Gibraltar’s revamped Gambling Act has dismantled its traditional single-tier B2B licence in favour of a tiered system designed to ease market entry for smaller operators whilst formalising arrangements that previously operated in regulatory grey zones.

A More Proportionate Approach

The shift marks a significant departure from the one-size-fits-all licensing model that has governed supplier operations for years. Under the new framework, companies can now apply for permissions that genuinely reflect their operational scale. Smaller suppliers no longer need to shoulder the costs and compliance burden of a full B2B licence from day one.

The reforms also spell the end of the informal “sheltering” arrangement, whereby suppliers operated under the licensed infrastructure of B2C operators pending their own approval. This long-standing workaround will be replaced by a formal, tiered structure that recognises different market participants have different needs.

According to Steven Caetano of legal advisory firm ISOLAS, the new regime accelerates the entire licensing process whilst introducing proportionate entry points. A supplier not yet ready to pursue a top-tier licence can instead opt for tier three status, which comes with correspondingly lower fees and a restricted customer base. This flexibility allows operators to grow into their regulatory permissions rather than being forced to commit to the highest level immediately.

Modernising for Cloud Infrastructure

The legislative refresh extends beyond licensing tiers. Gibraltar’s regulatory framework is shedding requirements built around physical server infrastructure and local hardware, adapting instead to the reality of cloud-based service delivery that now dominates the industry.

Caetano highlighted the practical necessity: “There’s a lot of cloud services provision. That requirement to have all your technology based in Gibraltar is not realistic nowadays. So we need to adapt to the changing times, and hence the modernisation.”

The overhaul is already generating industry interest. The tiered model makes Gibraltar more attractive to established suppliers seeking independent licences and new entrants looking for cost-effective market access. Nicky Macias of the Gibraltar Betting and Gaming Association acknowledged that attention has now shifted to implementation. The jurisdiction has given operators and suppliers a six-month transition window before the new framework takes full effect, allowing the industry to adapt to the revised regime.

What the team thinks

Baz Hartley says:

Philippa’s identified a genuine positive here, and the tiered model does signal that Gibraltar is listening to operator feedback about proportionality, but what I’d push back on is the “regulatory grey zones” framing, because smaller operators need clarity more than they need flexibility. The real test won’t be whether the tiers exist on paper, it will be whether the compliance burden and costs actually scale down proportionately for each tier, or whether we end up with operators paying nearly as much for Tier 2 as they would have for the old single licence, which would make this a rebrand rather than a reform.