Gibraltar Shifts to Activity-Based Gambling Law
After two decades under the 2005 Gambling Act, a new regulatory framework has come into force as of April 1, 2026. The introduction of the Gambling Act 2025 signals a shift away from an operator-focused licensing system toward one centred on regulated activities.
Rather than an immediate overhaul, the transition is being implemented gradually. A six-month adjustment period has been introduced to allow the industry to adapt while maintaining operational continuity as the updated framework takes shape.
Expanded Scope of Regulation
A key feature of the new legislation is the redefinition of what triggers regulatory oversight. Under the previous model, licensing requirements were tied primarily to operators themselves. The new Act broadens this approach by bringing certain supporting functions within scope when they are carried out in or from Gibraltar.
At the centre of this expansion is the introduction of the Gambling Operator Support Services (GOSS) licence. Depending on the nature of the activity and any exemptions that may apply, this licence may cover areas such as marketing and advertising activities linked to gambling services, the handling of customer funds and certain business-to-business operational roles that support the wider gambling ecosystem.
Treatment of Internal Group Functions
The legislation also addresses how internal corporate services are treated. Not all support functions within a company group automatically require licensing.
In general, services provided within the same corporate structure to an already licensed entity are less likely to fall under separate licensing requirements. However, when similar services are offered externally as a primary business activity, they are more likely to be captured under the new framework. As a result, operators are encouraged to review each function individually to determine whether it falls within the revised regulatory scope.
Transition Period for Compliance
To support the shift, the Act includes provisions that ensure continuity for affected businesses. Companies whose activities now require licensing, but did not previously, can operate under transitional arrangements.
This interim period runs for six months from the April 1 implementation date. During this time, businesses must submit full applications to the Licensing Authority to secure the appropriate authorisations. The structured transition is designed to prevent disruption and ensure there is no regulatory gap as the old system is phased out.
Implications for Operators
The move to an activity-based licensing model requires operators to reassess their organisational structures and service chains. Particular attention should be given to functions such as marketing, payment handling and outsourced operational support, as these may now fall within the definition of regulated activities.
By identifying relevant services early and making use of the transitional window, operators can navigate the changes effectively and align with Gibraltar’s updated regulatory framework.
