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United KingdomLegislation gov

Gibraltar firms keep UK market access until end of 2027

The 12-month rollover preserves Gibraltar Order access to 31 December 2027 while the permanent Gibraltar Authorisation Regime is completed.

By Taxxa AI OyPublished 3 November 2026

Financial Sector & Markets Legal & Corporate

Industry: Financial and insurance activities

Gibraltar-based financial services firms keep their temporary access to the United Kingdom market for another yearLegislation. The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2026 amend regulation 12(1) of the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019Legislation so that Parts 2 and 3 of those Regulations expire at the end of 2027Legislation instead of 2026Legislation. The instrument was made on 2 November 2026Legislation, laid before Parliament on 3 November 2026Legislation, and comes into force on 16 December 2026Legislation. It extends to England and Wales, Scotland and Northern Ireland.

The extended provisions preserve the market-access arrangements that applied during common European Union membership. Before exit, access between the two jurisdictions ran through the Financial Services and Markets Act 2000 (Gibraltar) Order 2001. The 2019 Regulations kept that Order, with amendments, as the main component of the temporary regime and amended section 409 of the Financial Services and Markets Act 2000; the 2026 Regulations extend those amendments, with the rest of Parts 2 and 3, to 31 December 2027Legislation. That lets specified Gibraltar-based firms provide services in the United Kingdom, cross-border and through United Kingdom branches, and facilitates access by similar United Kingdom firms to Gibraltar's market. The 2019 Regulations have been extended by 12 months at a time ever sinceLegislation, most recently to 31 December 2026Legislation, because the power in regulation 12 permits only 12-month extensionsLegislation. Without this instrument, Gibraltar would lose the breadth and depth of its United Kingdom access when the current extension expires, forcing reliance on third-country routes with a discontinuity that would disrupt existing United Kingdom customers.

The permanent replacement is the Gibraltar Authorisation Regime established by the Financial Services Act 2021, which is being operationalised through a framework of statutory instruments. A ministerial progress statement laid alongside the instrument under the regulation 12(3) duty reports that analysis of corresponding United Kingdom and Gibraltar law is complete for insurance, insurance distribution, investment services and alternative investment fund managers. Insurance has been prioritised: over 35% of United Kingdom motor insurance contracts are written by Gibraltar-based firms, alongside around 17% of pet insurance, with Gibraltarian intermediaries processing an estimated 46% of travel insurance contracts. A Bill measure will align the Schedule 2A approval test with the outcome-based overseas-recognition approach and allow the regime to start for certain activities without that assessment, with biennial reviews once in force.

The scale of the preserved access is material in both directions. Financial Conduct Authority data for 2025 shows over 100 Gibraltar-based firms operating in the United Kingdom, including insurers, credit institutions, asset managers and e-money firms, with over 95% of Gibraltar's financial services business placed with the United Kingdom. Over 2,000 United Kingdom firms hold cross-border services passports into Gibraltar, though many may be inactive since permissions could be obtained for several jurisdictions at no extra cost, and 16 United Kingdom firms hold branch permissions there. The Government of Gibraltar determines the terms of the United Kingdom's access to the Gibraltarian market.

Businesses have to do nothing differently: the instrument preserves the status quo, so the only United Kingdom cost is familiarisation, estimated at up to 4,400 in total and well below the 10 million threshold, with no significant impact on small businesses, charities or the public sector. The instrument is not intended to be reviewed; further 12-month extensions remain available while the permanent regime is completedLegislation.

Legal basis: regulation 12(2) of the 2019 RegulationsLegislation (S.I. 2019/589), exercised by the 2026 Regulations (2026 No. 1154), substituting 2027 for 2026 in regulation 12(1)Legislation.

Diary the 31 December 2027 sunset of the temporary Gibraltar access arrangements and track the Gibraltar Authorisation Regime commencement instruments if you rely on Gibraltar-United Kingdom market access.

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