HM Treasury has made the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025 (S.I. 2025/1182), extending the UK–Gibraltar transitional market access regime by 12 months. The instrument was made on 11 November 2025, laid before Parliament on 13 November, and comes into force on 16 December 2025. It applies across England and Wales, Scotland and Northern Ireland, and is signed by two Lords Commissioners of His Majesty’s Treasury, Lilian Greenwood and Christian Wakeford.
Legally, the amendment is confined to regulation 12(1) of the 2019 Gibraltar EU Exit Regulations, replacing the expiry year so that Parts 2 and 3 remain in force until 31 December 2026. Regulation 12 already provides for successive 12‑month extensions by statutory instrument, which HM Treasury has used each year since 2020.
Parts 2 and 3 maintain access for specified categories of Gibraltar‑based firms to provide financial services in the UK and facilitate reciprocal access for similar UK‑based firms to Gibraltar. The Explanatory Note again indicates no, or no significant, impact and points to a de minimis assessment published alongside the instrument on legislation.gov.uk.
Policy intent remains consistent: preserve continuity until the permanent Gibraltar Authorisation Regime (GAR) is commenced. HM Treasury consulted on GAR’s design in 2020 and the regime was legislated for in the Financial Services Act 2021, which envisages access based on regulatory alignment and supervisory cooperation between the UK and Gibraltar.
For regulated firms already operating under the route, the extension averts a year‑end permissions cliff‑edge. Cross‑border business can continue under current approvals while authorisation plans are refined in anticipation of GAR commencement.
The 2025 instrument does not widen scope or introduce new obligations; it simply rolls forward the expiry date. Compliance manuals, customer disclosures and internal calendars that reference a 2025 end‑date should be updated to reflect the new 2026 sunset.
Regulators are expected to refresh public guidance to reflect the new date. The Financial Conduct Authority’s page on UK–Gibraltar passporting, last updated on 10 January 2025, still notes 31 December 2025 as the end of the transitional period; S.I. 2025/1182 supersedes that position.
Under regulation 12(3) of the 2019 Regulations, any extension must be accompanied by a Treasury statement to Parliament on progress toward replacement legislation. That statement will be a key signal for the sequencing and scope of GAR‑approved activities to follow.