HM Treasury has extended the post‑EU exit arrangements that allow Gibraltar‑based financial services firms to operate in the UK and vice versa. The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025 (SI 2025/1182) were made on 11 November 2025, laid before both Houses on 13 November 2025, and come into force on 16 December 2025. The change moves the expiry of the current framework to 31 December 2026.
Technically, the 2025 instrument amends regulation 12(1) of the Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019 by substituting “2026” for “2025”. Regulation 12 sets the expiry of Parts 2 and 3 at the end of 31 December of the specified year and permits HM Treasury to extend the period by 12 months on each occasion.
Parts 2 and 3 preserve UK–Gibraltar market access after Brexit by correcting the Gibraltar Order 2001 and related provisions. In practical terms, they keep in place a modified passport so that specified categories of Gibraltar‑based firms can provide services in the UK, and facilitate access by similar UK‑based firms to Gibraltar.
For process purposes, the instrument proceeds under the negative resolution procedure; the UK Parliament tracker lists an objection period ending on 8 January 2026. In addition, whenever this extension power is used, HM Treasury must publish and lay a statement describing progress towards replacement legislation.
The Explanatory Memorandum indicates no full impact assessment; a de minimis assessment is available from HM Treasury and has been published alongside the instrument on legislation.gov.uk. The Regulations extend to England, Wales, Scotland and Northern Ireland.
For regulated firms, the immediate effect is continuity through 2026. Existing permissions and branch arrangements maintained under the 2019 regime continue on the same terms, so customers should see no change triggered by this instrument alone.
This is the latest in a sequence of annual roll‑overs. Earlier statutory instruments in 2020, 2021, 2022 and 2023 extended the same expiry mechanism, and the 2024 amendment moved the date to 31 December 2025 before this year’s extension to 2026.
The longer‑term direction remains the Gibraltar Authorisation Regime provided for in the Financial Services Act 2021, intended to replace these temporary EU‑exit arrangements once fully commenced. Until that happens, the 2019 Regulations-kept in force by these one‑year extensions-continue to govern UK–Gibraltar financial services market access.