Cryptoassets Regulatory Intelligence

Gibraltar

GI schema crypto-v2.0.0 trajectory: not yet assessedregulated (omnibus)Also covered: Financial Integrity · World Payments

Last updated · 9 categories · 34 sourced findings · 28 sources in the cumulative register

Evidence re-verified: ·Position last changed: ·
Record history & provenance ▾

Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: Expert-reviewed · As-of date: 2026-10-26

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Framework postureRegulated (omnibus)9 of 9 modules populated · Expert-reviewed
Lead supervisory authorityGovernment of Gibraltar (Gibraltar Laws)Primary statutory & supervisory perimeter
Next milestone (> 2026-10-26)2026-Q4Protected Cell Companies (Amendment) Bill 2026 passage
Module coverage & confidence9 / 9 modules assessed9 Confirmed · 0 Probable · 0 Uncertain

Jurisdiction lead brief

Latest update · 25 October 2026

Lead Signal

Gibraltar's principles-based distributed ledger technology licensing regime continues to issue new permissions, with Revolut Global Digital Assets Limited obtaining a Part 7 permission from the Gibraltar Financial Services Commission to undertake transmission and execution of virtual asset orders, virtual asset custody and virtual asset staking. The grant was confirmed in HM Government of Gibraltar press release 796/2026 the same day, 19 October 2026, per secondary reporting. The underlying framework, the Financial Services (Distributed Ledger Technology Providers and Virtual Asset Arrangement Providers) Regulations 2020 as amended, requires any person carrying on by way of business the use of DLT to store or transmit value belonging to others in or from Gibraltar, or, from 27 October 2025, providing virtual asset arrangements, to hold a Part 7 permission from the GFSC.

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Crypto Licensing

Gibraltar regulates cryptoasset business under Schedule 2 Part 16 of the Financial Services Act 2019 (retitled 'Value stored or transmitted by database and virtual asset arrangements' by the Financial Services (Regulated Activities) (Amendment) Regulations 2025, LN 2025/254, in force 27 October 2025) and the renamed Financial Services (DLT Providers and VAA Providers) Regulations 2020 (LN 2020/012). Two distinct Part 7 GFSC authorisation tracks apply: (1) DLT Providers using distributed ledger technology by way of business to store or transmit value belonging to others (Schedule 2 para 140), and (2) Virtual Asset Arrangement Providers (VAAPs) providing virtual asset arrangements (fiat-to-virtual-asset or virtual-asset-to-virtual-asset exchange and arrangement services, Schedule 2 para 139A, subject to para 139B exclusions). Under LN 2025/254 transitional sub-regulations (2)–(4), existing VAA businesses were required to give written notice to the GFSC within 14 days of 27 October 2025 and submit a Part 7 application within six months (extendable by the GFSC in exceptional circumstances), and may continue operating pending determination. Initial Part 7 applications follow the GFSC Staged Application for Authorisation Approach (Stages 1–3 plus optional Stage 4 mobilisation of 3–6 months). Token issuers selling their own tokens remain subject to the POCA 2015 (Relevant Financial Business) (Registration) Regulations 2021, while VAA businesses moved out of the AML-only registration regime and are being transitioned into the DLT Framework in 2026. Under regulation 5A of the DLT Regulations and the GFSC Guidance Note on Notification of Dividend Payments (16 July 2026, paras 2.2–2.3), a DLT or VAA provider must give at least 30 days' prior complete notice (including Appendix I documentation) before declaring or making any dividend or capital distribution (including capital repayments of a loan to a parent or holding company). Under the Financial Services (Fees) Regulations 2020 (LN 2020/040, consolidated 3 September 2026, Schedules 1B, 2 and 2A; LN 2025/257 effective 1 April 2026), the obsolete Category 1–3 fee model no longer applies: DLT and VAA providers in Fee Block G1 pay a £12,254 base annual fee, a 0.1% trade activity fee (DLT: reported volume of trade; VAA: value of trades arranged) capped at £92,700 on the trade-activity component, and a £28,183 additional annual fee, plus a separate £4,017 annual AML supervision fee (Schedule 1B) and £407 per approved individual annually (Schedule 2A, with a £788 application fee where made separately from the firm licence application). A £45,000 one-off firm Part 7 application fee is carried forward from draft practitioner tables pending primary verification of the current Schedule 1 row. Holding another FSA permission does not grant a blanket DLT/VAA exemption: the incidental-activity route in FSA Schedule 2 para 141 (read with para 140 and GFSC Scope Guidance para 5.5) is conditional, must be verified on current statutory conditions before reliance, and does not automatically exclude separate VAA activity under para 139A. Carrying on a regulated activity without authorisation is prohibited by FSA s.8 (practitioner sources cite criminal penalties of up to 2 years' imprisonment and/or a fine; exact penalty section subject to pinpoint check).

Open gap — crypto-int-2Whether the dividend non-objection mechanism (reg 5A) specifies an objection period length was not confirmed.no under-indexing note recorded

The standing position above is expert-reviewed text (as at 24 Oct 2026). Material below dated after 24 Oct 2026 was added by a later AI monitoring cycle and is displayed as Pending expert review; it does not amend the reviewed brief.

Periodic update · new data 2026-10-25 Pending expert review

Crypto Licensing

Gibraltar licenses distributed ledger technology and virtual asset arrangement activity under the Financial Services (Distributed Ledger Technology Providers and Virtual Asset Arrangement Providers) Regulations 2020, as amended. Any person carrying on by way of business the use of DLT to store or transmit value belonging to others in or from Gibraltar must hold a Part 7 permission from the Gibraltar Financial Services Commission. From 27 October 2025, an amendment extended that perimeter to cover providers of virtual asset arrangements as well, bringing a wider population of digital-asset business models within the same Part 7 permission requirement. A further 2026 amendment introduced a dividend non-objection mechanism under regulation 5A: a relevant provider may make a dividend or comparable capital distribution only after notifying the GFSC and where the GFSC has not objected, though the exact length of the objection period and the required form of notification have not been confirmed.

The regime continues to issue new licences under this structure. Revolut Global Digital Assets Limited, a newly established Gibraltar entity, obtained a Part 7 permission to undertake transmission and execution of virtual asset orders, virtual asset custody and virtual asset staking, confirmed by HM Government of Gibraltar press release 796/2026 on 19 October 2026. The GFSC administers the regime on a principles-based basis, and new licence grants of this kind indicate the framework remains commercially viable for firms seeking to combine digital-asset custody and execution services with other regulated activities under Gibraltar's broader financial-services licensing structure.

Outlook

Whether the objection-period length under the regulation 5A dividend non-objection mechanism is clarified in further GFSC guidance, and whether additional DLT/VAA licences are granted to new entrants, are the principal items to watch.

Sources and findings (12)
  1. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Financial Services (Distributed Ledger Technology Providers) Regulations 2020 (LN 2020/012) renamed Financial Services (DLT Providers and VAA Providers) Regulations 2020 by LN 2025/254 from 27 October 2025.retrieved M5bindingin force
  2. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — LN 2025/254 regs 2–3 insert FSA 2019 Schedule 2 paras 139A ('Providing virtual asset arrangements') and 139B (exclusions) and retitle Part 16 'Value stored or transmitted by database and virtual asset arrangements', requiring Part 7 GFSC permission from 27 October 2025 alongside the para 140 DLT Provider custody/transmission track.retrieved M5bindingin force
  3. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Under LN 2025/254 transitional sub-regulations (2)–(4), existing VAA businesses had to notify the GFSC in writing within 14 days of 27 October 2025 and apply for Part 7 permission within six months (with GFSC power to extend in exceptional circumstances), and may continue operating pending determination.retrieved M4bindingin force
  4. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — Under DLT Regulations reg 5A and GFSC Guidance Note: Notification of Dividend Payments (16 July 2026, paras 2.2–2.3), firms must give at least 30 days' prior complete notice (with Appendix I documents) before declaring or making any dividend or capital distribution, including capital repayments of a loan to a parent or holding company.retrieved M4bindingin force
  5. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Under Financial Services (Fees) Regulations 2020 (LN 2020/040, consolidated 3 September 2026, Schedule 2; LN 2025/257), annual fees for DLT Providers and VAA Providers comprise a £12,254 base fee, a 0.1% trade activity fee (DLT: reported volume of trade; VAA: value of trades arranged) capped at £92,700 on the trade-activity component, and an additional annual fee of £28,183 (the former Category 1–3 complexity model is obsolete).retrieved M4bindingin force
  6. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Under Financial Services (Fees) Regulations 2020 Schedule 1B (as amended by LN 2025/257 reg 3(4), effective 1 April 2026), DLT Providers and VAA Providers in Fee Block G1 pay a separate annual AML supervision fee of £4,017 in addition to ordinary annual fees.retrieved M3bindingin force
  7. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Under Financial Services (Fees) Regulations 2020 Schedule 2A (as amended by LN 2025/257 reg 3, effective 1 April 2026), the annual approved-individual fee is £407 per individual for the all-other-regulated-persons category applicable to DLT/VAA firms, plus a separate £788 individual approval application fee where applied for separately from the firm licence application.retrieved M3bindingin force
  8. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — A one-off £45,000 firm Part 7 application fee for a DLT Provider or VAAP is carried forward from draft practitioner tables; primary-text verification against the current Schedule 1 row of the Financial Services (Fees) Regulations 2020 remains open.retrieved M3bindingin force
  9. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — Token issuers selling their own tokens remain under the POCA 2015 (Relevant Financial Business) (Registration) Regulations 2021, whereas VAA businesses were moved out of the AML-only registration regime by LN 2025/254 and are being transitioned into the DLT Framework by the GFSC in 2026.retrieved M4bindingin force
  10. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — Initial Part 7 applications follow the GFSC Staged Application for Authorisation Approach from 2024, structured across Stages 1–3 plus an optional Stage 4 mobilisation phase (3–6 months).retrieved M3non-bindingin force
  11. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Holding another Financial Services Act 2019 permission does not provide a blanket DLT exemption; the conditional incidental-activity exclusion in FSA 2019 Schedule 2 para 141 (read with para 140 and GFSC Scope Guidance Note para 5.5) requires verification of all current statutory conditions and does not automatically exclude separate VAA activity under para 139A.retrieved M4bindingin force
  12. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Carrying on a regulated DLT or VAA activity without authorisation is prohibited by Financial Services Act 2019 s.8; practitioner sources report criminal liability of up to 2 years' imprisonment and/or a fine (offence/penalty section pinpoint pending primary verification).retrieved M4bindingin force

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Token Classification

Gibraltar has not adopted a codified statutory token taxonomy equivalent to EU MiCA (such as separate statutory categories for ARTs, EMTs or utility tokens); regulatory classification under the Financial Services Act 2019 and the GFSC Guidance Note on Scope of the DLT Framework is activity-based, turning on whether a business stores/transmits third-party value on a distributed ledger (DLT Provider track, Schedule 2 para 140) or provides non-custodial virtual asset exchange/arrangement services (VAA Provider track, Schedule 2 para 139A). At the private-law foundation, the Property (Digital Assets etc) Act 2026 (Act 2026-09), which received assent and commenced on publication on 23 March 2026 (s.2), confirms in s.3 that a thing—including a digital or electronic thing—is not prevented from being an object of personal property rights merely because it is neither a thing in possession nor a thing in action. For fund tokenisation, the Protected Cell Companies (Amendment) Act 2026 (Act 2026-20), published on 9 July 2026 and commenced on 30 July 2026 under LN 2026/294, establishes a statutory framework for tokenised cell shares and DLT share registers in protected cell companies operating as Experienced Investor Funds, subject to statutory requirements and prior GFSC approval. Older secondary media reporting (CoinDesk 2020) referring to a GFSC distinction between 'virtual assets' and 'virtual asset denominated instruments' (VADIs) and a restriction on counting internally generated tokens toward regulatory capital following a public token offering is not supported by an identified primary statutory or current GFSC guidance text and is treated as unverified non-binding commentary.

No periodic updates recorded in this cycle

Sources and findings (4)
  1. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — The Property (Digital Assets etc) Act 2026 (Act 2026-09) received assent and commenced on 23 March 2026 (s.2); s.3 confirms that a digital or electronic thing is not prevented from being an object of personal property rights merely because it is neither a thing in possession nor a thing in action.retrieved M5bindingin force
  2. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — The Protected Cell Companies (Amendment) Act 2026 (Act 2026-20), published on 9 July 2026 and commenced on 30 July 2026 under LN 2026/294, provides for tokenised cell shares and DLT share registers for protected cell companies operating as Experienced Investor Funds, subject to statutory requirements and GFSC approval.retrieved M4bindingin force
  3. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — GFSC Guidance Note: Scope of the DLT Framework classifies digital-asset activity by function performed (custodial DLT Provider vs non-custodial VAA Provider) rather than by a MiCA-style statutory token taxonomy.retrieved M4non-bindingin force
  4. T3 · CoinDeskCoinDesk — Secondary media reporting from 2020 referring to a 'virtual asset denominated instruments' (VADI) distinction and an internally-generated-tokens capital restriction has no identified primary GFSC statutory or guidance source and is treated as unverified non-binding commentary.retrieved M2non-bindingguidance

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On-Chain Activity Regime

Gibraltar has no separate statutory licensing category dedicated solely to staking, DeFi lending, or decentralized exchange (DEX) protocols; instead, on-chain activities are assessed functionally against the two Schedule 2 Part 16 regulated activities under the Financial Services Act 2019 and the GFSC Guidance Note on Scope of the DLT Framework. Custodial staking or DeFi activities involving the storage or transmission of value belonging to others fall within the DLT Provider perimeter (para 140), whereas non-custodial by-way-of-business exchange or arrangement of virtual assets—including central-limit or arranged DEX-facilitation models operating by way of business in or from Gibraltar—falls to be assessed under the Virtual Asset Arrangement Provider perimeter (para 139A, effective 27 October 2025). On the tax side, Schedule 1 para (1A)(b) of the Income Tax Act 2010 expressly treats income generated from virtual assets—including lending virtual assets for use by another person or proof-of-stake validation—as 'similar amounts' to interest Where applicable statutory conditions are met.

No periodic updates recorded in this cycle

Sources and findings (2)
  1. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — On-chain activities (staking, DeFi lending, DEX facilitation) are regulated functionally under FSA 2019 Schedule 2 Part 16: custodial storage/transmission triggers the DLT Provider track (para 140), while non-custodial by-way-of-business virtual-asset exchange or arrangement triggers the VAA Provider track (para 139A).retrieved M4bindingin force
  2. T3 · CoinDeskCoinDesk — The GFSC signalled in November 2022 that DeFi lending was a focus area for supervisory development without enacting a standalone DeFi licensing statute separate from the DLT/VAA framework.retrieved M2non-bindingguidance

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Stablecoin Regime

Gibraltar has not enacted a standalone MiCA-style stablecoin issuance, reserve-composition or redemption-right statute; stablecoin issuance or custodial/arrangement activity conducted in or from Gibraltar is assessed under the general Financial Services Act 2019 (DLT/VAA Providers and e-money/payment services frameworks). However, for settlement use within licensed prediction markets, regulation 22 ('Use of digital asset payments') of the Prediction Market Regulations 2026 (LN 2026/176, in force 13 July 2026 under the Gambling Act 2025) expressly permits an authorised operator to use digital asset payments, including stablecoins, for funding customer accounts, providing collateral, settling contracts, and making payments or withdrawals. Regulation 22 further provides that such use does not of itself affect the legal character of a contract or cause the operator or participants to carry on another regulated activity.

Open gap — crypto-int-1Protected Cell Companies (Amendment) Bill 2026's current parliamentary stage as of 2026-10-25 was not located.no under-indexing note recorded
Horizon · 2026-Q4 (± more than a year)Protected Cell Companies (Amendment) Bill 2026 passageProposed · Tier 3 source

No periodic updates recorded in this cycle

Sources and findings (2)
  1. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Regulation 22 ('Use of digital asset payments') of the Prediction Market Regulations 2026 (LN 2026/176, in force 13 July 2026 under the Gambling Act 2025) permits an authorised operator to use digital asset payments, including stablecoins, for funding accounts, collateral, settlement and payments/withdrawals, and provides that such use does not of itself affect the legal character of a contract or cause the operator or participants to carry on another regulated activity.retrieved M4bindingin force
  2. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — Outside the sector-specific Prediction Market Regulations 2026 settlement rule, Gibraltar has no standalone statutory stablecoin issuance or codified reserve-composition statute akin to MiCA's EMT/ART regime; issuance is assessed under general FSA 2019 DLT/VAA and e-money rules.retrieved M3non-bindingin force

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Consumer Protection

Consumer and customer-asset protection in Gibraltar's crypto framework is delivered through the ten statutory regulatory principles in the Financial Services (DLT Providers and VAA Providers) Regulations 2020 alongside general Financial Services Act 2019 conduct rules (including the Financial Services (Core Principles and Consumer Duty) Regulations 2024 and the Restricted Promotions Regulations 2025). In its current Guidance Note on Scope of the DLT Framework (paras 5.11–5.12), the GFSC confirms a critical track distinction between DLT Providers and VAA Providers: Principle 5 (protection of customer assets) is not applicable to VAA Providers because VAA Providers never take custody of client virtual assets (whereas Principle 5 applies in full to custodial DLT Providers), and Principle 10 (market integrity) is unlikely to apply to VAA Providers (para 5.12) while continuing to bind DLT Providers against market manipulation and insider dealing. While the Financial Services Act 2019 contains a statutory market-abuse regime (insider dealing, unlawful disclosure, market manipulation) limited to traditional financial instruments, there is no separate crypto-specific statutory market-abuse offence outside Principle 10.

No periodic updates recorded in this cycle

Sources and findings (3)
  1. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — Under GFSC Guidance Note: Scope of the DLT Framework (paras 5.11–5.12), Principle 5 (protection of customer assets) is not applicable to VAA Providers because they never take custody of client assets, and Principle 10 (market integrity) is unlikely to apply to VAA Providers (para 5.12), whereas both principles apply in full to custodial DLT Providers.retrieved M5bindingin force
  2. T3 · Chambers and PartnersChambers and Partners — The Financial Services Act 2019 market-abuse regime (insider dealing, unlawful disclosure, manipulation) is limited to financial instruments; there is no separate crypto-specific statutory market-abuse regime, and Principle 10 of the DLT Regulations covers equivalent market-integrity conduct for DLT Providers.retrieved M3bindingin force
  3. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Custodial DLT Providers must segregate and protect customer virtual assets as a mandatory condition of their Part 7 permission under Principle 5 of the Financial Services (DLT Providers and VAA Providers) Regulations 2020.retrieved M5bindingin force

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Tax Treatment

Gibraltar does not levy capital gains tax on private or corporate capital disposals, and the headline corporate income tax rate is 15% from 1 July 2024 on income accruing in or derived from Gibraltar. Crucially, the Income Tax Act 2010 (consolidated 23 March 2026, Schedule 1, including para (1A)(b)) contains explicit cryptoasset provisions: 'similar amounts' to taxable interest include income from lending or otherwise generating income from virtual assets (whether through use by another person or proof-of-stake validation), deemed to accrue in and derive from Gibraltar where the statutory conditions apply, alongside specific provision regarding interest received by DLT Part 7 permission holders (note: exact charging-provision pinpoint and original commencement date remain flagged for verification). On international tax transparency, the OECD CARF commitment list (updated 14 September 2026) records Gibraltar's political commitment to undertake first CARF information exchanges by 2028; however, an enacted domestic Gibraltar CARF implementing statute and domestic reporting commencement dates remain unverified. LN 2026/032 amends the International Co-operation (Improvement of International Tax Compliance) Regulations 2016 (CRS) to address CARF-related duplicate-reporting interactions, and must not be conflated with standalone domestic CARF implementation.

Horizon · 2028 (± more than a year)OECD CARF commitment: first information exchanges by 2028 (domestic implementing instrument unverified)Proposed · Tier 1 source

No periodic updates recorded in this cycle

Sources and findings (3)
  1. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Under the Income Tax Act 2010 (consolidated 23 March 2026, Schedule 1, including para (1A)(b)), 'similar amounts' to interest include income from lending or otherwise generating income from virtual assets (use by another person, or proof-of-stake validation), deemed to accrue in and derive from Gibraltar, with specific provision on interest received by DLT Part 7 permission holders; Gibraltar's headline corporate income tax rate is 15% from 1 July 2024 (exact charging-provision pinpoint and commencement date remain open for verification).retrieved M5bindingin force
  2. T1 · OECD Global Forum on Transparency and Exchange of Information for Tax PurposesOECD Global Forum on Transparency and Exchange of Information for Tax Purposes — The OECD CARF commitment list (updated 14 September 2026) places Gibraltar among jurisdictions committed to first CARF exchanges by 2028; domestic Gibraltar CARF implementing legislation and domestic reporting commencement dates remain unverified, while LN 2026/032 amends the 2016 CRS Regulations for CARF duplicate-reporting interaction rather than enacting standalone CARF obligations.retrieved M4non-bindingproposed
  3. T2 · European Commission / EUR-LexEuropean Commission / EUR-Lex — Gibraltar's tax regime structurally excludes capital gains from taxable profit where disposals are capital in nature rather than trading income.retrieved M4bindingin force

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Cross-Border Transfer

Cross-border virtual-asset transfers in or from Gibraltar are governed by the Funds (Transfer) Regulations 2026 (LN 2026/134), made under the Proceeds of Crime Act 2015, which commenced on 15 July 2026 (reg.2) and replaced the Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021. Part 3 applies to virtual-asset transfers where the originator's, beneficiary's or intermediary VASP has its registered office in Gibraltar, with no general de minimis exemption from Part 3 information requirements. Instead, regulation 16(5) imposes an additional ownership/control assessment for outbound self-hosted-address transfers exceeding the sterling equivalent of EUR 1,000, and regulation 18(2) applies an exceeding-EUR 1,000 threshold for inbound self-hosted-address transfers (distinct from Part 2 ordinary-funds concessions and the narrow reg.4(9) domestic goods/services payment exemption up to the sterling equivalent of EUR 1,000). On international standing, FATF removed Gibraltar from increased monitoring in February 2024, MONEYVAL published its 2nd Enhanced Follow-Up Report in May 2024, and the EU removed Gibraltar from its high-risk third-country AML list effective 5 August 2025. On cross-border market access, UK SI 2025/1182 (in force 16 December 2025, amending SI 2019/589 Parts 2–3) extends the temporary UK-Gibraltar financial-services transitional arrangements by 12 months to 31 December 2026, while DLT/VAA permissions do not confer an EU MiCA passport (eligibility of DLT/VAA activities under the scheduled categories of SI 2019/589 remains flagged for pinpoint verification).

Horizon · 2026-12-31 (± a quarter)UK-Gibraltar transitional arrangements extended to 31 December 2026 by SI 2025/1182Adopted, not yet in force · Tier 1 source

No periodic updates recorded in this cycle

Sources and findings (4)
  1. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — The Funds (Transfer) Regulations 2026 (LN 2026/134), made under POCA 2015, commenced on 15 July 2026 (reg.2) and replaced the Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021, applying to virtual-asset transfers where the originator's, beneficiary's or intermediary VASP has its registered office in Gibraltar.retrieved M5bindingin force
  2. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Under the Funds (Transfer) Regulations 2026 (LN 2026/134), no general de minimis threshold exempts virtual-asset transfers from Part 3 Travel Rule information requirements; reg.16(5) (outbound > GBP equivalent of EUR 1,000) and reg.18(2) (inbound > EUR 1,000) impose additional ownership/control assessments for self-hosted-address transfers, distinct from Part 2 concessions and the narrow reg.4(9) domestic goods/services exemption.retrieved M5bindingin force
  3. T1 · UK Legislation (legislation.gov.uk)UK Legislation (legislation.gov.uk) — The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025 (UK SI 2025/1182, in force 16 December 2025) extend the UK-Gibraltar transitional market-access arrangements under SI 2019/589 Parts 2–3 by 12 months to 31 December 2026 (exclusion of DLT/VAA activity from the SI 2019/589 scheduled categories remains subject to schedule pinpoint verification).retrieved M4bindingin force
  4. T1 · FATF / MONEYVAL / European CommissionFATF / MONEYVAL / European Commission — FATF removed Gibraltar from increased monitoring in February 2024, followed by MONEYVAL's 2nd Enhanced Follow-Up Report in May 2024 and removal from the EU high-risk third-country AML list effective 5 August 2025.retrieved M4non-bindingin force

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AML / CFT Regime

Gibraltar's crypto AML/CFT framework operates under the Proceeds of Crime Act 2015 (POCA 2015) and the Funds (Transfer) Regulations 2026 (LN 2026/134, commenced 15 July 2026, replacing the 2021 Transfer of Virtual Assets Regulations). Part 3 of LN 2026/134 enforces the virtual-asset Travel Rule with no general de minimis threshold on required originator and beneficiary information, while requiring additional ownership/control verification for transfers involving self-hosted addresses above the EUR 1,000 threshold (reg.16(5) outbound exceeding the sterling equivalent of EUR 1,000; reg.18(2) inbound exceeding EUR 1,000). Token issuers selling their own tokens remain subject to AML registration under the POCA 2015 (Relevant Financial Business) (Registration) Regulations 2021 (per the GFSC VASP Registration Scope Guidance Note v1.0), whereas Virtual Asset Arrangement Providers moved into full Part 7 Financial Services Act 2019 authorisation under LN 2025/254 from 27 October 2025. Under Schedule 1B of the Financial Services (Fees) Regulations 2020 (as amended by LN 2025/257, effective 1 April 2026), DLT Providers and VAA Providers in Fee Block G1 pay a dedicated £4,017 annual AML supervision fee.

No periodic updates recorded in this cycle

Sources and findings (2)
  1. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Funds (Transfer) Regulations 2026 (LN 2026/134, commenced 15 July 2026) govern virtual-asset Travel Rule obligations under POCA 2015 with no general Part 3 de minimis exemption and mandatory self-hosted-address ownership/control assessments above EUR 1,000 (reg.16(5) / reg.18(2)).retrieved M5bindingin force
  2. T1 · Gibraltar Financial Services CommissionGibraltar Financial Services Commission — Token issuers selling their own tokens remain registered under the POCA 2015 (Relevant Financial Business) (Registration) Regulations 2021, while VAA businesses transitioned to FSA 2019 Part 7 permission under LN 2025/254.retrieved M4bindingin force

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Commercial Activity

Gibraltar's digital-asset market infrastructure advanced materially in 2026 through two enacted statutory milestones: (1) the Property (Digital Assets etc) Act 2026 (Act 2026-09, assent and commencement 23 March 2026), confirming statutory personal-property status for digital and electronic assets (ss.2–3), and (2) the Protected Cell Companies (Amendment) Act 2026 (Act 2026-20, published 9 July 2026 and commenced 30 July 2026 under LN 2026/294), enabling protected cell companies operating as Experienced Investor Funds to issue tokenised cell shares and maintain DLT share registers with GFSC approval. Alongside these legislative developments, Bullish Group received GFSC approval under the DLT framework to offer trading in tokenised securities.

The standing position above is expert-reviewed text (as at 24 Oct 2026). Material below dated after 24 Oct 2026 was added by a later AI monitoring cycle and is displayed as Pending expert review; it does not amend the reviewed brief.

Periodic update · new data 2026-10-25 Pending expert review

Commercial Activity

Gibraltar's digital-asset sector includes firms establishing dedicated local entities to hold Gibraltar Financial Services Commission permissions. Revolut Global Digital Assets Limited, a newly established Gibraltar entity within the wider Revolut group, holds a GFSC Part 7 permission covering transmission and execution of virtual asset orders, virtual asset custody and virtual asset staking, confirmed in a government press release as at 19 October 2026. The structure reflects a market-entry approach in which an international payments group sets up a Gibraltar-domiciled subsidiary specifically to hold a digital-asset regulatory permission, distinct from its wider group operations domiciled elsewhere.

Activity of this kind sits within Gibraltar's Financial Services Act framework, administered by the GFSC under the Part 7 DLT/VAA permission structure described in the licensing position above. The commercial substance of such an event, a new Gibraltar entity obtaining a licence, is confirmed through multiple independent press sources alongside the government's own press-release reference, giving it a reasonably well-corroborated evidentiary basis notwithstanding that no single primary-source document was independently retrieved and read in full.

Outlook

Whether further firms establish comparable dedicated Gibraltar entities to hold digital-asset permissions, and the operational scale at which Revolut's new entity begins functioning, are the items to watch.

Sources and findings (2)
  1. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Protected Cell Companies (Amendment) Act 2026 (Act 2026-20, published 9 July 2026, commenced 30 July 2026 under LN 2026/294) enables protected cell companies structured as Experienced Investor Funds to issue tokenised cell shares and operate DLT share registers with GFSC approval.retrieved M4bindingin force
  2. T1 · Government of Gibraltar (Gibraltar Laws)Government of Gibraltar (Gibraltar Laws) — Property (Digital Assets etc) Act 2026 (Act 2026-09, commenced 23 March 2026) confirms that digital and electronic things can be objects of personal property rights notwithstanding that they are neither things in possession nor things in action.retrieved M4bindingin force
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Disclosure model: module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is.

Sentinel-fed modules receive no special rendering treatment. sentinel_feed is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page.

Family taxonomy is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning.

Suppressed by doctrine: derived risk score; per-module RAG traffic light. Not shown on this page.

Band honesty: uncertainty bands are computed against a frozen build clock of 2026-10-27. A year-precision row is never promoted into a tighter band.

Orphan deltas: 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card.

Envelope: baseline resolved at jurisdiction_json.baseline; 9 module(s), 34 finding(s), 28 source(s) in the cumulative register.

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