The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025, enacted by HM Treasury, exercise powers derived from earlier 2019 legislation to formally postpone the expiry date of existing transitional arrangements from 2025 to 2026 for specified categories of Gibraltar-based financial services firms operating in the UK, and vice versa.
These Regulations apply across England and Wales, Scotland, and Northern Ireland, and accompany an explanatory note confirming no significant impact assessment was required due to the minor, administrative nature of the extension.
Arguments For
The extension maintains regulatory stability for specified Gibraltar-based firms currently serving the UK market, avoiding immediate disruption to cross-jurisdictional financial service provision.
It provides additional time for ongoing negotiations or internal restructuring necessary for firms to comply fully with post-EU exit regulatory frameworks.
The action avoids imposing immediate barriers to market access for UK firms seeking to operate in Gibraltar's financial services market under the existing temporary rules.
Arguments Against
Extending transitional arrangements may delay the implementation of the final, permanent post-Brexit regulatory settlement between the UK and Gibraltar.
It can create uncertainty for firms that require long-term clarity on their operating framework, potentially hindering long-term investment decisions.
Continuing temporary measures might disincentivize the timely completion of necessary regulatory alignment or equivalence discussions between the two jurisdictions.
The Treasury make these Regulations in exercise of the power conferred by regulation 12(2) of the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019 1 .
HM Treasury created these specific legal rules by using the authority granted under regulation 12(2) of the existing Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019.
Citation, commencement and extent 1. (1) These Regulations may be cited as the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025.
(2) These Regulations come into force on the 16th December 2025.
(3) These Regulations extend to England and Wales, Scotland and Northern Ireland.
The first section identifies the official title of these legal rules as the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025.
The rules become legally effective on the 16th of December 2025.
Furthermore, the legislation applies its provisions across the entire United Kingdom: England, Wales, Scotland, and Northern Ireland.
Amendment of the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019
2.
In regulation 12 of the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019 (expiry of Parts 2 and 3) 2 , in paragraph (1), for “2025”
substitute
.“2026”
This provision specifically amends the older 2019 Regulations concerning the expiry of Parts 2 and 3, which deal with temporary access rights.
The text replaces the year "2025" with "2026" in paragraph (1) of regulation 12, effectively extending the operation of those parts by one year.
Lilian Greenwood Christian Wakeford Two Lords Commissioners of His Majesty's Treasury 11th November 2025
This signing block confirms the instrument was authorized by two Lords Commissioners of His Majesty's Treasury, Lilian Greenwood and Christian Wakeford, on the 11th of November 2025.
Explanatory Note (This note is not part of the Regulations) These Regulations are made in exercise of the power conferred by regulation 12(2) of the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019 (S.I. 2019/589). They extend by 12 months the transitional arrangements under Parts 2 and 3 of those Regulations which enable specified categories of Gibraltar-based firms to provide financial services in the United Kingdom and facilitate the access by similar types of UK-based firms to Gibraltar’s financial services market.
A full impact assessment has not been produced for these Regulations as no, or no significant, impact on the private, voluntary or public sector is foreseen. A de minimis impact assessment of the effect of these Regulations is available from HM Treasury, 1 Horse Guards Road, London, SW1A 2HQ and is published alongside these Regulations on www.legislation.gov.uk.
This note clarifies that the rules were made under the authority of the previous 2019 legislation.
Their primary purpose is to extend the temporary arrangements for Gibraltar firms operating in the UK, and for UK firms accessing Gibraltar's market, by exactly 12 months.
The government states that a full impact assessment was unnecessary because the changes are unlikely to cause significant effects on the private, voluntary, or public sectors; a minimal assessment summary is available publicly.
Related
The Renters’ Rights Act 2025 (Commencement No. 3) Regulations 2026
Commenced legal provisions enabling local housing authorities to fine landlords for unaddressed category 1 property hazards and established the definition of qualifying residential premises.
Read MoreThe Merchant Shipping (Maritime Labour Convention) (Miscellaneous Amendments) Regulations 2026
Amended maritime labour regulations to expand ship security documentation requirements and mandate seafarer rights disclosures by recruitment agencies.
Read MoreCorrection Slip
A typographical error in the first signature block on page 24 of The Vaping Products (Production, Duty Stamps and Commencement) Regulations 2026 was officially corrected, changing 'Justin Holiday' to 'Justin Holliday'.
Read MoreThe Diocese of Salisbury (Educational Endowments) (Shaw Church of England Primary School Teacher’s House) Order 2026
The Secretary of State appointed the Salisbury Diocesan Board of Education as trustee for the endowment funds of the former Shaw Church of England Primary School Teacher's House and ordered that these assets be consolidated with existing diocesan educational endowments under uniform statutory trusts.
Read More