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  5. Gibraltar — the Gambling Act 2025: Licensing for European Operations

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Foreign Licenses and Jurisdictions

Gibraltar — the Gambling Act 2025: Licensing for European Operations

Is the Gambling Act 2005 still in force in Gibraltar?

No. The Gambling Act 2025 commenced on 1 April 2026 (Notice of Commencement 2026/064); the 2005 Act is repealed, and old licensees are deemed licensed under the new act.

When does the six-month transition window close?

From commencement (1 April 2026) the six-month window closes around 1 October 2026. Within it, persons in the new categories obtain a licence by notification and application, and are deemed to be conducting lawful activity.

How much does a Gibraltar licence cost?

The fee types are officially published, but the amounts sit in the schedules of the 2026 regulations — the administrative guidelines do not repeat them. The budget is built on figures confirmed with the Division.

Does a Gibraltar licence replace a Georgian permit?

No. Articles 5 and 11 of the Georgian gambling law tie organising and supplying into Georgia to a Georgian permit, issued only to an entrepreneur registered in Georgia.

8 min·22 Sep 2026

Anyone writing today that Gibraltar licenses under the Gambling Act 2005 is working from a dead text: on 1 April 2026 the new Gambling Act 2025 entered into force, the 2005 Act was repealed, and the regime is in transition — the six-month licensing window for the new categories is approaching its end as this page is prepared. That is not a technicality. Any Gibraltar decision — entering, pausing, or assessing an existing structure — must now be built on the new act, its widened scope and its deadlines. This page describes the new regime strictly from the Gibraltar Gambling Division and the official statute database, marks separately what still needs confirmation, and closes with the Georgian cross-border layer.

We repeat the principle established on our other jurisdiction pages: a Gibraltar licence creates no access to the Georgian market and does not remove Georgian permits, taxes or reporting. But one element of the new Gibraltar regime — the widened "reach" test — means Georgian groups should also assess whether they fall within this regulation at all; we deal with that below.

The Gambling Act 2025: what changed on 1 April 2026

The new act formally commenced on 1 April 2026 — by Notice of Commencement 2026/064 — and has already been amended once, by the Gambling (Amendment) Act 2026. The Gambling Act 2005 is marked repealed in the official statute database. The architecture keeps a proven shape: licences are granted by the Licensing Authority — the designated Minister — while day-to-day regulation belongs to the Gambling Commissioner, supported by the Gambling Division's staff. Applications run through the eGov portal or by email; the Division also publishes a list of Approved Testing Facilities. Historically the Division licensed blue-chip companies with track records, but in its own words it considers start-ups and relocations as well.

The new scope and the "reach" test

In the Division's own wording, the new regime's scope covers: B2C — gambling businesses managed or controlled in or from Gibraltar; B2B — supplies made in or from Gibraltar or to a Gibraltar entity; regulated individuals; and gambling marketing activity conducted in or from Gibraltar. Two elements deserve particular attention because they step beyond classic territorial logic. The first is the "managed or controlled in or from Gibraltar" test, which captures B2C business by the seat of management rather than only by the server's address. The second is the rule extending the regime to companies holding more than a 25% share in a relevant company. For a Georgian group this means: if any ring of your structure manages operations from Gibraltar, conducts marketing from there, or holds more than 25% of a Gibraltar licensee, the regime's assessment reaches your own position. A new vertical has also appeared — prediction markets, under the Prediction Market Regulations 2026 with their own fees-and-duties rules.

The transition: the six-month window and its end

The transition rules are of two kinds. First, persons licensed under the 2005 Act are deemed to be licensed under the Gambling Act 2025 — a clean grandfathering. Second, persons within the new categories of licence have a period of six months from the commencement date in which to obtain a licence, in two steps: notifying the Gambling Division and applying for a licence; within that window such persons are deemed to be conducting lawful activity. Counting from 1 April 2026, the six-month window closes around 1 October 2026: as this page is being prepared (September 2026) it is running out. If your structure falls within the new scope and has not yet been brought onto a Gibraltar licence, the time factor is now part of the decision — and the precise current state must be established with the Division.

Duties and fee types — the financial rhythm of the regime

The financial side divides in two. The first part is duties, established by the Gambling (Duties and Licence Fees) Regulations 2026, which repealed the 2011/2018 rules: the General Betting Duty on gross betting profit, the General Gaming Duty on gross gaming profit, and the Betting Intermediary Duty on commission income. The licensing year runs from 1 April to 31 March; the quarterly return is due by the 15th of the month following quarter-end, with payment by the end of that month; nil returns are mandatory. The profit definition is strict: stakes less payouts; bonuses, free bets and marketing costs are not deductible; chargebacks stay in the base.

The second part is the fee types listed in the regulations' schedules: the application fee (payable at submission, non-refundable — an application is not "formally made" until it is paid); the annual licence fee (due 1 April, payable by 30 April, pro-rated from the quarter of grant); change-of-control fees (a base fee on notice plus a complexity top-up up to a prescribed maximum); content-provider approval fees (for supply through the Gibraltar-licensed aggregator platform); regulated-individual approval fees, including material-change applications; and duplicate-document fees. Here lies a real limitation: the administrative guidelines deliberately do not repeat the specific amounts — they sit in the schedules of the 2026 regulations, and the published versions were not accessible to our verification pass. This page therefore shows no Gibraltar fee figures — not as an accusation, but as an honest statement of source level: exact amounts and rates must be read from the schedules of the regulations in force and confirmed with the Division.

The Georgian cross-border layer

The Gibraltar licence stays within the same boundary: it gives nothing on the Georgian market. Article 5, part 1 of the Georgian law on gambling ties organising and supplying into Georgia to a Georgian permit, and article 11, part 2 grants that permit only to an entrepreneur registered in Georgia. In Gibraltar's case a second direction is added: because the new regime is built on the "managed or controlled from Gibraltar" test, a Georgian group's management of a Gibraltar ring makes the Georgian person even more clearly the central figure of the structure — and the Georgian tax and reporting layer is built precisely on that person.

That layer is written in familiar articles: article 80, part 7 of the Tax Code — margin taxation of an individual organiser; article 81 — the rates, including the 5% line on supply-permit excess income; article 8 — player winnings and loss offsetting; article 171(b) — VAT exemption of gambling services. Reporting: articles 3, 11 and 12 of the AML law where a Georgian entity is in the chain; article 29(b) of the gambling law — winnings registration with reporting to the Financial Monitoring Service; article 36-1 — the selected-person regime for system-electronic supply. And articles 951 and 952 of the Civil Code: a claim from a game arises only on a permitted game.

Frequently asked questions

Four questions repeat themselves in consultations on Gibraltar's new regime.

Is the Gambling Act 2005 still in force?

No. The Gambling Act 2025 commenced on 1 April 2026 by Notice of Commencement 2026/064, and the 2005 Act is repealed. Persons licensed under the old act are deemed licensed under the new one, but their activity now continues on the new basis.

What is the six-month window and when does it close?

Persons within the new licence categories have six months from commencement to obtain a licence — by notifying the Gambling Division and applying; during that period they are deemed to be conducting lawful activity. From 1 April 2026 the window closes around 1 October 2026 — it is running out at the time of writing; the current state is established with the Division.

How much does a Gibraltar licence cost?

The fee types are officially published — application, annual, change-of-control, content-provider and regulated-individual fees — but the amounts sit in the schedules of the regulations in force, and the administrative guidelines do not repeat them. Budgeting is therefore done on figures confirmed by the Division; this page deliberately quotes none.

Does the new regime touch a Georgian group if the licensee is in Gibraltar?

Possibly. The scope covers B2C business managed or controlled in or from Gibraltar, B2B supplies, marketing conducted from Gibraltar, and holders of more than 25% of a relevant company. If any ring of a Georgian group meets that test, an individual assessment is needed — a separate argument for building the structure correctly from the start.

How We Help on Legal.ge

Legal.ge runs the Gibraltar direction in the reality of the new regime: we establish whether your structure meets the new scope and the 25%-share test; if you are within the six-month window, we prepare the notification to the Division and the application through the eGov portal; we build the duties calendar on the licensing year and the quarterly return deadlines, and we obtain the live schedule amounts from the Division for budgeting. In parallel we construct the Georgian layer — the tax and reporting plan of the Georgian person behind the structure, under the relevant articles. Gibraltar is in the middle of a major reform — which is exactly why it must be read from official sources rather than last year's handbooks. Contact us, and we will start with an assessment of your structure.

Updated: 22 Sep 2026

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