Recent Regulatory Changes for Gibraltar Private Limited Companies: 2025–2026

Overview

Gibraltar has introduced significant regulatory changes affecting private companies limited by shares during 2025–2026. Reforms address beneficial ownership transparency, anti-money laundering supervision, virtual asset service providers, and the UK–Gibraltar financial services passporting framework.

1. UBO Register — Free Public Access (February 2026)

Gibraltar made its beneficial ownership register freely accessible to the general public with effect from February 2026. Any natural or legal person may now search the Companies House Gibraltar register for BO details of Gibraltar private limited companies without needing to demonstrate a legitimate interest. Companies must ensure UBO records are accurate and updated within 14 days of any change.

2. Anti-Money Laundering Regulations 2025 (May 2025)

The Anti-Money Laundering and Terrorist Financing Regulations 2025 replaced the prior 2007 framework. Gibraltar private limited companies in regulated sectors must conduct enhanced due diligence for customers in FATF high-risk jurisdictions, apply a risk-based approach with a 25% BO threshold, and maintain AML records for at least 5 years. Suspicious Activity Reports must be submitted to the GFIU.

3. Virtual Asset Service Providers — FSA Supervision (October 2025)

The Financial Services Act 2019 (VASP) Regulations, effective October 2025, placed all VASP activities under direct FSA supervision. Gibraltar companies operating as VASPs must hold an FSA licence, comply with travel rule obligations for transfers exceeding GBP 1,000, and maintain minimum capital requirements.

4. UK–Gibraltar Financial Services Passporting (December 2025)

The UK–Gibraltar Qualifying Recognition Regime, extended under the December 2025 agreement, allows Gibraltar-authorised financial services firms to passport services into the United Kingdom without separate FCA or PRA authorisation.

Summary of Key Legislative Instruments