Gibraltar’s new Gambling Act 2025: a modernised framework

A new era for gambling regulation

On 1 October 2025, Gibraltar is expecting to see the introduction of the Gambling Act 2025, which will replace the long-standing Gambling Act 2005. The new legislation introduces a modernised framework for regulation designed to strengthen trust in the industry and safeguard Gibraltar’s reputation. The objective of the regulation includes maintaining confidence in gambling markets, promoting safer and more responsible gambling, preventing the sector from being linked to financial crime, and protecting the jurisdiction’s macro-economic interests.

The reform establishes a more robust and forward-looking framework. In doing so, it ensures that Gibraltar’s gambling regime continues to protect its standing on the global stage while adapting to an increasingly complex operating environment.

Why change was needed

Since the original 2005 Act was developed, the landscape has changed significantly. Rapid digitalisation, the emergence of new business models and heightened global scrutiny of the sector have transformed the way the industry operates. Against this backdrop, a modernised framework was necessary to ensure that regulation remained fit for purpose.

In modernising the framework, the Government is attempting to maintain Gibraltar’s competitive edge in the industry, whilst increasing oversight by the Gambling Commission, and addressing areas that previously fell outside formal supervision. It reflects a determination to ensure that all areas of the gambling industry contribute positively to the economy and to maintain the reputation of the jurisdiction.

What the Act delivers

The Gambling Act 2025 provides a comprehensive overhaul of licensing and regulatory requirements. One of the most significant developments is the expansion of the licensing regime to cover a wider range of activities. B2B suppliers, marketing companies and entities holding customer funds will fall within the scope of regulation. This shift ensures a wider scope of the gambling value chain is properly supervised, closing gaps that previously left certain functions outside the regulator’s reach.

Another cornerstone of the Act is substance requirements. Licensed operators must demonstrate that they have a real and meaningful presence in Gibraltar, whether through jobs, tax contributions or physical infrastructure. 

The Act also strengthens the enforcement powers of the Gambling Commissioner. In addition to traditional sanctions such as fines and suspensions, the regulator will now be able to commission independent Skilled Person’s reports, appoint inspectors to conduct investigations, and escalate matters to the Supreme Court when necessary. These powers provide the regulator with a more flexible and effective toolkit for addressing non-compliance and protecting consumers.

Key changes to know

Broader regulatory net

As mentioned, the scope of regulation will extend beyond the traditional operator model. Remote B2B providers, holding companies with significant ownership in licensed businesses, and firms managing customer funds are all brought within the framework. This expansion reflects the reality that consumer protection and market integrity depend on oversight of the wider supply chain, not just the point of customer interaction.

Individual accountability

The Act also introduces a framework for regulated individuals, making personal accountability a central feature of the new regime. Senior managers and those exercising significant influence must undergo pre-application vetting and pass fit and proper tests before taking up their roles. This emphasis on governance places responsibility firmly on individuals as well as corporate entities, strengthening confidence in decision-making at the highest level.

Substance and presence

The new Act requires operators to demonstrate that their presence in Gibraltar is more than just nominal. Companies will need to show tangible contributions through employment, taxation and the establishment of infrastructure. This ensures that Gibraltar not only hosts the businesses but also benefits directly from their operations, reinforcing the jurisdiction’s long-term economic interests.

Enhanced enforcement powers

The Gambling Commissioner is granted a wider range of investigatory and sanctioning powers than before. From financial penalties and public statements to prohibition orders and licence suspensions, the regulatory toolkit has been significantly expanded. These powers are designed to provide a proportionate and flexible response to misconduct, enabling the regulator to act decisively when required.

Strengthening Gibraltar’s reputation

The Gambling Act 2025 represents a decisive step in Gibraltar’s regulatory evolution. By expanding the scope of licensing, introducing a framework for regulated individuals, embedding substance requirements and strengthening enforcement, the Act aligns Gibraltar with international standards and reflects regulatory trends seen in other industries.

For operators, the challenge will lie in adapting systems and governance structures to meet these new obligations. Effective internal controls remain a requirement, as they were under the 2005 Act, but the broadened remit increases the importance of compliance for both the companies and senior management. By raising the bar, Gibraltar is ensuring that only firms that will maintain the reputation of the jurisdiction and contribute to the economy, will operate from the jurisdiction.

The transition will not be without its challenges, but the benefits are clear. The Act strengthens Gibraltar’s reputation as a trusted and competitive centre for gambling, while putting in place the foundations for a more sustainable industry that contributes meaningfully to the local economy.

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