A practical adviser-focused guide to Gibraltar’s Gambling Act 2025, including scope, governance, support services, substance and key implications.
April 1, 2026
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5
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The Gambling Act 2025 represents a structural shift in how Gibraltar regulates gambling and related activities. This article explains what has changed, which businesses may now fall within scope, and where advisers should focus their attention.
Gibraltar has long been recognised as an established base for online gambling operators. Its licensing framework, regulatory infrastructure and time zone position have made it a preferred choice for many well-known businesses in the sector. The Gambling Act 2025, enacted in March 2026, marks a significant evolution of that framework.
The previous model was often understood primarily through the lens of operator licensing and the location of technical infrastructure. The new Act broadens that picture considerably. It brings a wider range of activities and entities into scope, raises the bar on governance and personal accountability, and reinforces the expectation of substantive operational presence in Gibraltar.
This article is a practical explainer for professional advisers. It is not legal advice and does not substitute for Gibraltar-specific legal analysis. Its purpose is to help advisers identify where the new regime may be relevant to a client’s structure, and to recognise when specialist input is warranted.
The Act replaces the earlier legislative framework with a more comprehensive and modern regulatory structure. At its heart is a shift in emphasis: from a model that focused on where infrastructure was located to one that asks broader questions about what activities are being conducted, by whom, and with what level of accountability.
The new regime places supervision, governance and substance at the centre of regulatory expectations. It introduces clearer definitions of regulated activity, more explicit requirements for those in positions of influence, and greater oversight of the supply chain and support services that sit around licensed operators.
For advisers, the key shift is that the regulatory perimeter is no longer defined solely by whether a client holds a gambling licence. Ownership structures, support functions and advisory arrangements may all now attract attention from the Gibraltar Gambling Commissioner.
One of the most significant structural changes concerns the definition of what falls within the scope of Gibraltar gambling regulation. Section 17 of the Act is described as widening the concept of regulated activity beyond the direct provision of gambling services.
Activities such as marketing services and customer fund management are among those that may now be treated as regulated depending on how they are structured and to whom they are provided. Ownership arrangements also become relevant: where a Gibraltar-based entity holds a significant interest in a licensed operator (broadly, more than 25% or a position of significant influence) that entity may itself be drawn into the regulatory framework.
This is not simply a tightening of existing rules. It is an expansion of the regulatory perimeter to encompass a broader range of ancillary and support activities. Advisers should not assume that because a client is not itself a licensed operator, the new Act is irrelevant to their situation.
The Act’s treatment of B2B and supply-chain relationships deserves specific attention. Sections 19 and 20 define facilities for remote gambling broadly and give the Gambling Commissioner powers to request information about B2B services being used by licensed operators. In some circumstances the Commissioner may also prohibit the use of a specific provider.
This has practical consequences for a range of businesses that do not themselves hold Gibraltar gambling licences but whose services are integral to licensed operators. Platform providers, CRM and customer management suppliers, fraud prevention and data services, content providers, and outsourced operational functions are all capable of falling within this wider picture.
Section 30 goes further: certain suppliers outside Gibraltar may be required to establish a sufficient presence in Gibraltar if their services would otherwise be regulated and they serve Gibraltar-licensed operators. Advisers whose clients provide services of this kind to Gibraltar licensees should therefore consider whether the Act requires a reassessment of the client’s operating model and Gibraltar footprint.
Part 5 of the Act introduces the concept of regulated individuals. This brings personal accountability into the regulatory framework in a more explicit way than the previous regime.
Importantly, the scope of this category is not confined to those with formal executive titles. Significant influence over a licensed business, whether exercised through ownership, operational control, commercial relationships or advisory roles, may be sufficient to bring an individual within scope. Advisers should not assume that a client is outside this category simply because they do not hold a named directorship or formal board position.
For governance purposes, this creates a clear expectation that organisations understand who exercises meaningful influence within and around their Gibraltar structures, that roles and responsibilities are clearly allocated, and that those individuals are identifiable and accountable to the regulator.
This is consistent with the direction of travel in well-regulated jurisdictions more broadly. It reinforces the importance of maintaining clear governance documentation, appropriate internal structures and well-evidenced lines of authority within Gibraltar-based groups.
Section 40 of the Act introduces a requirement for sufficient substantive presence for those conducting regulated activities from Gibraltar. The Gambling Authority may assess this by reference to local operations, infrastructure and economic contribution.
This is a significant signal about the kind of Gibraltar structure the regulator expects to see. A letterbox arrangement or a nominal operational footprint is unlikely to satisfy a substantive presence requirement. Businesses should be able to demonstrate meaningful activity in Gibraltar: people, processes, and decisions that genuinely reflect the jurisdiction as the base of operations.
Advisers reviewing a client’s Gibraltar structure should therefore consider whether that structure reflects operational reality. This is not primarily a tax question, though tax substance considerations will often run in parallel. It is a question of jurisdiction credibility and regulatory compliance: does the Gibraltar entity do what it says it does, and does it doit from Gibraltar?
This emphasis on substance is consistent with how Gibraltar positions itself more broadly: as a jurisdiction that takes its responsibilities seriously and expects regulated businesses to do the same.
Schedule 8 of the Act provides a transitional window for activities that are newly brought into scope by the new regime. Businesses whose activities now require a licence for the first time may continue to operate under a transitional licence for a period of six months from commencement while a full application is made.
This window is relevant to any group or support entity that previously operated outside the licensing perimeter but now finds itself within scope under the broader definitions introduced by the Act. The transitional period creates time to act, but not time to defer the initial scope assessment.
Advisers with clients in this position should be raising several questions promptly: Has the client identified all entities within the group whose activities may now be regulated? Are B2B suppliers or outsourced service providers exposed to new requirements? Does the structure currently in place reflect the substantive presence the Act now requires? Are the right individuals identified as regulated persons for governance purposes?
The Gambling Act 2025 is relevant to a broader set of clients than the previous regime. The following categories of client or structure are likely to need specific attention:
• Operators already licensedin Gibraltar, who should review whether their operational substance, governancearrangements and regulated individual designations remain appropriate under thenew framework.
• B2B suppliers and supportservice providers serving Gibraltar-licensed operators, particularly if theirservices fall within the broadened definition of regulated activity or if theyhave a significant service relationship with a licensed operator.
• Group entities involved inownership, control or customer funds where Gibraltar-based entities hold morethan a threshold stake or exercise significant influence over licensedoperations.
• Businesses reviewingwhether their existing Gibraltar footprint is adequate under the substantivepresence requirement, or whether additional operational investment is needed.
• Advisers preparingboard-level briefings or governance reviews for clients with Gibraltarexposure, where the accountability and regulated individual provisions will bedirectly relevant.
In each case, the starting point is a structured scopereview: what activities are being conducted, through which entities, and doesthe current structure match what the Act now requires?
• The Gambling Act 2025 broadens Gibraltar’s regulatory perimeter well beyond traditional operatorlicensing. Support services, ancillary activities and ownership structures arenow more explicitly in scope.
• B2B suppliers and serviceproviders to Gibraltar-licensed operators should assess whether theiractivities are captured by the Act’s wider definitions, and whether a Gibraltarpresence may be required.
• Governance and personalaccountability are more explicit under the new regime. Those exercisingsignificant influence, whether or not they hold a formal title, may beregulated individuals.
• Substantive presence inGibraltar is now a formal requirement. Nominal structures are unlikely tosatisfy the regulatory expectation.
• A six-month transitional licence window applies for newly in-scope activities, but this makes earlyscope assessment more important, not less.
• Advisers should reviewclient structures holistically: not only at the licensed entity level butacross the wider group, supply chain and support function.
The Gambling Act 2025 reflects a jurisdiction continuingto evolve its regulatory model in line with international expectations.Gibraltar’s reputation in the gambling sector has always depended on thecredibility of its oversight framework. The new Act reinforces that by placinggovernance, accountability and operational substance at the centre of whatregulated businesses are expected to demonstrate.
Acquarius works with advisers and their clients tounderstand Gibraltar structures and governance in practice. If a client’sposition may require review in light of the Gambling Act 2025, whether inrelation to licensing scope, substantive presence, governance arrangements orregulated individual obligations, we are available to discuss the specifics.
Contact Acquarius
Email: enquiries@acquarius.gi
Telephone: +350 200 50418
This article is provided for general information purposes only and does not constitute legal, regulatory or professional advice. Readers should seek specific professional advice before taking or refraining from any action on the basis of this content.
Published March 2026. Based on the Gambling Act 2025 as listed on the Laws of Gibraltar site, dated 23 March 2026.
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