HM Treasury has extended the UK–Gibraltar transitional market‑access regime by 12 months. The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025 (SI 2025/1182) amend regulation 12(1) of the 2019 Gibraltar Regulations so that Parts 2 and 3 now expire on 31 December 2026 rather than 2025. The instrument was made on 11 November, laid on 13 November, and comes into force on 16 December 2025, according to legislation.gov.uk.
Parts 2 and 3 of the 2019 Regulations preserve mutual market access arrangements for specified categories of Gibraltar‑based firms into the United Kingdom and facilitate reciprocal access for similar UK firms into Gibraltar. They operate by amending section 409 of the Financial Services and Markets Act 2000 and the Financial Services and Markets Act 2000 (Gibraltar) Order 2001, with associated changes to the EEA Passport Rights (EU Exit) Regulations. The 2025 instrument does not alter scope or conditions; it only changes the sunset date.
The extension maintains continuity while the longer‑term Gibraltar Authorisation Regime progresses. That regime, created by the Financial Services Act 2021, introduces “approved activities” and Schedule 2A permissions for Gibraltar‑based firms, subject to alignment tests and regulatory cooperation. Until that framework is fully commenced and populated by secondary legislation, the existing transitional access remains the operative route.
For firms, this means current cross‑border permissions under the transitional arrangements continue without additional applications or immediate system changes. Banking, insurance and investment businesses already relying on the Gibraltar access provisions may keep serving UK customers, and comparable UK firms can continue Gibraltar operations under the same temporary basis. Consumer contracts and ongoing service lines are unaffected by the date change alone.
Regulation 12 requires the Treasury to publish and lay a statement describing progress toward permanent legislation each time an extension is made. Policy and compliance teams should look for that statement alongside the instrument and factor it into forward planning for the eventual migration to the Gibraltar Authorisation Regime.
The 2019 Regulations envisaged annual extensions in 12‑month increments where needed. They have been rolled forward each year since 2020, with the most recent prior amendment in 2024 carrying the expiry to 31 December 2025. The 2025 instrument pushes the expiry to the end of 2026, continuing that pattern while longer‑term arrangements are readied.
Key dates for diaries are straightforward: made on 11 November 2025; laid before Parliament on 13 November 2025; and commencement on 16 December 2025. The practical effect for firms is the extension of the transitional market‑access window through to 31 December 2026, avoiding a year‑end cliff‑edge. These timings are recorded on legislation.gov.uk.
The instrument records that it was signed on behalf of HM Treasury by two Lords Commissioners. No impact assessment has been produced, consistent with prior extensions which were assessed as having no, or no significant, effect on the private, voluntary or public sectors; a de minimis assessment is published alongside on legislation.gov.uk. Market participants should continue preparing for the permanent regime while relying on the extended transitional access.