HM Government of Gibraltar has confirmed changes to the Qualifying (Category 2) Individuals Rules, the regime most often used by high net worth private clients of professional services firms, alongside the wider Residence Criteria framework covering employment and business-based applications. Both reflect a deliberate move toward higher thresholds and closer alignment between status and ongoing contribution.
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For advisers structuring relocations, trusts or holding arrangements that depend on a client's residence in Gibraltar, both sets of changes are directly relevant and worth building into current advice.
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Category 2: a higher fee and a higher entry threshold

From the date the changes take effect, the Category 2 application fee will rise from £1,233 to £5,000, and the minimum net wealth requirement for new applicants will increase from £2 million to £5 million. The Government has linked the change to Gibraltar's strengthened international position following the agreement reached with the European Union on Gibraltar's future relationship with the EU and the Schengen area.
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Existing Category 2 individuals are fully grandfathered and are not affected by the revised wealth threshold. Advisers should note, however, that maintaining status, not simply holding it, is what continued residence will now depend on.

Gibraltar's appeal beyond the structure

The Government's decision to raise the Category 2 thresholds reflects, in part, the volume of interest the jurisdiction has seen since the EU-UK Treaty announcement. Gibraltar is a small, professionally administered common law jurisdiction with a stable fiscal environment, English as its working language, and close proximity to mainland Europe. For individuals weighing international options, those qualities tend to compound rather than stand alone. The Category 2 regime has long provided a clearly defined route for high net worth individuals who want to establish genuine residence in Gibraltar, and the changes now being introduced are designed to ensure that route remains credible and selective as demand grows.

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Category 2 status and continued residence are now linked

The Government has reaffirmed that Category 2 status does not carry entitlement to publicly funded healthcare or schooling, a position that already applied but is now stated more explicitly. More significant for advisers is the confirmation that an individual who does not maintain their Category 2 status will lose the right to remain resident in Gibraltar.
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This makes ongoing compliance, rather than the initial grant of status, the more material consideration for long-term planning. Advisers should treat the conditions attached to Category 2 as something to monitor through the life of a structure, not only at the point a client first applies.
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Employment-based residence is also tightening

Alongside the Category 2 changes, the wider Residence Criteria framework for employment and business-based applications made after 6 October 2025 sets a higher bar too. Applicants need a contract at or above the average earnings benchmark, currently £37,500, with a properly registered and compliant employer, genuine accommodation, and ongoing tax and social insurance contributions. Permits lapse automatically where those conditions are not maintained, and the path to Gibraltarian status now requires twenty years of continuous residence for new applicants.
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Why this matters

This is most relevant to advisers with high net worth clients considering Category 2 status as part of a relocation, trust or holding structure, and to those structuring employment-based relocations for directors or staff supporting Gibraltar substance.
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Advisers should consider whether a client's net wealth and the higher application fee still make Category 2 the right route, whether existing Category 2 clients understand the grandfathering position, and whether ongoing compliance, accommodation and contribution conditions are being actively monitored rather than assumed once status is granted.
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Key takeaways

- Category 2 application fees rise from £1,233 to £5,000, and the minimum net wealth requirement for new applicants rises from £2 million to £5 million

- Existing Category 2 individuals are grandfathered and unaffected by the new wealth threshold

- Category 2 status does not, and will not, carry entitlement to publicly funded healthcare or schooling

- Losing Category 2 status now means losing the right to remain resident in Gibraltar, making ongoing compliance more significant than the initial grant

- Employment-based residence applications made after 6 October 2025 require a contract at or above the £37,500 earnings benchmark and a properly registered employer

- Gibraltarian status now requires twenty years of continuous residence for new applicants under either route
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Working with this framework

Acquarius works alongside advisers on the governance and administration of Gibraltar structures, including arrangements where Category 2 status or standard residence supports a wider trust, holding or family office structure. The firm does not advise on immigration matters directly, but coordinates closely with advisers and Gibraltar immigration specialists so that residence considerations, however a client qualifies, are properly reflected within the structure as a whole.

Advisers considering how these changes affect a client's relocation plans, Category 2 position or wider structure are welcome to discuss the practical implications.
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Contact Acquarius: enquiries@acquarius.gi

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