Gibraltar GOSS Licence: Marketing Is Now Licensable
Since 1 October 2025, providing gambling marketing services in or from Gibraltar needs a GOSS licence. Who is caught, the exemption, fees and next steps.
Contents
On 1 October 2025, Gibraltar’s new Gambling Act came into force — and with it, a change that most of the affiliate industry hasn’t fully priced in yet. Conducting, managing, arranging, booking, facilitating or providing advertising or marketing services for gambling, wherever in the world the gambling takes place, in or from Gibraltar is now a regulated activity. It requires a Gaming Operator Support Services (GOSS) licence. If your affiliate business or your group’s marketing company sits on the Rock, marketing gambling brands is no longer just something you do — it’s something you must be licensed to do.
What changed on 1 October 2025
Under Gibraltar’s old regime, affiliates and marketing companies were simply not licensed. The regulatory weight sat entirely on the operator: licensed B2C and B2B firms answered to the Gambling Commissioner for the conduct of their marketing partners through the Codes of Practice. If an affiliate ran a misleading campaign, that was the operator’s compliance problem to fix — the affiliate itself had no direct relationship with the regulator.
The new Gambling Act inverts that. The statutory language is deliberately wide: “conducting, managing, arranging, booking, facilitating or providing advertising or marketing services for gambling, wherever in the world the gambling takes place,” in or from Gibraltar is a regulated activity — and carrying it on requires a GOSS licence.
Two phrases in that sentence deserve a second read:
- “Wherever in the world the gambling takes place.” The activity is caught regardless of the target market. Marketing a Curaçao-licensed casino to Brazilian players from a Gibraltar office is just as much in scope as marketing a Gibraltar sportsbook to UK players.
- “In or from Gibraltar.” The territorial hook is where the marketing service is provided from — the office, the entity, the team — not where the audience sits or where the promoted operator is licensed.
| Before 1 October 2025 | From 1 October 2025 | |
|---|---|---|
| Affiliate / marketing licence | None | GOSS licence required |
| Who carried the regulatory risk | The operator, via Codes of Practice | The marketing provider itself |
| Territorial trigger | — | Services provided in or from Gibraltar |
Who is caught
Marketing affiliates operating in or from Gibraltar
If you run an affiliate business — comparison sites, review portals, media buying, player acquisition — through a Gibraltar company or a Gibraltar-based team, you are now providing a regulated marketing service. It makes no difference that your traffic is British, German or Brazilian, and no difference whether the brands you promote are licensed in Gibraltar or anywhere else. The activity is licensable because of where you are.
The group marketing hub
This is the structure the provision was clearly written with in mind. Gibraltar’s operator groups have long used a familiar arrangement: the licensed B2C entity takes the bets, while a separate group marketing company — often in the same building — handles advertising and acquisition for the group’s brands worldwide. Under the old regime that marketing entity needed no licence of its own. Under the new Act, it is squarely providing “marketing services for gambling… from Gibraltar” and needs its own GOSS licence, separate from the group’s operating licences. If your group runs this structure, the marketing company is now a regulated entity in its own right, with its own application, its own fees and its own compliance obligations.
The exemption: marketing aimed at Gibraltar itself
The Act carves out one situation: marketing aimed primarily at a Gibraltar audience. A local media company promoting the local casino to residents doesn’t need a GOSS licence.
Read that exemption for what it is — narrow. Gibraltar has around 34,000 residents; virtually no commercial affiliate operation on the Rock exists to serve the domestic market. The Gibraltar gambling industry’s marketing output is aimed at the UK and international audiences almost by definition, which is precisely the activity the licence now covers. Do not build a compliance position on this exemption without a proper scope analysis of where your campaigns actually point.
Who this does not affect
Just as important is who falls outside the net.
Those affiliates remain in the familiar position: unlicensed themselves, with compliance duties flowing through their operator contracts. Whether some other jurisdiction licenses them is a separate question — our country-by-country pillar on whether gambling affiliates need a licence maps exactly that.
What a GOSS licence costs — treat the number with care
Industry reporting and law-firm commentary have put the annual GOSS licence fee at around £50,000 per year. We deliberately hedge that figure: as Hassans noted in its July 2025 analysis, the final fee schedule had not been published at that point, and the ~£50,000 figure is expected rather than confirmed. Before you budget, restructure or file, confirm the current fees directly against the Gibraltar Gambling Division’s published schedule. If the reported level holds, the commercial maths is straightforward and uncomfortable: a boutique affiliate netting £200,000 a year faces a very different decision than an operator group whose Gibraltar marketing hub supports nine-figure revenues.
What Gibraltar-based marketing teams should do now
The Act is in force, so this is remediation, not horizon-scanning. In practice the work falls into four steps:
- Scope assessment. Map every entity and team in Gibraltar that touches gambling marketing — affiliate businesses, group marketing companies, shared-services teams whose remit includes acquisition. For each, establish whether its activity amounts to providing advertising or marketing services for gambling in or from Gibraltar, and whether the Gibraltar-audience exemption could genuinely apply.
- Licence application. Where the activity is in scope and staying, prepare the GOSS application: corporate and ownership documentation, description of the marketing activity, and the compliance arrangements the Gambling Division will expect from a newly regulated entity.
- Relocation analysis. For some businesses — particularly independent affiliates whose only tie to Gibraltar is historical — the honest answer may be that the activity no longer belongs there at the reported fee level. That analysis has to weigh licence cost against substance, tax and the regulatory position of any destination jurisdiction; moving the problem can also mean acquiring a different licence obligation elsewhere.
- Contract and structure clean-up. Group structures should decide which entity holds the GOSS licence and align intercompany marketing agreements accordingly, so that the licensed entity is actually the one providing the regulated service on paper as well as in practice.
The wider trend: the marketing layer gets its own licences
Gibraltar is not acting alone — it has joined a short but growing list of jurisdictions that formally license gambling’s marketing layer rather than policing it only through operators. Romania runs the fullest regime: the ONJN Class 2 licence at roughly €35,000 per year all-in, valid for ten years. Greece requires an HGC Affiliate Suitability Licence and entry in a public register of affiliates, with a €1,000 deposit. The Philippines brought marketing and promotional service providers into PAGCOR accreditation from 2 October 2025 — the day after Gibraltar’s Act — with a PHP 1,000,000 performance deposit. What makes Gibraltar notable is its weight class: this is a tier-1 hub adopting a marketing licence just two years after the UK’s April 2023 white paper expressly declined to license affiliates. We track the full landscape, jurisdiction by jurisdiction, in our affiliate licensing index.
Bottom line
If your gambling marketing activity happens in or from Gibraltar, it is now licensable — full stop. The questions worth paying for answers to are narrower: whether your specific structure is in scope, whether the Gibraltar-audience exemption genuinely applies, what the fee schedule actually says by the time you file, and whether licensing or relocating is the better commercial answer.
That scoping is what we do. Vantegris runs GOSS scope assessments for Gibraltar-based affiliates and group marketing companies, prepares licence applications, and models the relocation alternative against other regimes where we license marketing businesses — Romania, Greece and beyond — as part of our affiliate licensing service. If the 1 October change caught your structure, talk to us before the fee schedule catches your budget.
This article is general information, not legal advice. The GOSS regime is new and its fee schedule was unpublished at the time of the sources we rely on — we confirm the current position for your structure at scoping.
Frequently asked questions
What is a GOSS licence?
GOSS stands for Gaming Operator Support Services — a licence category created by Gibraltar's new Gambling Act, in effect since 1 October 2025. It covers businesses that support gambling operators rather than take bets themselves. Critically, the Act makes conducting, managing, arranging, booking, facilitating or providing advertising or marketing services for gambling, wherever in the world the gambling takes place, a regulated activity when carried out in or from Gibraltar — so a marketing business needs a GOSS licence.
Do gambling affiliates need a GOSS licence?
Only if they operate in or from Gibraltar. A marketing affiliate based in Gibraltar — a company, a team, an established place of business — now needs a GOSS licence to provide gambling marketing services, regardless of which country the audience is in. An affiliate with no Gibraltar presence does not need one, even when it promotes Gibraltar-licensed brands from elsewhere.
My marketing company is based in Gibraltar — am I caught?
Almost certainly, yes. The provision catches both independent marketing affiliates and group marketing companies — the classic structure where an operator group runs its global advertising through a Gibraltar marketing entity. The only carve-out is marketing aimed primarily at a Gibraltar audience, which is a narrow exemption in practice. Start with a scope assessment before assuming either way.
How much does a GOSS licence cost?
The annual fee has been reported at around £50,000, but that figure was not confirmed — final fees were still unpublished as of July 2025, per Hassans. Treat £50,000 as a planning assumption only and confirm the current fee schedule with the Gibraltar Gambling Division before budgeting or filing.
When did the GOSS requirement start?
The new Gibraltar Gambling Act came into effect on 1 October 2025. From that date, providing advertising or marketing services for gambling in or from Gibraltar is a regulated activity requiring a GOSS licence. Under the old regime, affiliates were unlicensed and marketing standards were enforced against operators through the Gambling Commissioner's Codes of Practice.
Sources
This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.
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