UK delays Gibraltar finance rule expiry to 2026
HM Treasury has extended the temporary UK–Gibraltar market access rules for financial services by one year, moving the expiry from the end of 2025 to the end of 2026. The change comes via the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025, which keep the current set‑up in place while a permanent regime is readied.
Dates to pin: the instrument was made on 11 November 2025, laid before Parliament on 13 November 2025, and takes effect on 16 December 2025. It applies across England and Wales, Scotland and Northern Ireland. Keep those dates in your notes; they often come up in exam questions and policy briefings.
Quick recap: the ‘transitional arrangements’ live in the 2019 regulations and let specified Gibraltar‑based firms continue serving UK customers, with similar access for UK firms into Gibraltar. In the 2019 instrument, as published on legislation.gov.uk, regulation 12 set an end‑date but also gave the Treasury power to extend in 12‑month steps; in 2024 the date shown in law was updated to 31 December 2025.
Here’s the legal move in plain English: by changing one line in regulation 12(1) - replacing “2025” with “2026” - the Treasury keeps Parts 2 and 3 alive for another year. Tiny text change; big practical effect for firms and customers who would otherwise face a cliff‑edge.
What this means for you: no sudden switch‑off this winter. Firms relying on UK–Gibraltar access can carry on while new, longer‑term rules are finalised. The Explanatory Note says no full impact assessment was needed beyond a de minimis check, signalling continuity rather than a policy shift.
Who is covered in practice: only specified categories of firms. If you work in compliance or you’re studying this, start with the Financial Conduct Authority’s page on passporting between the UK and Gibraltar, which explains how notifications work and notes that the date can be extended.
Why timing matters: in June 2025 the UK, EU, Spain and Gibraltar announced they’d agreed the core elements of a future treaty on border and cooperation issues. Keeping today’s financial access steady gives institutions and learners a clear timeline while that treaty text is finalised.
What sits in the background is the Gibraltar Authorisation Regime - the long‑term model to replace these stop‑gap rules. Parliament has already brought the necessary powers into force, and earlier FCA guidance said the 2025 end‑date might be extended. This year’s instrument does exactly that.
Study tip to finish: always log three dates for a statutory instrument - made, laid and in force - and note who signs it. Here, two Lords Commissioners of His Majesty’s Treasury, Lilian Greenwood and Christian Wakeford, signed on 11 November 2025; it was laid on 13 November and starts on 16 December.