Gibraltar’s six-month transition under the Gambling Act 2025 ended on 1 October 2026, and the Gambling Division’s own Getting Licensed page still described that window in the present tense when it was read on 21 October. The businesses carrying the risk are not the licensed operators, who were deemed licensed under the new Act and never had a cut-off date, but the marketing companies, overseas suppliers, customer funds holders and holding companies the Act caught for the first time. For a Gibraltar licensee that makes it a contracting problem, since section 20 lets the Commissioner stop a licence holder using a named provider.
Key Takeaways
- The Gambling Act 2025, Act 2026-04, came into operation on 1 April 2026 under LN.2026/064, with sections 55 to 77 held back. Schedule 8 gave newly licensable businesses a transitional licence valid for up to six months, so that cover ended on 1 October 2026 unless a full and complete application had already gone in. (1) (2)
- Operators licensed under the Gambling Act 2005 are deemed licensed under the 2025 Act and never faced the deadline. The activities that were newly licensable sit under one licence type, created by section 17(1)(f) and named by section 17(8) as a Gambling Operator Support Services licence: marketing services for gambling, the holding or managing of customer funds, and Gibraltar companies owning more than 25 per cent of a gambling business licensed elsewhere. (1) (2)
- The register kept under section 14 of the Act listed five Gambling Operators Support Services licence holders on 21 October 2026, all of them for marketing or affiliate services, against 29 B2C remote operators, one non-remote operator and 33 B2B remote operators. Nothing on it is listed against customer funds or relevant company ownership. (3)
What actually closed on 1 October 2026?
The transitional licence closed, not the regime. Gibraltar’s transition ran from 1 April 2026 for six months, and inside it the Division asked every in-scope business to notify it and then apply for a licence. (2) Schedule 8 carried newly licensable businesses through on a transitional licence, and where a full and complete application went in before the window shut, the cover holds until the Authority decides it. Where nothing went in, the cover stopped. (1) No extension has been published, and the guidance page still describes the transition as running, so the official source gives no warning that it has gone. (2)
Sections 55 to 77 never commenced either. That is the regulated individuals regime, which would put a named and approved person behind each key management function, and the commencement notice carved it out with no replacement date. (1) The part of the Act that creates criminal liability is running, while the part that would put a name against each function is not.
Who was caught for the first time, and who was never at risk?
Existing licensees were never at risk, because Schedule 8 treats a 2005 Act licence holder as licensed under the 2025 Act until a new licence is issued. (2) Those are companies with Gibraltar counsel on retainer and somebody whose job includes reading the Gazette.
The newly caught businesses are not like that. Section 17(1)(f) brings in marketing services for gambling, the holding or managing of customer funds for remote gambling by anyone other than a licensed credit institution, and a Gibraltar company holding more than 25 per cent of a company that provides gambling facilities elsewhere but would need a licence if it sat here. Section 30(5) reaches further out again, treating facilities provided to a licence holder from outside Gibraltar as provided in or from Gibraltar, and the section 18 exemption covers only advertising aimed primarily at a Gibraltar audience. (1)
Then there are the fees. Marketing services cost £8,000 to apply for and £50,000 a year under the Gambling (Duties and Licence Fees) Regulations 2026, falling to £25,000 where annual sales are under £200,000, against £8,000 and then £5,000 for relevant company ownership. (4) Some small Gibraltar affiliate businesses will have done that arithmetic and decided not to apply.
Why are there only five support services licence holders?
Because section 37(6) shuts the door on most of the businesses the category was written for. The Authority will not grant a marketing services licence other than for marketing a gambling business run by a Gibraltar licence holder, and only the Minister can go wider, under section 37(8), where no public interest of Gibraltar would be prejudiced. (1) So a Gibraltar agency or affiliate whose clients hold Maltese or Curaçao licences has no route of right to the licence it now needs, and its transitional cover ran out three weeks ago.
The register shows the result. Tipico Services Limited, SBI Digital Marketing Limited, COE Services Limited, Tonybet Sourcing Limited and Etteluor Marketing Limited are the five, each against marketing or affiliate services, which reads as group service companies rather than third-party agencies. (3) Nobody holds the other two permissions in that class, and customer funds and relevant company ownership are where an operator is most likely leaning on an unexamined counterparty.
How do Gibraltar, Curaçao and Malta compare on licensing the supply chain?
All three license the supply chain now rather than the operator alone, and Curaçao is the only one of the three with a window still open.
| Market | Instrument and date | Who needs their own authorisation | Deadline |
| Gibraltar | Gambling Act 2025 (Act 2026-04), in operation 1 April 2026 under LN.2026/064 | B2C and B2B operators, marketing and affiliate services, holders of customer funds, owners of more than 25 per cent of a relevant company | Transitional licences ended 1 October 2026 |
| Curaçao | National Ordinance for Games of Chance, with the Curaçao Gaming Authority supplier notice of 24 June 2026 | Curaçao established suppliers need a licence and an active registration, and foreign suppliers to CGA licensees need to register | 24 December 2026, when the LOK transition ends |
| Malta | Gaming Act (Chapter 583) and the Gaming Authorisations Regulations (S.L. 583.05) | B2C under a gaming service licence, B2B under a critical gaming supply licence | None, because the authorisation precedes the supply |
Curaçao’s version puts the duty on the operator as well as the supplier, since a CGA licensed operator may not keep a commercial relationship with an unregistered supplier, so 24 December gets enforced through contract terminations rather than prosecutions. (5) Malta has required a critical gaming supply licence before supply since the Gaming Act came in, so Gibraltar and Curaçao look less like innovators here than like two more markets arriving at the same answer. (6)
What should an operator do about its counterparties now?
Build a counterparty authorisation register, per licence rather than per group, with one row for every affiliate, marketing agency, B2B supplier and customer funds holder the business pays. Against each row:
- the authorisation it holds in each market where it serves you, with the instrument named
- its expiry date, or its transition deadline where that market is mid-change
- the date someone at your end last verified it, and the name of the person who did
- for Gibraltar, whether it filed a full and complete application before 1 October 2026
- for Curaçao, whether it is registered with the Curaçao Gaming Authority, against 24 December 2026
The dates are the point of it. Section 27(2) gives a defence to a person who took all reasonable precautions and exercised all due diligence, and a dated register with a name against each check is what that defence looks like once a counterparty turns out to have been unlicensed for a quarter. (1)
If the weaker side is your own licence portfolio rather than your counterparties, the Licence Renewal Management Planner already tracks one across the UK, MGA, Gibraltar, Ontario and Brazil with the pre-renewal documentation attached. The counterparty rows are the part to add.
Boardroom Questions
- Which of our marketing suppliers, affiliates and B2B providers operate in or from Gibraltar, and which of them are on the section 14 register today?
- For any that are not, did they file a full and complete application before 1 October 2026, and who here has seen the evidence?
- Do any of our Gibraltar marketing suppliers serve clients licensed elsewhere, which under section 37(6) leaves them no route of right to a licence?
- Who holds or manages customer funds for our remote business, and does that need a licence nobody has applied for?
- Which of our suppliers serve Curaçao licensed operators, and are they registered with the Curaçao Gaming Authority ahead of 24 December 2026?
- If the Commissioner prohibited us under section 20 from using a named provider, how long would replacing them take, and what would stop meanwhile?
Sources
- Gambling Act 2025 (Act 2026-04), Gibraltar, assented 23 March 2026 and brought into operation on 1 April 2026 by LN.2026/064 for all provisions except sections 55 to 77, gibraltarlaws.gov.gi. Section 17(1) lists the regulated activities, with marketing services for gambling, the holding or managing of customer funds for remote gambling and relevant company ownership at section 17(1)(f), licensed as a Gambling Operator Support Services licence under section 17(8). Section 18 exempts marketing carried out through publications and broadcast media intended primarily for an audience in Gibraltar. Section 20 allows the Commissioner to require information about B2B services and to prohibit a licence holder from using a particular provider. Section 26(1) prohibits carrying on a regulated activity in or from Gibraltar without a licence or exemption, and section 27(1) sets penalties of six months’ imprisonment or the statutory maximum fine on summary conviction and two years or a fine on conviction on indictment, with a defence at section 27(2) for a person who took all reasonable precautions and exercised all due diligence. Section 30(5) treats a person providing facilities for remote gambling to or for the benefit of a licence holder from outside Gibraltar as operating in or from Gibraltar. Section 37(6) restricts marketing services licences to the marketing of a gambling business run by a Gibraltar licence holder, with a ministerial discretion at section 37(8). Schedule 8 holds the transitional provisions, and was amended by Act 2026-12, also commenced 1 April 2026. Sourcing limit worth stating: the published text of the Act was readable only to roughly its midpoint during this research, so the transitional licence mechanics set out above rest on the Gambling Division’s own published description at source 2 and on practitioner summaries of Schedule 8 rather than on the schedule’s own wording.
- Gambling Division, H.M. Government of Gibraltar, Getting Licensed, gamblingdivision.gov.gi, read 21 October 2026. “Licence Holders who were licensed under the Gambling Act 2005 are deemed to be licensed under the Gambling Act 2025.” “A transition period runs from 1 April 2026 for six months and in that period, any business that falls within scope of licensing will need to: a) Notify the Gambling Division; b) Apply for a licence.” The same page describes the widened scope as covering B2C businesses managed or controlled in or from Gibraltar, B2B in or from Gibraltar or making supplies to a Gibraltar entity, regulated individuals holding key management functions, gambling marketing activity conducted in or from Gibraltar, and companies holding more than a 25 per cent share in a relevant company.
- Gambling Division, Register of Licence Holders maintained in accordance with section 14 of the Gambling Act 2025, gamblingdivision.gov.gi, read 21 October 2026. Twenty-nine B2C remote gambling operators, one B2C non-remote operator, 33 B2B remote gambling operators, and five Gambling Operators Support Services licence holders, namely Tipico Services Limited, SBI Digital Marketing Limited, COE Services Limited, Tonybet Sourcing Limited and Etteluor Marketing Limited, each listed against Marketing/Affiliate Services. No entry on the register is listed against the holding or managing of customer funds, or against relevant company ownership.
- Gambling (Duties and Licence Fees) Regulations 2026, Gibraltar, in effect 1 April 2026 and cited elsewhere as LN.2026/065. Marketing and affiliate services in or from Gibraltar at £8,000 application and £50,000 a year, or £25,000 a year where annual sales are under £200,000. Holding or managing customer funds other than by a licensed credit institution at £8,000 and £50,000. Relevant company ownership at £8,000 and £5,000. Annual fees fall due on 1 April and are payable by 30 April, and a licence granted mid-year pays from the start of that calendar quarter. These figures are taken from published practitioner summaries of the regulations rather than from the legal notice itself, so confirm them against the notice before budgeting on them.
- Curaçao Gaming Authority notice on suppliers of products and services essential to gambling operations, 24 June 2026, implementing the National Ordinance for Games of Chance (LOK), reported 26 June 2026. Companies established in Curaçao must hold a supplier licence and maintain an active registration, while foreign suppliers providing services to CGA licensed operators must register without needing a local licence. Both obligations take full effect on 24 December 2026, when the LOK transition period ends. The registration system was expected to open in October 2026 and the Authority advised unlicensed Curaçao based suppliers to apply by 1 September 2026. CGA licensed operators may not engage or maintain commercial relationships with unregistered suppliers. The Authority’s illustrative list of critical suppliers covers RNG game developers, live casino studios, peer-to-peer providers, lottery providers, sports betting platforms, bet processing and settlement firms, odds and sports data providers and game aggregators.
- Malta Gaming Authority, licence types, mga.org.mt, under the Gaming Act (Chapter 583) and the Gaming Authorisations Regulations (S.L. 583.05). Two categories are issued: a gaming service licence, which is the business-to-consumer authorisation to offer or carry out a gaming service, and a critical gaming supply licence, which is the business-to-business authorisation covering the supply and management of material elements of a game and the supply and management of software that generates, captures, controls or otherwise processes an essential regulatory record, together with the control system on which that software resides.