Gibraltar Reforms Gambling Licenses: Lower Costs for Software Suppliers

Gibraltar has adjusted its gambling regulatory model. There are now separate fee tiers for software providers directly offering B2B services. The aim is to make the market more accessible, especially for smaller companies. Previously, all providers paid the same annual fee, regardless of their size or business volume in Gibraltar.

The new system, which took effect on April 1, 2026, offers three different cost tiers. These are linked to revenue or the number of integrations with B2C operators licensed in Gibraltar. This allows for more flexible and potentially more cost-effective licensing for many software companies.

Numbers and facts

The new framework divides direct B2B integrations into three annual fee bands. Tier 1 costs £85,000 annually and allows unrestricted integrations with approved Gibraltar B2C licensees. Tier 2 carries a £50,000 annual fee. This is available to providers generating less than £550,000 in gross sales from Gibraltar licensees or maintaining no more than three approved integrations.

Tier 3 reduces the annual fee to £20,000. It covers software providers with relevant sales of less than £200,000 or up to two approved integrations. According to the Gibraltar government, all B2B providers previously paid a flat annual fee of £85,000. Smaller businesses often found this disproportionately expensive. The new tiered system aims to change this. Companies can also advance to higher tiers as their business expands.

Another important aspect is regulatory approval, even if games are offered through an aggregation platform. The original source mentions a £1,000 fee for this approval. Steven Caetano of ISOLAS emphasizes the significance of this innovation:

„The lower direct-integration tiers replace an informal arrangement under which some suppliers initially operated within the systems of a licensed B2C company.“ - Steven Caetano, ISOLAS

Background

The reforms go beyond mere fees. The server location still matters but is no longer the sole test. The regulator can now also consider day-to-day management, operational control, services supplied to Gibraltar licensees, and the company's local presence. The scope of regulated B2B activities has also been expanded. Companies conducting activities that became licensable before April 1, 2026, receive a six-month transitional license. During this period, they must submit a complete application. Existing license holders are transferred into the new system without submitting a fresh application.

The introduction of these tiered license fees was part of a broader consultation on new gambling legislation in Gibraltar. The intention to revise the fee model was announced in 2022. At that time, there were also considerations to introduce separate licenses for marketing service providers, known as affiliates, with an annual fee of £50,000, limited to providers "in or from Gibraltar." Separate regulations are also planned for aggregators, which provide for a basic fee of £85,000 per vertical game category plus 1% of revenue from Gibraltar licensees.

Why it matters for German players

For players in Germany, these changes in Gibraltar have no direct impact on their online gambling experiences. The German online gambling market has been comprehensively regulated since July 2021 by the State Treaty on Gambling (GlüStV 2021). This treaty sets strict rules that differ significantly from the licensing models of other countries.

German players should only play in online casinos that hold a license from the Joint Gambling Authority of the Federal States (GGL). These casinos are bound by the rules of GlüStV 2021. This includes a betting limit of 1 Euro per spin on slot machines and a monthly deposit limit of 1,000 Euro, controlled by the central monitoring system LUGAS.

Casinos with a Gibraltar license, an MGA license from Malta, or a Curaçao license operate outside this German legal framework. They cannot legally advertise in Germany and should be avoided by German players. The reforms in Gibraltar primarily affect the B2B relationships of software providers. They do not change the strict regulations that apply to online gambling in Germany.

What it means for GGL-licensed casinos

For online casinos holding a German GGL license, the new provisions in Gibraltar have only a very indirect significance. GGL-licensed providers must procure their software and games from providers that comply with German guidelines. These guidelines are often stricter than those of other jurisdictions, especially concerning player protection and technical requirements.

If a software provider already licensed in Gibraltar also wishes to serve the German market, they must meet the specific requirements of the GGL. They will then also pay the corresponding fees. While the cost structure in Gibraltar might facilitate market entry for some aspiring software developers, this does not automatically equate to compliance with GlüStV 2021. German casinos must continue to carefully check whether the software offered meets all country-specific requirements.