Gibraltar iGaming Licence: B2C Operator and Betting Intermediary Advisory
Gambling Act 2025 · In Force 1 April 2026 · Gibraltar Gambling Commissioner. Zitadelle AG advises operators through the full Gibraltar licensing lifecycle — from jurisdictional assessment and corporate structuring through to application preparation, regulated individual onboarding, and post-licensing compliance.
— Last updated: June 2026 · 12 min read
Gibraltar occupies a position in iGaming regulation that very few jurisdictions can match: a Tier 1 legal framework, a pragmatic regulator with decades of sector experience, and a tax structure that — for the right operator — is among the most efficient available anywhere. Home to Bet365, Entain, 888 Holdings, and Betfred, Gibraltar's licensing community is small by design and prestigious by reputation.
The Gambling Act 2025 — assented on 23 March 2026 and in force from 1 April 2026 — replaces the 2005 framework entirely. It introduces three distinct licence categories, a formalised substantive presence test, and a new personal accountability regime for key management. For operators evaluating Gibraltar for the first time, and for existing operators navigating the transition, the new framework requires careful advice from people who understand both the letter of the Act and the practical working relationship with the Commissioner's office.
Zitadelle AG advises operators through the full Gibraltar licensing lifecycle — from initial jurisdictional assessment and corporate structuring through to application preparation, regulated individual onboarding, and post-licensing compliance. Our fee engagement ranges from £60,000 to £120,000 depending on the scope of support required, complexity of the group structure, and the level of documentation preparation needed.
Why Gibraltar?
Six reasons operators choose Gibraltar over other Tier 1 jurisdictions:
Dedicated Betting Intermediary Licence
The Gambling Act 2025 introduces a specific licence category for exchanges and commission-based intermediaries. No other jurisdiction in this tier has an equivalent instrument tailored to the exchange model.
Lowest effective duty for exchanges
Betting Intermediary Duty is 0.15% of gross intermediary profit (total commission received), with the first £100,000 exempt each year under LN.2026/065. For an exchange generating £30M in annual commission, annual duty is approximately £44,850.
Tier 1 regulatory brand
Gibraltar-licensed operators are accepted by major payment processors, banking partners, and enterprise B2B suppliers without the friction offshore licences routinely generate. The Commissioner's reputation for rigorous oversight is a commercial asset.
No corporate tax on gambling profits
Gibraltar does not levy corporate income tax on profits derived from qualifying gambling activities. Combined with the low duty, the effective tax burden for a Gibraltar-licensed exchange is materially lower than comparable EU jurisdictions.
English common law jurisdiction
Contracts, dispute resolution, employment, and corporate governance all operate within a familiar English-language common law framework. No translation friction, no unfamiliar legal concepts for international operators.
Phased substance approach accepted
Gibraltar assesses substantive presence holistically. A credible, committed plan for growing the Gibraltar footprint over time — tied to the business plan — is acceptable. Not all regulated roles need to be physically based in Gibraltar at launch.
Licence Types Under the Gambling Act 2025
The Gambling Act 2025 introduces three principal licence categories. The relevant ones for most iGaming operators are:
B2C Gambling Operator's Licence
Issued to operators that offer gambling products or services directly to end users. It covers:
- •Sports betting — fixed odds, in-play, pari-mutuel
- •Casino gaming — RNG-based games, slots, live dealer
- •Betting intermediary / exchange — a dedicated sub-type for facilitating bets between parties without being party to those bets
- •Lottery
- •Betting agent — services that select or place bets using others' funds
Each major gambling vertical requires its own licence under the new framework — an operator running both a sportsbook and a casino requires two separate B2C licences.
B2B Gambling Operator's Licence
Covers a significantly expanded range of activities under the 2025 Act. Businesses providing platform services, game aggregation, managed trading, virtual/simulated content, fraud prevention, or similar B2B services to Gibraltar-licensed operators now require a B2B licence. The basic B2B fee (single vertical) is £85,000 per annum, with an additional £15,000 per additional vertical.
GOSS Licence (Gambling Operator Support Services)
Captures three categories that were previously unlicensed:
- •Marketing services for Gibraltar-licensed operators (including affiliates)
- •Ownership of 25%+ of shares in a Relevant Company (a Gibraltar gambling licence holder)
- •Holding or managing customer funds
Annual fee: £25,000 (marketing affiliates with under £200,000 in revenue) or £50,000.
Licence Fees — Gambling Act 2025 (In Force April 2026)
All fees payable to the Gibraltar Government / Authority. Reproduced from LN.2026/065. No Zitadelle markup applies to government fees.
| Licence Type | Application Fee | Annual Licence Fee |
|---|---|---|
| B2C — Betting Intermediary (Exchange) | £15,000 | £100,000 |
| B2C — Sportsbook / Casino (GGY ≤ £20M) | £30,000 | £50,000 |
| B2C — Sportsbook / Casino (GGY £20M–£300M) | £30,000 | £100,000 |
| B2C — Sportsbook / Casino (GGY > £300M) | £30,000 | £200,000 |
| B2C — Lottery | £20,000 | £100,000 |
| B2B — Platform / Aggregator (single vertical) | £20,000 | £85,000 |
| B2B — Direct integration (tiered by revenue) | £10,000 | £20,000–£85,000 |
| GOSS — Marketing affiliate (< £200k revenue) | £8,000 | £25,000 |
| GOSS — Marketing affiliate (≥ £200k revenue) | £8,000 | £50,000 |
| GOSS — Relevant Owner / holding entity | £8,000 | £5,000 |
Duty Structure
Betting Intermediary Duty: 0.15% of gross intermediary profit (total commission received). First £100,000 exempt per year. Payable quarterly: 1 April, 1 July, 1 October, 1 January. Payment due by the last day of the month in which the instalment falls.
B2C Operator Duty (betting/gaming): 0.15% of gross gambling yield, with the first £100,000 exempt per year.
Threshold Conditions
To be granted a licence, applicants must satisfy — and continue to satisfy — the threshold conditions set out in Schedule 2 to the Gambling Act 2025. These are not a checklist to be completed once; they are ongoing obligations assessed throughout the life of the licence.
Conduct of Business
Services must be fair, transparent, free from criminal influence, protective of vulnerable users, and supportive of Gibraltar's reputation.
Location of Offices
Registered office (or principal place of business) must be in Gibraltar.
Appropriate Resources
Financial and non-financial resources must be appropriate to the regulated activities; business must be conducted soundly and prudently.
Effective Supervision
The licensee must be capable of effective oversight by the Commissioner, having regard to complexity and group membership.
Suitability
The applicant must be fit and proper. Compliance history, management experience, probity, and connections with third parties are all assessed.
Business Model
The proposed business strategy must be suitable, compatible with sound conduct, and supportive of Gibraltar's gambling system integrity.
Procedures and Internal Controls
Effective internal controls covering authorised activities, AML obligations, and all relevant legislation must be established and maintained.
Responsible Gambling
The licensee must take reasonable steps to ensure customers gamble responsibly and appoint at least one senior manager responsible for this obligation.
Prevention of Financial Crime
Compliance with the Proceeds of Crimes Act 2015 and related legislation; a senior manager responsible for financial crime compliance must be appointed.
Customer Registration
A vetting and registration system for customers must be maintained. Customer data must be retained for at least 6 years after participation ceases.
Duty of Candour
Licensees, directors, officers, and employees must engage in loyal, transparent, and spontaneous cooperation with the Authority and Commissioner.
Protection of Customer Funds
Customers must be informed at registration about fund protection from insolvency; relevant regulations and codes of practice must be followed.
Payment of Winnings
Winnings must be promptly paid; the licensee must maintain adequate financing for payouts and ongoing operations.
Terms and Conditions
Terms must be readily accessible; an effective complaints procedure must be maintained.
Substantive Presence in Gibraltar
This is the section where many applicants get stuck — not because the requirement is impossibly onerous, but because it is deliberately flexible and the Commissioner's expectations are not published in a single prescriptive document.
The Gambling Commissioner assesses substantive presence across four factors, in combination and with discretion as to their relative weight:
- •The nature, extent, purpose and usage of remote gambling equipment located in Gibraltar
- •The number and nature of jobs to be created and maintained in Gibraltar
- •The amount of tax revenue accruing to the Government of Gibraltar
- •Any other factors the Commissioner considers relevant to a sufficient substantive presence
Three practical principles from Zitadelle's advisory experience:
Not all substance needs to be in Gibraltar from day one
The Commissioner accepts a phased approach. What matters is a credible, specific plan for growing the Gibraltar footprint — one that is tied to commercial milestones in the business plan, not left as a vague aspiration.
Not all regulated roles need to be physically based in Gibraltar at launch
Key management roles can sit within the wider group outside Gibraltar, provided lines of regulatory accountability are clearly documented, reporting relationships are unambiguous, and the application makes clear how the Commissioner would supervise those individuals in practice.
The precise footprint depends on the business
An exchange processing billions in annual matched bets will be expected to demonstrate more substance than an early-stage operator with a modest initial revenue profile. The Commissioner takes a proportionate view.
Regulated Individuals
Every Gibraltar gambling licence holder must ensure that regulated functions are performed by individuals who have been personally approved by the Commissioner as "regulated individuals." Approval requires the individual to be fit and proper and to have the skills, qualifications, and experience required for their role.
Part 1 — Mandatory for all licensees
- •Chief Executive Officer (CEO)
- •Managing Director (MD)
These may be the same person in appropriate structures.
Part 2 — As applicable
- •Financial Management (CFO or equivalent)
- •Head of Regulatory Compliance
- •Money Laundering Reporting Officer (MLRO)
- •Head of Safer / Responsible Gambling
- •Head of Marketing and/or Commercial Development
- •IT Infrastructure and Cyber Security (CIO or equivalent)
- •Management of Gaming Operations and Floor Management (not applicable to remote betting intermediaries)
Important: Part 5 has not yet commenced
Application Requirements
A complete application for a Gibraltar B2C Gambling Operator's Licence must include:
- 1Statement of the regulated activities the applicant proposes to carry on
- 2Registered Gibraltar office address for service of notices and documents
- 3Evidence of satisfaction of all Schedule 2 threshold conditions
- 4Substantive presence plan — current and planned Gibraltar footprint, staffing, and infrastructure
- 5Details of all proposed regulated individuals (Schedule 3 roles)
- 6Detailed business plan with 3-year financial projections
- 7Corporate structure chart covering all group entities and ultimate beneficial owners
- 8Source of funds and source of wealth documentation for all UBOs and key persons
- 9AML/KYC policies and procedures (Proceeds of Crimes Act 2015 compliant)
- 10Responsible gambling policy suite and designated senior manager details
- 11Internal controls framework and compliance monitoring procedures
- 12Customer registration system description and 6-year data retention policy
- 13Terms and conditions and complaints procedure documentation
- 14Evidence of appropriate financial resources
Zitadelle prepares and compiles all application documentation, coordinating with Gibraltar-based legal counsel where formal opinions or local filings are required.
Application Process — Step by Step
Engagement and Scoping
Weeks 1–3Initial review of the group structure, UBO profile, and proposed business model to confirm regulatory eligibility and identify any sensitivities. Full KYC/AML documentation is collected for all UBOs, directors, shareholders, and proposed regulated individuals. Substantive presence strategy and Gibraltar footprint plan are scoped.
Corporate Setup
Weeks 2–6Incorporation or re-domiciliation of the Gibraltar operating entity. Registered office arrangements. Opening of banking relationships with Gibraltar-connected institutions. Registration with the Gibraltar Companies Registry and preparation of constitutional documents.
Application Preparation
Weeks 3–12Preparation of the full application package: business plan and 3-year financial projections; AML/KYC policy suite; responsible gambling framework; internal controls documentation; customer registration system description; terms and conditions; corporate governance pack; source of funds/wealth evidence; substantive presence plan.
Pre-Submission Engagement
Weeks 10–12Optional but strongly recommended: informal pre-submission engagement with the Gibraltar Gambling Division to present the application structure and gauge any concerns before formal submission. Zitadelle manages this dialogue.
Submission
Week 12Formal submission of the complete application package to the Gibraltar Gambling Commissioner. Payment of the non-refundable application fee (£15,000 for betting intermediary; £30,000 for B2C sportsbook/casino).
Commissioner Review
3–6 months post-submissionThe Commissioner reviews the application. There is no statutory determination deadline. Zitadelle manages all correspondence, responds to queries and requests for further information, and maintains active dialogue throughout the review period.
Regulated Individual Approvals
Concurrent or post-reviewThe Commissioner approves proposed regulated individuals. This may run concurrently with the application review or follow it. All Part 1 (CEO, MD) and applicable Part 2 regulated individuals must be approved before the licence is operational.
Licence Grant and Go-Live
Issuance of the B2C Gambling Operator's Licence. Annual licence fee obligations commence immediately. Quarterly duty reporting begins. Zitadelle transitions the client to the ongoing compliance support programme.
Total estimated timeline: 6–9 months
Zitadelle's Advisory Fee
Our professional fee for a Gibraltar iGaming licence engagement ranges from:
£60,000 — £120,000
The specific fee depends on the scope of support required, complexity of the group structure, and the volume of documentation to be prepared from scratch versus client-supplied. We agree a fixed fee within this range before engagement commences.
This fee covers the full engagement from initial scoping through to licence grant — including business plan preparation, all policy documentation, application compilation, Commissioner liaison, regulated individual onboarding support, and post-submission query management.
| Engagement Scope | Fee Range | Best For |
|---|---|---|
| Lighter-touch advisory — prior regulatory experience, existing compliance infrastructure, simple structure | £60,000–£70,000 | Established operators from other Tier 1 jurisdictions adding a Gibraltar licence |
| Full-service advisory — standard end-to-end engagement | £70,000–£90,000 | Most clients — comprehensive support from scoping through to licence grant |
| Complex engagement — multi-entity groups, novel business model, extended regulatory dialogue | £90,000–£120,000 | First-time Tier 1 applicants, exchange operators with complex ownership, prediction market businesses |
Who This Service Is For
Betting Exchanges and Intermediaries
Operators providing a platform through which parties place bets against each other, earning commission rather than assuming risk. Gibraltar's dedicated Betting Intermediary licence and 0.15% duty on commission — with the first £100k exempt — make this the most tax-efficient Tier 1 jurisdiction for exchange models.
Sportsbook Operators (UK & International)
Gibraltar's longstanding relationship with the UK market and its standing as a trusted jurisdiction for major bookmakers make it a natural home for operators seeking banking credibility and counterparty acceptance. Duty of 0.15% on GGY (first £100k exempt) compares favourably against UK Remote Gaming Duty at 21%.
Prediction Market Operators
Gibraltar became the first jurisdiction to license a prediction market operator in 2026. The Commissioner has indicated openness to appropriately structured prediction market businesses. Zitadelle has experience advising on the intersection of prediction markets and the Betting Intermediary framework.
Established Operators Adding Gibraltar
Operators already licensed in Malta, Alderney, or the Isle of Man who wish to add Gibraltar to their portfolio — either for the exchange vertical or for the reputational and commercial benefits of a Gibraltar registration.
Well-Funded Start-Ups
Gibraltar has historically licensed only blue-chip operators, but the Commissioner has signalled openness to appropriately funded, credible start-ups under the 2025 Act. A strong business plan, clear substance commitment, and experienced management team are essential.
Informational only. iGaming regulatory requirements change frequently. Fees and duty rates reflect the Gambling (Duties and Licence Fees) Regulations 2026 (LN.2026/065), in force 1 April 2026. The Part 5 regulated individuals regime had not commenced as of June 2026. Always verify current requirements with the Gibraltar Gambling Commissioner before applying. Last updated: June 2026.
Frequently Asked Questions
Under the Gambling (Duties and Licence Fees) Regulations 2026 (LN.2026/065), which came into force on 1 April 2026, a Gibraltar Betting Intermediary licence costs £15,000 non-refundable application fee plus £100,000 annual licence fee. B2C sportsbook and casino licences have a £30,000 application fee and a tiered annual fee of £50,000, £100,000, or £200,000 depending on gross gambling yield. Betting Intermediary Duty is levied at 0.15% of gross intermediary profit, with the first £100,000 of profit exempt each year.
Ready to apply for a Gibraltar gambling licence?
Speak to Zitadelle AG's iGaming advisory team for a no-obligation jurisdictional assessment. All enquiries handled in strict professional confidence — response within one business day.
Related Licenses
Quick Facts
- Regulator
- Gibraltar Gambling Commissioner
- Governing Act
- Gambling Act 2025 (in force 1 Apr 2026)
- Licence
- B2C Gambling Operator's Licence
- Application Fee
- £15,000 (betting intermediary)
- Annual Fee
- £100,000
- Duty
- 0.15% gross profit (first £100k exempt)
- Min. Capital
- Not prescribed
- Corporate Tax on Gambling
- None
- Timeline
- 6–9 months
- Updated
- June 2026
Disclaimer: This page is for informational purposes only and does not constitute legal or regulatory advice. Requirements, timelines, and fees are subject to change. Always consult directly with the relevant regulatory authority or a qualified professional for the most current information. Zitadelle Advisory Group LTD is not a law firm and does not provide legal representation.