Gib Certs Gibraltar Gaming Act October 2025
🎧 Gibraltar's 2025 Gaming Act Hear it!
🎬 Navigating Gibraltar's Gaming 2025 Updates
Implementation Timeline
Era of Gambling Act 2005
The existing regulatory framework effective for its time but designed for an era less dominated by online operations. Gibraltar removed from FATF grey list, demonstrating commitment to AML/CTF measures.
Awareness & Preparation Phase
Operators assess compliance status, begin internal preparations, and participate in industry consultation. Framework for the New Act is finalized.
Bill Publication
The New Gibraltar Gambling Act 2025 bill is published, outlining comprehensive overhaul of existing regulations.
Transition Phase
Formal enactment, transitional provisions activated, compliance upskilling, and process modifications begin. Operators prepare for regulatory shift.
Parliament Approval
Gibraltar Parliament expected to approve the New Act, finalizing legislative process.
Effective Date & Full Enforcement
New Act officially takes effect, replacing Gambling Act 2005. Regulated Individuals regime introduced with 12-month approval window. New Gambling Appeals Tribunal established.
Monitoring & Adaptation
Ongoing compliance monitoring, regular reviews, audit readiness, and strategic adaptation to leverage new framework for competitive advantage.
Regulated Individual Deadline
Final deadline for individuals performing regulated functions to become "Regulated Individuals" if not previously approved under Old Act.
Key Stakeholders
Patrick Roberts
Director of Compliance & MLRO
Legal Expert
Director of Compliance & MLRO at in2Solutions Limited providing guidance on the Gambling Act 2025 and transitional provisions. in2Solutions Limited specializes in compliance and legal advice for the new legislation.
Ed Reif
Strategic Insights Provider
Industry Thought Leader
Strategic insights provider for GIB CERTS, known for philosophical quotes and perspectives on gambling regulation, compliance, and market dynamics. Emphasizes adaptation and proactive engagement.
Gibraltar Gambling Commissioner
Primary Regulatory Authority
Regulatory Oversight
Responsible for licensing, supervising, and enforcing gambling regulations. Guides license migration, approves Regulated Individuals, and possesses enhanced supervisory powers under the New Act.
GIB CERTS
Regulatory Guide Authors
Industry Education
Entity responsible for authoring "The Black Book: Navigating Gibraltar's Gaming Revolution" - a definitive regulatory guide providing insights and roadmaps for stakeholders.
Gambling Appeals Tribunal
Independent Appeals Body
Dispute Resolution
New dedicated body established by the New Act to provide independent forum for hearing appeals against regulatory decisions. Ensures transparency and expert resolution of disputes.
Gibraltar Financial Intelligence Unit
GFIU - National AML Center
Financial Crime Prevention
National center for receiving, analyzing, and disseminating suspicious activity reports. Enhanced reporting obligations under New Act include real-time suspicious transaction reporting capabilities.
Frequently Asked Questions
The New Gibraltar Gambling Act 2025 ("the New Act") is a comprehensive overhaul designed to modernize Gibraltar's gambling regulatory framework. It aims to establish a more robust, flexible, and comprehensive system that replaces the Gambling Act 2005 ("Old Act"). This legislative update addresses the complexities of the modern digital gaming ecosystem, focusing on technological advancements, player protection, and enhanced anti-money laundering (AML) efforts.
The New Act is expected to be approved by the Gibraltar Parliament in September 2025 and will officially take effect on October 1, 2025. This date signifies a complete transition to the new framework, signaling Gibraltar's commitment to maintaining its status as a premier, forward-thinking jurisdiction in the online gaming industry.
The New Act abandons the "one-size-fits-all" approach of the Old Act and introduces a sophisticated tiered licensing model with more granular categories. This new architecture distinguishes between:
B2C (Business-to-Consumer) licenses: For operators directly offering gambling services to end-users (e.g., online casinos, sports betting platforms). The focus here is heavily on player protection, responsible gaming, and consumer-facing compliance.
B2B (Business-to-Business) licenses: For entities providing services or products to other gambling operators (e.g., software developers, platform providers, payment processors). The emphasis for B2B is on the integrity and security of their products/services and their contribution to the overall AML/CTF framework.
This tiered and granular approach allows the Gibraltar regulatory authority to apply tailored oversight, precisely addressing the specific risks and compliance obligations inherent in each business model.
The New Act includes specific transitional provisions to ensure a smooth shift for existing operators and pending applicants:
Existing Licence Holders: A licence holder under the Old Act is automatically treated as licensed under the New Act until a new licence is issued. There is no need for current licensed operators to reapply immediately. The Gambling Commissioner will guide them through migration to the appropriate new categories.
Pending Applications: Applications made under the Old Act but not determined by October 1, 2025, will be treated as if they were made under the New Act.
Newly Licensable Activities: Businesses conducting activities that previously did not require a licence but now do under the New Act will be granted a temporary "transitional licence," valid for up to six months. This period can be extended until a full and complete licence application is determined, ensuring continuity.
These provisions aim to minimize disruption and facilitate a pragmatic migration to the new regulatory landscape.
The New Act significantly strengthens AML/CTF requirements, aligning Gibraltar's framework even more closely with international standards set by bodies like the Financial Action Task Force (FATF) and the UK. This builds upon Gibraltar's recent removal from the FATF 'grey list,' enhancing its international credibility. Key enhancements include:
Enhanced Customer Due Diligence (CDD) procedures: More rigorous checks to understand customers and their risk profiles.
Digital KYC Thresholds: Likely clearer and potentially lower thresholds for initiating full digital KYC procedures to prevent fraud and illicit activities.
More rigorous risk assessment methodologies: Moving beyond a tick-box approach to truly risk-based controls.
Improved Suspicious Activity Reporting (SAR) mechanisms: More prescriptive and comprehensive obligations for identifying and reporting suspicious transactions.
These measures aim to safeguard Gibraltar's reputation and ensure its gambling sector remains impenetrable to illicit financial flows.
The New Act introduces an enhanced regime for "Regulated Individuals" – those holding critical positions within licensed gambling operations (e.g., directors, senior management, compliance officers, MLROs). This is to ensure the integrity and accountability of the industry.
12-Month Approval Window: Individuals performing regulated functions have twelve months from the Effective Date (October 1, 2025) to become "Regulated Individuals." If an application for approval is made within this period, the deadline is extended until the application (and any appeal) is decided.
Recognition of Previously Vetted Staff: Individuals already performing regulated functions and previously approved or vetted by the Gambling Commissioner under the Old Act are automatically approved on the Effective Date. This streamlines the process for experienced personnel while still subject to ongoing conditions.
Ongoing Fit and Proper Assessment: The "fit and proper" assessment is continuous, requiring prompt reporting of any changes in circumstances affecting suitability.
This framework aims to ensure that key functions are consistently held by individuals meeting the highest standards of regulatory compliance and ethical conduct.
The New Act places an "unprecedented emphasis" on robust data and player protection measures, recognizing their critical importance in safeguarding sensitive information and promoting responsible gaming. Key areas include:
Digital KYC Innovation: Implementation of advanced digital KYC systems for efficient and secure identity verification.
Responsible Gaming Excellence: Proactive behavioral monitoring, enhanced affordability assessments, comprehensive self-exclusion systems, and evidence-based intervention strategies. Operators are expected to provide tools for setting spending and time limits and promote clear communication about responsible gaming.
Data Privacy Leadership: Emphasizing "Privacy by Design" implementation, comprehensive audit trails, GDPR excellence, and advanced cybersecurity measures to protect all player information.
Regulatory Reporting Excellence: Transparent, timely, and comprehensive reporting that provides valuable insights for regulatory oversight regarding player protection metrics and data integrity.
These measures aim to foster a gaming environment that is commercially vibrant, socially responsible, and secure for all participants.
The New Act ensures continuity and robust oversight regarding offences, appeals, and enforcement:
Continuity of Old Act Enforcement: Investigations or proceedings for offences committed or allegedly committed prior to the New Act's effective date, and ongoing enforcement actions by the Gambling Commissioner before this date, will continue to be governed by the provisions of the Old Act until their conclusion. This ensures legal certainty and prevents disruption to ongoing legal processes.
Appeals: Appeals connected to decisions made under the Old Act must be decided in accordance with the Old Act's provisions, regardless of whether the appeal is filed after the New Act's effective date.
New Gambling Appeals Tribunal: The New Act formally introduces a dedicated Gambling Appeals Tribunal. This independent and specialized body will hear appeals against decisions made by the Gibraltar Gambling Commissioner under the New Act, providing a transparent and expert forum for dispute resolution.
Enhanced Supervisory and Enforcement Powers: The Gambling Commissioner will have broader investigative powers, increased sanctioning capabilities (including higher financial penalties and licence suspension/revocation), and a shift towards more proactive, risk-based supervision.
This framework ensures fairness, due process, and effective oversight of the dynamic gambling industry.
Gibraltar's overall strategic vision with the New Act is to remain a world-class, premier hub for the online gaming industry, ensuring a robust and future-proof regulatory environment. The Act is seen not just as legislative housekeeping but as a "complete reimagining" of gambling regulation in the digital age.
For operators, the expectation is to transform compliance from a burden into a competitive advantage. This requires:
Proactive Engagement: Building constructive relationships with regulatory authorities, seeking early clarification, and actively participating in consultations.
Strategic Planning: Conducting comprehensive gap analyses, developing risk-based compliance prioritization, and investing in technology upgrades and staff training.
Operational Excellence: Implementing advanced digital KYC, responsible gaming frameworks, and robust data privacy measures that exceed baseline requirements.
Continuous Adaptation: Recognizing that the regulatory landscape is constantly evolving and that ongoing monitoring, compliance reviews, and audit readiness are essential.
Ultimately, Gibraltar aims to attract high-quality operators who embrace these changes, build compliance into their "competitive DNA," and contribute to a stable, secure, and reputable operating environment.