Gibraltar GOSS Licence: Marketing Is Now Licensable
Since 1 April 2026, gambling marketing provided in or from Gibraltar needs a GOSS licence. Who is caught, the exemptions, the fees and the deadline.
Contents
On 1 April 2026, Gibraltar’s Gambling Act 2025 came into operation, bringing a change that much 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 needs a Gambling Operator Support Services (GOSS) licence. If your affiliate business sits on the Rock, marketing gambling brands now requires a licence, and the six-month transition for newly caught businesses ends on 1 October 2026.
- Since 1 April 2026, providing gambling advertising or marketing services in or from Gibraltar requires a GOSS licence.
- The trigger is where the service is provided from, whatever the audience’s location.
- Independent affiliates in Gibraltar are caught. Marketing between group companies is out of scope where the recipient is a Gibraltar licence holder.
- Two carve-outs: intra-group marketing to a Gibraltar licensee, and local media advertising aimed primarily at a Gibraltar audience.
- Fees are now published: £8,000 to apply and £50,000 a year, or £25,000 a year below £200,000 of annual sales.
- Affiliates with no Gibraltar presence are unaffected, even when marketing Gibraltar-licensed brands.
What changed on 1 April 2026
Under Gibraltar’s old regime, affiliates and marketing companies were not licensed. The regulatory weight sat on the operator: licensed B2C and B2B firms answered to the Gambling Commissioner for the conduct of their marketing partners. If an affiliate ran a misleading campaign, that was the operator’s compliance problem to fix, and the affiliate itself had no direct relationship with the regulator.
The Gambling Act 2025 changes that. Section 17(1)(f) 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, except exempt advertising, and section 17(8) names the licence for it: a Gambling Operator Support Services licence. The same licence family covers holding or managing customer funds for remote gambling (other than a licensed credit institution) and Gibraltar companies owning more than 25% of an overseas gambling business that would need a licence if it were in Gibraltar.
Two phrases 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 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), rather than where the audience sits or where the promoted operator is licensed.
| Aspect | Before 1 April 2026 | From 1 April 2026 |
|---|---|---|
| Affiliate / marketing licence | None | GOSS licence required |
| Who carried the regulatory risk | The operator | The marketing provider itself |
| Territorial trigger | Not applicable | 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, or whether the brands you promote are licensed in Gibraltar or anywhere else. The activity is licensable because of where you are.
One point in the Act is easy to miss. Section 37(6) says the Authority will not license marketing services except for the marketing of a gambling business carried on by a Gibraltar licence holder. The Minister, as Licensing Authority, can still grant a wider licence at his absolute discretion if no public interest of Gibraltar would be prejudiced, and can attach conditions (section 37(8)). A Gibraltar affiliate whose partners are licensed elsewhere should expect that question to come up.
The group marketing hub
Gibraltar’s operator groups have long used a familiar arrangement: the licensed B2C entity takes the bets while a separate group marketing company handles advertising and acquisition for the group’s brands. The Act treats this more gently than early commentary suggested. Section 17(2) switches off the marketing licence requirement where the service is provided by one group member to another that is a Gibraltar licence holder, or by a licence holder to itself. And section 38(4) says a B2C or B2B operator’s licence already authorises marketing of the gambling services it covers.
So the question for a group is who the marketing company actually serves. If it markets only for Gibraltar-licensed group companies, it is likely outside the requirement. If it also markets brands licensed in Malta, Curaçao or elsewhere, or sells services to third parties, that part of its work is in scope.
The exemptions: group services and local media
Beyond the group carve-out, section 18 exempts one kind of advertising: marketing carried out for a licence holder by a business that advertises to the public at large in publications and broadcast media intended primarily for an audience in Gibraltar. A local newspaper or radio station carrying an operator’s advertisement does not need a GOSS licence.
Read that exemption for what it is: narrow. Virtually no commercial affiliate operation on the Rock exists to serve the domestic market, and the Gibraltar industry’s marketing output is aimed at the UK and international audiences almost by definition. Do not build a compliance position on the local-media exemption without a proper scope analysis.
Who this does not affect
An affiliate with no entity, office or team on the Rock does not need a GOSS licence, even when it spends all day marketing Gibraltar-licensed sportsbooks and casinos from London, Malta or São Paulo. The trigger is where the marketing business operates from; the brands it promotes are irrelevant.
What a GOSS licence costs
The fee schedule that was still missing in 2025 commentary is now law. The Gambling (Duties and Licence Fees) Regulations 2026, in effect from 1 April 2026, set these figures:
| GOSS activity | Application fee | Annual fee |
|---|---|---|
| Marketing / affiliate services in or from Gibraltar | £8,000 | £50,000 |
| Marketing services with annual sales under £200,000 | £8,000 | £25,000 |
| Holding or managing customer funds (non-bank) | £8,000 | £50,000 |
| Relevant company ownership | £8,000 | £5,000 |
Annual fees fall due on 1 April and must be paid by 30 April, and a licence granted mid-year pays from the start of that calendar quarter. The commercial maths is still uncomfortable for small players: a boutique affiliate netting £150,000 a year faces £25,000 a year plus the application fee and compliance costs, a very different decision from a marketing hub that supports nine-figure revenues.
What Gibraltar-based marketing teams should do now
The Act is in force and the transition window ends on 1 October 2026, so this is remediation work. In practice it 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 is marketing for gambling in or from Gibraltar, and whether the group or local-media exemptions genuinely apply.
- Licence application. Where the activity is in scope and staying, prepare the GOSS application: corporate and ownership documentation, a description of the marketing activity, and the compliance arrangements the Gambling Division will expect. A complete application filed before the six-month window ends keeps your transitional cover running until it is decided.
- Relocation analysis. For some businesses, particularly independent affiliates whose only tie to Gibraltar is historical, the answer may be that the activity no longer belongs there. That analysis has to weigh licence cost against substance, tax and the regulatory position of the destination; moving can also mean acquiring a different licence obligation elsewhere.
- Contract and structure clean-up. Group structures should decide which entity does the marketing, and for whom, and align intercompany agreements so the licensed or exempt entity is actually the one providing the service on paper as well as in practice.
The wider trend: the marketing layer gets its own licences
Gibraltar 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, with a PHP 1,000,000 performance deposit. What makes Gibraltar notable is its weight class: a tier-1 hub adopting a marketing licence three years after the UK’s April 2023 white paper declined to license affiliates. We track the full landscape in our affiliate licensing index.
Bottom line on Gibraltar
If your gambling marketing happens in or from Gibraltar and it is not purely intra-group marketing for a Gibraltar licensee, it now needs a GOSS licence. The questions worth paying for answers to are narrower: whether your specific structure is in scope, whether an exemption genuinely applies, whether the Authority will license marketing for operators licensed elsewhere, 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 take marketing businesses through licensing (Romania, Greece and beyond) as part of our affiliate licensing service. If the new Act caught your structure, talk to us and we will map it against the fee schedule and your budget.
This article is general information, not legal advice. The GOSS regime is new; we confirm the current position for your structure at scoping.
Frequently asked questions
What is a GOSS licence?
GOSS stands for Gambling Operator Support Services, one of the three licence families in Gibraltar's Gambling Act 2025, which came into operation on 1 April 2026. It covers businesses that support gambling rather than take bets: providing advertising or marketing services for gambling, wherever in the world the gambling takes place; holding or managing customer funds for remote gambling (other than a licensed credit institution); and certain Gibraltar holding companies of overseas gambling businesses.
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, a place of business) now needs a GOSS licence to provide gambling marketing services, whichever 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 group's marketing company is in Gibraltar. Am I caught?
It depends who it markets for. Section 17(2) of the Act takes marketing provided between members of the same group out of scope where the recipient is a Gibraltar licence holder, and a Gibraltar B2C or B2B operator's licence already covers marketing of its own gambling services. A Gibraltar marketing company that serves group brands licensed elsewhere, or third-party operators, is in scope. Start with a scope assessment before assuming either way.
How much does a GOSS licence cost?
Under the Gambling (Duties and Licence Fees) Regulations 2026, a marketing or affiliate services licence carries an £8,000 application fee and an annual fee of £50,000, reduced to £25,000 for marketing businesses with annual sales under £200,000. Holding or managing customer funds costs £8,000 to apply and £50,000 a year; relevant company ownership costs £8,000 to apply and £5,000 a year.
When did the GOSS requirement start, and is there a deadline?
The Gambling Act 2025 came into operation on 1 April 2026. Businesses that became licensable for the first time are treated as holding a transitional licence for six months from that date, to 1 October 2026. If a complete application is filed in that window, the transitional cover runs on until the application is decided; if not, it lapses when the six months end.
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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