Gibraltar’s new Gambling Act aims to improve compliance and give the regulator more authority. But stakeholders have pointed out things that are unclear and need more explanation.
Gibraltar has officially ushered in its Gambling Act 2025, ending its two-decade run under the Gambling Act 2005 and setting the stage for what it hopes will be a reimagined, more resilient regulatory identity. With the promise of stronger enforcement, increased oversight, and a sharpened global brand, the new law also carries with it significant uncertainties for operators navigating the transition.
At its core, the new act is designed to eliminate “brass-plate” operations—shell companies that have little operational presence in Gibraltar. Licensees will now be required to demonstrate real economic substance: staffing, offices, infrastructure, and local tax contributions. The aim is to anchor gambling firms more firmly in the territory, and to reduce the regulatory arbitrage that has plagued the industry.
The legislation significantly expands the licensing boundary, breaking apart different functions into distinct categories. Under the 2025 Act, B2C, B2B, and Gaming Support Services (such as marketing, CRM, software hosting, and managed trading) are now separate licensing classes. The boundaries between these categories, however, remain fuzzy in places — especially for group structures, hybrid services, or centralized functions that span multiple jurisdictions.
A standout addition is the “Approved Persons” regime: senior managers will now need individual vetting and personal licenses, pushing accountability down to individuals rather than just entities. Simultaneously, marketing efforts “in or from Gibraltar” are brought under scrutiny—bringing affiliates, ad agencies, and group marketing operations into the regulatory fold.
To oversee compliance, the Gambling Commissioner is armed with stronger powers: administrative fines, cease-and-desist orders, inspections, and suspensions. And for recourse, an independent Gambling Appeals Tribunal will now adjudicate appeals of regulatory decisions—license denials, revocations, or penalties.
The shifts mandated by the act are already prompting industry players to reengineer internal structures. According to legal experts, operators must map out which arms of their business require separate licenses, whether in-house or outsourced. Multinational groups face a complex puzzle: how to divide operations, allocate licensing, and manage cross-hub support functions without triggering duplicative or conflicting requirements.
Particularly thorny are “support services” like managed trading, RNGs, software hosting, and shared services. The act names them explicitly, but offers limited clarity around thresholds or carve-outs—meaning operators must interpret whether their centralized teams are in or out of scope. Similar ambiguity surrounds marketing and affiliate regulation: while marketing “in or from Gibraltar” is broadly captured, whether intra-group flows or internal agency teams must be licensed remains unresolved.
Smaller operators may find the compliance burden steep. New license filings, infrastructure investments, staffing demands, and enhanced reporting will all raise costs—especially for lean models. During the transition, current licensees will be grandfathered in, but they must reapply within six months under the new framework. Meanwhile, Gibraltar’s limited labor pool may constrain firms’ ability to meet the new local presence requirements.
The significance of the iGaming sector of the small British Overseas Territory situated at the southern tip of the Iberian Peninsula, which has become a premier iGaming hub lately, can’t be understated: it employs over 3,200 people across 54 operators and accounts for about 20 % of the territory’s GDP. In 2024 alone, it delivered £110 million in corporate tax and £40 million in employee contributions. With 83 license holders currently active (49 B2C, 34 B2B), Gibraltar faces stiff competition from regulated jurisdictions like Malta, the Isle of Man, and newer offshore hubs.
Gibraltar now bets its regulatory prestige—not laxity—as its competitive edge. By offering nuanced regulation, enforcement confidence, and legal appeal mechanisms, it positions itself as a credible hub rather than simply a permissive jurisdiction. The new act also signals that Gibraltar expects its operators to adhere to local licensing rules elsewhere, reinforcing reciprocal compliance norms.
Despite its bold architecture, the real test lies in execution. Secondary rules, interpretive guidance, and regulatory precedents are vital—and for now, many operators are left waiting. The key unanswered issues:
The ambitions behind the Gambling Act 2025 are clear: Gibraltar wants to remain in the top tier of licensed jurisdictions, combining credibility with commercial pragmatism. But the path forward is testing, and only time will tell how well the territory balances clarity, enforcement, and flexibility in a highly competitive, always evolving gambling landscape.
