Act commenced. Trade-press modelling cited by iGaming Business puts Gibraltar's public-revenue loss at roughly $203 million and around one-third of government revenue – figures we attribute rather than underwrite.
Commissioner Lyman's framing to iGaming Business was blunt: William Hill, Entain, and Lottoland had already announced Gibraltar cost reductions, driven mainly by the UK duty hike rather than the Act. Evoke (parent of 888 and William Hill) launched a strategic review in December 2025 with an estimated £125–135 million annual RGD hit. Entain's CEO Stella David flagged a ~£200 million annual cost rising to £150 million per year from 2027.
We have not seen confirmed mass relocation from Gibraltar citing the 2025 Act specifically. Bet365's partial Malta re-domicile predates this Act and was a Brexit-era decision. The two narratives – UK tax pressure and Gibraltar activity-based licensing – need to stay separated.
Six-Month Transition Map
The transitional window is short and the workload is heavy.
1 April 2026 – commencement. Legacy 2005-Act licences continue under transitional arrangements. New licence categories open.
April 2026. First prediction-markets licence issued 4 April. Gambling Division begins triaging GOSS filings.
April to June 2026. Secondary regulations expected on the "in or from Gibraltar" test and intra-group carve-out mechanics.
By July 2026. Approved-Persons filings under Part 5 intensify. The GOSS window narrows.
1 October 2026 – hard deadline. Transitional status expires. All activity-specific licences must be in place.
Post-October 2026. The Commissioner's administrative-penalty powers are fully operational. First test cases expected on GOSS scope and the affiliate exemption.
Key Takeaway
Operators have six months from 1 April 2026 to file every licence their group activities require. Missing the 1 October deadline is not a paperwork issue – it exposes the group to prohibition orders and criminal liability.
Operator and Industry Reaction
Ramparts' Peter Howitt described the Act as a "structural shift in regulatory scope and supervision" and flagged grey zones in "support services." Hassans warned affiliate and marketing agencies not to assume they sit outside scope.
Commissioner Lyman told iGaming Business: "Any gambling business now managed and controlled in or from Gibraltar potentially falls within scope," adding, "If we drive business away, it will be business we don't want." Feetham framed the new enforcement toolkit as a "flexible framework" replacing the "nuclear option" of licence revocation. The Gibraltar Betting and Gaming Association was broadly supportive.
Open concerns include the ambiguity of "in or from Gibraltar," intra-group marketing mechanics across the B2C/B2B/GOSS split, and the Gambling Division's capacity to process a flood of GOSS applications inside six months.
The Market the Act Applies To
Gibraltar's gambling sector is a concentrated, high-value cluster. Roughly 25% of global online betting majors have presence on the Rock – a safer framing than the often-repeated "60% of global online gambling traffic" figure, which we flag as disputed. Licensed operator count sits at 54 per Company.gi's April 2026 list.
Sector employment runs at 3,200 to 3,400 people. Gaming contributes an estimated 20–30% of Gibraltar GDP. 2024 tax contribution was approximately £110 million corporate tax plus £40 million PAYE.
For brands holding a UKGC licence alongside Gibraltar, the compliance load is substantial across both jurisdictions. Our list of UKGC-regulated UK market operators covers the brands most exposed. The broader context sits inside European regulatory convergence, which the Gibraltar Act accelerates.
Comparison – 2005 Act vs 2025 Act
| Dimension | Gambling Act 2005 | Gambling Act 2025 |
|---|---|---|
| Licensing basis | Operator/entity holding infrastructure | Regulated activity, regardless of entity |
| B2C / B2B fees | Legacy schedule | £100,000 per annum |
| B2B Support Services | Not a separate category | £85,000 per annum |
| GOSS (marketing/holding/custody) | Not licensed | £50,000 p.a. + £8,000 application |
| Affiliate marketing in/from Gibraltar | Outside scope | Licensable unless narrow exemption |
| Group holding companies | Outside scope | Licensable under GOSS |
| B2B supplying Gibraltar licensees from abroad | Outside scope | In scope via Section 19 |
| Key-person approvals | Limited | Part 5 Regulated Individuals regime |
| Commissioner sanctions | Licence revocation primary tool | Administrative fines, public statements, prohibition orders |
| Appeals | Ad-hoc | Gambling Appeals Tribunal |
| Criminal penalty (on indictment) | Variable | Up to 2 years + unlimited fine |
| Licence term | Variable | 5 years |
Key Takeaway
The 2025 Act does not raise the headline tax rate. It widens the licensing perimeter to cover activity that was previously unlicensed, and hands the Commissioner enforcement tools short of revocation. The cost shock is GOSS fees plus compliance build, not duty.
What We're Watching
Three things matter between now and 1 October 2026. First, the secondary regulations on the "in or from Gibraltar" test. A narrow reading pulls most affiliate operations inside the perimeter; a broader reading leaves targeted-market affiliates outside it.
Second, intra-group carve-out practice. B2C licensees can absorb group marketing at no extra cost, but the mechanics – which entities, which contracts, which service-level terms – are not yet settled in published guidance. The first dozen GOSS determinations will set the de facto template.
Third, the UK cost stack. The 40% RGD is the structural event compressing operator margins. If the UK duty hike drives a group to consolidate outside Gibraltar, the 2025 Act will be blamed in the trade press even when the causation runs through UK tax.
For our framework on how licensing structures feed into brand rankings and operator trust, see the ClearCasinos Trust & Licensing methodology.
FAQ
What is the GOSS licence?
GOSS – Gambling Operator Support Services – is a new category under Section 17(1)(f) of the Gambling Act 2025. It covers advertising and marketing services, group holding entities for foreign-licensed gambling business, customer-fund custody by non-licensees, and any further activities the Minister designates. It costs £50,000 per year plus an £8,000 non-refundable application fee and runs for five years.
What does "activity-based" licensing mean?
The 2005 Act licensed the operator – the entity holding the gambling infrastructure. The 2025 Act licenses the regulated activity itself, regardless of which entity performs it. A marketing agency, holding company, fund custodian, or B2B provider can each require its own licence even if none is a traditional gambling operator.
Do affiliates need a Gibraltar licence now?
Most affiliates operating in or from Gibraltar now require a GOSS licence. The narrow exemption applies only where marketing is primarily targeted at a Gibraltar audience and the person is in the business of advertising and is not part of a Gibraltar-licensed gambling group. Ministerial discretion applies to every grant.
What do existing B2C operators like Bet365 need to do?
Map every group entity that performs marketing, affiliate management, CRM, fund custody, or holding functions. B2C licensees can cover group marketing under their existing B2C licence at no additional fee. B2B licensees need a separate marketing licence. Full applications must be lodged by 1 October 2026.
What are the penalties for non-compliance?
On summary conviction, up to six months' imprisonment plus the statutory maximum fine. On indictment, up to two years' imprisonment and an unlimited fine. The Commissioner can also impose administrative fines, suspend licences, and make prohibition orders under Part 8 without going to court.
Is the Gibraltar Act connected to the UK's 40% gambling tax?
The two measures commenced the same day – 1 April 2026 – but are separate policy actions. The UK RGD hike from 21% to 40% is a tax change from the December 2025 Autumn Budget. The Gibraltar Act is a licensing reform passed in March 2026. Lyman confirmed Gibraltar cost-cutting is driven mainly by UK RGD, not the Act. The two forces combine on operator margins, but causation runs through tax on the UK side and licensing perimeter on the Gibraltar side.
Sources
- Gibraltar Laws – Gambling Act 2025 Consolidated Version – enacted text
- Gibraltar Parliament – Gambling Bill 2025 (B. 13/25) – bill as passed
- Gibraltar Gambling Division – regulator portal and licensee register
- Ramparts – Gambling Act 2025 Enactment Briefing – Howitt's structural analysis
- Hassans – Marketing and GOSS Note – affiliate perimeter
- Hassans – New Gambling Act Key Changes – section-by-section overview
- iGaming Business – Questions Unanswered – Lyman interview
- SBC News – Gibraltar's Gambling Bill – parliamentary passage
- Gibraltar Chronicle – Parliament Passes New Gambling Law – floor statements
- Yogonet – Gibraltar Shifts Gambling Oversight – activity-based framing
- iGaming Business – UK Tax Hike Recasting Gibraltar Economy – revenue modelling
- HM Government of Gibraltar – Licensing Framework and Fees Consultation – fee schedule