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Gibraltar's Gambling Act Brings B2B Suppliers Under Licence

Gibraltar's Gambling Act now licenses B2B suppliers and marketing firms for the first time, with the transition window for new entrants closing 1 October 2026.

Gibraltar's Gambling Act Brings B2B Suppliers Under Licence

Image credit: Source: Government of Gibraltar and Gambling Division publications. Never imply stock depicts the actual event.

Gibraltar's Gambling Act now licenses platform suppliers, jackpot vendors and gambling marketing agencies for the first time, splitting what was once a single licence into three distinct classes under legislation that took effect 1 April 2026. Act 2026-04 was assented on 23 March and most of its provisions commenced the same day the UK's higher Remote Gaming Duty landed on Gibraltar's biggest client base, replacing a 2005 framework built for an industry of two or three server-based game suppliers.

The law now separates a B2C Gambling Operator's Licence for consumer-facing bookmakers and casinos from a B2B Gambling Operator's Licence for platform providers, content aggregators and managed-trading suppliers, and a new Gambling Operator Support Services (GOSS) licence for marketing agencies and customer-fund handlers, according to the Act text published by the Government of Gibraltar. New applicants have until 1 October 2026, the close of a six-month transition window, before they need a licence to keep operating lawfully, the Gambling Division confirmed on its own site, while existing licensees are grandfathered in.

Three licences where there was one

Before this Act, Gibraltar regulated the operator that took a bet, not the company that built the platform behind it, priced the odds, or ran a jackpot mechanic across a dozen casino brands. Section 17 of the new Act brings B2B content aggregators, direct software suppliers and providers of "managed trading services or virtual or simulated content" inside the licensed perimeter for the first time, and a separate GOSS category catches marketing firms conducting or arranging advertising on a licensee's behalf plus companies holding or managing customer funds.

The fee schedule Gibraltar set alongside the Act tiers cost to the category and, for B2C operators, to gross gaming yield. Application fees run to £30,000 for a B2C licence, £20,000 for a B2B content aggregator, £10,000 for a direct B2B software provider and £8,000 for a GOSS licence, paid in two instalments, per the government's own fees consultation. Annual B2C fees then scale from £50,000 for operators under £20 million in yield to £200,000 above £300 million, charged separately for each betting or gaming vertical a licensee runs. For a jurisdiction that competed for two decades largely on a low headline tax rate, this is a menu of costs calibrated to who is actually extracting value from the market, not just who holds the customer relationship.

The transition window is the real deadline

Commencement got the headlines, but the date that will decide who is still trading legally in Gibraltar is 1 October. The Gambling Division has said new categories of licence holder are "deemed to be conducting lawful activity" only through that six-month window, after which an unlicensed B2B supplier or marketing firm serving Gibraltar-based operators is outside the law. Existing operator licensees keep trading under grandfathered terms while their paperwork catches up, but a platform provider, jackpot vendor or affiliate-facing marketing shop that has never needed a Gibraltar licence before now has roughly a month left to get one.

The Act also introduces a "sufficient substantive presence" test, requiring licensees to show tangible jobs, tax contribution and operational activity in Gibraltar rather than a registered address alone, and creates a Gambling Appeals Tribunal and expanded information-gathering powers for the Commissioner. Minister with responsibility for Financial Services and Gaming Nigel Feetham KC MP told Parliament the industry's questions have already moved past the policy debate: "the main nature of enquiries are now centred on transition and implementation," he said, describing digitalisation work underway so operators can apply online. On who the new regime welcomes, Feetham was direct: "If you are prepared to be a good corporate citizen, paying your taxes, protecting consumers and guarding against the facilitation of financial crime then there is a welcome for you in the jurisdiction."

Suppliers and marketers are now inside the perimeter

The first licence issued under the new B2B category went to ThrillTech, a jackpot technology supplier, on 18 June. "Gibraltar is home to some of the industry's most prestigious operators," said co-founder Benjamin Bradtke, whose ThrillPots side-bet product now joins existing regulated approvals in the UK, Sweden, the Netherlands, Romania, Malta, Peru and Brazil. That a jackpot vendor, rather than a sportsbook or casino brand, is the Act's opening case study is itself the point: Gibraltar's new licence menu is built for the supply chain behind the brand, not just the brand.

Feetham's speaking note singled out marketing as the other gap the old law left open: "Gibraltar is a centre of excellence for gambling marketing, but some of that activity currently sits outside the scope of regulation," he told Parliament, explaining the GOSS category. That closes a loophole this publication has tracked in the UK's Remote Gaming Duty rising to 40%, which took effect the same day as Gibraltar's Act and squeezes the roughly three-quarters of Gibraltar's gambling sector that serves UK-facing brands. A jurisdiction whose tax advantage over London is shrinking is left competing on the breadth and credibility of what it licenses instead.

A different bet on prediction markets

Gibraltar has also licensed its first prediction market operator, ADI Predictstreet, ahead of a dedicated framework due later in 2026, treating the product as gambling-adjacent rather than forcing a blanket ban. Gambling Commissioner Andrew Lyman drew the contrast explicitly: "As a small jurisdiction we are agile, whilst the mindset of some jurisdictions is 'how can we stop this,'" he said, pointing to Spain, France, Portugal, Romania and Ukraine, which have all suspended or blocked prediction-market platforms outright. This publication has covered Denmark's move to block Polymarket and the parallel US fight over Kalshi's prediction markets in Illinois, where state regulators and federal-preemption claims are still colliding. Gibraltar's answer is neither a state gaming licence nor a CFTC filing, but a bespoke gambling-adjacent category, positioning the territory as the jurisdiction willing to regulate a product other markets are still arguing about how to classify.

It is a licence-first approach to market-building this publication has seen before, in how the UAE's GCGRA is assembling a commercial gaming market from the top down rather than waiting for demand to force the issue. Gibraltar is doing the reverse: an established jurisdiction rewriting its licence book to hold onto activity that has outgrown a 20-year-old statute, rather than building a market from nothing.

The pitch shifted from tax rate to licence menu

Gibraltar's old sales pitch to operators was largely fiscal: a low headline gaming tax and light-touch supervision relative to onshore Europe. That pitch weakens every time London raises the Remote Gaming Duty, because the tax gap that justified routing a UK-facing brand through the Rock keeps narrowing. The Gambling Act 2025 is the jurisdiction's answer, not a lower number, but a wider and more precisely priced set of things it is willing to license, from jackpot mechanics to marketing agencies to a product category most of Europe still will not touch.

Whether that holds depends on what happens after 1 October. A six-month grace period is generous by regulatory standards, but it also means the real test of how many B2B suppliers and marketing firms actually register, rather than quietly serve Gibraltar-licensed operators from elsewhere, is still to come. ThrillTech and ADI Predictstreet are the first data points in a much longer list the Commissioner's register will need to fill before the pitch counts as proven.

Related coverage: The UK's Remote Gaming Duty hits 40 percent | The UAE's GCGRA builds a market from the top down | Denmark blocks Polymarket | Kalshi's Illinois prediction market fight

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