Gibraltar insurers are authorised by the Gibraltar Financial Services Commission (GFSC) under a Solvency II-based regime, and most write UK risk through the UK–Gibraltar market access arrangements. For funds, the Experienced Investor Fund lets you launch first and notify the GFSC shortly afterwards. Private Funds with up to 50 investors sit largely outside fund regulation, though the 2025 reforms added administrator and custody requirements.
At a glance
| Item | Position as of October 2026 |
|---|---|
| Regulator | Gibraltar Financial Services Commission (GFSC) |
| Insurance capital rules | Solvency II-based, in force in Gibraltar since 1 January 2016 |
| Main insurance market | UK, especially motor; reportedly more than 35% of UK motor premiums |
| UK access | Transitional arrangements until 31 December 2026, pending the Gibraltar Authorisation Regime |
| EIF investor test | €100,000 invested, or certified high net worth or sophisticated status |
| Private Fund limit | No more than 50 investors, not listed |
| EU passport | None, and the 2026 treaty does not restore it |
Why do insurers choose Gibraltar?
Gibraltar’s insurance sector grew on access to the UK market. The GFSC must match UK regulatory standards, and around 90% of premiums written in Gibraltar relate to UK risks, according to one audit firm. An ISOLAS partner’s 2026 chapter cites industry estimates that Gibraltar insurers underwrite more than 35% of UK motor premiums, with total gross written premiums above £7 billion.
Typical structures include:
- open-market insurers, mainly UK motor, household and specialty lines
- captives that insure risks of their own group
- protected cell companies (PCCs), where sponsors rent a cell with ring-fenced assets and liabilities
- insurance managers and intermediaries that serve those carriers
Since 2017 the government has allowed PCC cells to be considered for third-party business, not just captive-type risks. The GFSC decides each case on its merits, and the cell’s assets and reinsurance programme are central to its decision. No fixed capital figure is published for a cell; you agree it with the GFSC under the Solvency II-based rules.
How do you get an insurance licence in Gibraltar?
Insurers need Part 7 permission from the GFSC under the Financial Services Act 2019. The process is staged and thorough. Expect the following.
1. Pre-application meetings
Present your business plan, lines of business, target markets and reinsurance programme to the GFSC early. Show how you will serve the UK, since that is the reason most insurers apply.
2. Capital and solvency modelling
Prepare a Solvency II-style assessment of your solvency capital requirement and minimum capital requirement, an Own Risk and Solvency Assessment, and the capital plan your owners will fund. Since 30 June 2023 the absolute floors for the minimum capital requirement have been €2.7 million for non-life (€4 million if you write liability, credit or suretyship classes), €4 million for life, €3.9 million for reinsurers and €1.3 million for captive reinsurers.
3. Governance and people
You will need a Gibraltar company with a local board, the key functions covered (actuarial, risk, compliance, internal audit) and approval of individuals in controlled roles. For 2025/26 the regulated individual application fee was £1,575. Many start-ups appoint a licensed insurance manager. Our guide to setting up a company in Gibraltar covers incorporation.
4. Assessment and authorisation
The GFSC reviews the application, asks questions and may attach conditions. If you will write UK business, factor in notification to the UK regulators under the market access arrangements. One Gibraltar insurance manager quotes about 9–12 months for an insurer or PCC, 3–6 months for a new cell and around 3 months for a captive, counted from a complete application.
How much does insurance authorisation cost?
The GFSC’s 2025/26 fees for open-market life and non-life insurers were:
| Fee | 2025/26 amount |
|---|---|
| Application fee | £75,000 |
| Annual base fee | £32,000 |
| Gross premium income fee, £100m to £249.99m | £222 per £1m |
| Gross premium income fee, £250m and above | £190 per £1m |
| Gross technical liabilities fee, £100m to £249.99m | £45 per £1m |
| Gross technical liabilities fee, £250m and above | £30 per £1m |
| AML supervision fee (life insurers) | £3,900 |
From 1 April 2026 the annual base fee for open-market insurers rose to £32,960 and the life-insurer AML supervision fee to £4,017; the application fee is unchanged. Under the Financial Services (Fees) Regulations 2020, other insurance fees are:
- captive insurers: £10,500 to apply, then a £9,192 annual base fee plus £2,625 a year per cell
- new PCC cells: £4,000, £15,000 or £45,000 for an open-market cell, or £3,500, £11,000 or £40,000 for a captive cell, depending on complexity
- insurance managers: £21,000 to apply, then a £9,192 annual base fee plus a charge for each insurer managed
- insurance intermediaries: £30,000 to apply since 3 September 2026, then a £7,222 annual base fee plus turnover-based fees
Insurers pay Gibraltar corporate tax at the standard 15%. Your largest costs will be capital, reinsurance, people and outsourced functions. These depend on your lines of business, size and outsourcing model, so ask a Gibraltar insurance manager to cost your business plan.
What fund structures does Gibraltar offer?
| Feature | Experienced Investor Fund (EIF) | Private Fund |
|---|---|---|
| GFSC status | Regulated fund | Not authorised as a fund by the GFSC |
| Investors | Experienced investors only | No more than 50, by private arrangement |
| Launch | On a Gibraltar legal opinion, then file with the GFSC | No fund authorisation |
| Listing | Not addressed by the EIF rules; ask counsel | Not permitted |
| Asset rules | No restrictions on asset class and no diversification rules | Set by the offering terms |
| Typical use | Hedge, private equity, real estate and digital-asset funds | Family, club and small co-investment vehicles |
Gibraltar also allows UCITS schemes, and funds can be set up as companies, limited partnerships or PCCs. A UCITS scheme no longer carries an EU marketing passport after Brexit. The regime is still on the statute book and in the GFSC fee schedule, but whether a Gibraltar UCITS suits your target investors is a question for a Gibraltar funds lawyer.
How do you launch an Experienced Investor Fund?
The EIF is Gibraltar’s flagship fund product because it can launch without prior approval.
- Structure the fund. Choose a company, PCC cell or limited partnership and prepare the offering document and constitution.
- Appoint the service providers. You need a fund administrator licensed in Gibraltar or approved for EIFs, a Gibraltar auditor, and at least two GFSC-approved directors, one of them resident in Gibraltar.
- Obtain the legal opinion. Gibraltar counsel confirms that the fund meets the EIF regulations.
- Launch. You can begin taking subscriptions.
- Notify the GFSC. The administrator files the offering document, constitutional documents, legal opinion, administrator’s form and fee within 10 working days of launch (or up to 10 working days before it). If the GFSC raises no objection within 10 working days of receiving them, the fund is treated as authorised.
- Ongoing reporting. Submit audited financial statements and a regulatory return each year.
The May 2025 amendments (LN.2025/099) redefined the experienced investor. Broadly, an investor qualifies by investing or holding at least €100,000 across EIFs, or by being a certified high net worth investor, a certified or self-certified sophisticated investor, or investing on solicited advice. Companies and partnerships qualify where their members do. The amendment replaced only this limb. The other routes still apply, including investment professionals, companies or trusts with more than €1 million in net assets, individuals worth more than €1 million, professional clients, and investors putting in at least €50,000 on professional advice.
Managers may need their own authorisation or registration. See our guide to family offices if the fund will sit within a family structure.
How do Private Funds work after the 2025 reforms?
A Private Fund is limited to 50 investors, cannot be listed and is not authorised by the GFSC as a fund. The May 2025 AIFM amendments (LN.2025/098) tightened the framework around these funds:
- the private placement limit is now no more than 50 persons, in Gibraltar or elsewhere
- small AIFMs must register with the GFSC before marketing to professional investors in Gibraltar, and report their main exposures
- self-managed small funds must appoint a local fund administrator with Part 7 permission, unless the GFSC grants an exemption
- the same funds need separate safe-custody arrangements for their assets
- existing managers had 12 months from the appointed day to comply
LN.2025/098 came into operation on 8 May 2025, so the 12-month compliance window for existing managers closed around 8 May 2026.
Can Gibraltar insurers and funds access the UK and EU?
UK. Gibraltar firms in insurance, banking, investment, e-money and payments access the UK under transitional arrangements. The FCA says these run until 31 December 2026, after an extension in December 2025. They are due to be replaced by the Gibraltar Authorisation Regime (GAR) under the UK Financial Services Act 2021. In June 2026 Gibraltar’s minister told Parliament the GAR was about 18 months away, and that UK amendments should remove the sector-by-sector assessments that had caused delays. Some older adviser pages say the transition ended in 2025, but the FCA’s current page gives 31 December 2026. As of late October 2026 no further extension had been announced: the FCA and the Bank of England still give 31 December 2026, and the Bank of England notes the date can be extended again until the GAR is in place. Check the FCA page before relying on access after that date.
EU. Gibraltar firms have no EU passport. Insurers that want EU business need an EU-authorised carrier or fronting arrangement. Fund managers market to EU investors under national private placement rules.
What changed with the 2026 UK–EU treaty?
For insurance and funds regulation, very little. The UK–EU treaty, applied provisionally since 15 July 2026, does not restore EU passporting or bring Gibraltar into the EU single market for financial services. The EIF and Private Fund regimes are unchanged. UK market access sits outside the treaty and continues under the arrangements above.
The practical gains are mobility and certainty. The border fence has gone, Schengen checks move to the port and airport, and Gibraltar residents are not subject to the EU Entry/Exit System or the 90-day Schengen limit that applies to UK nationals. That makes it easier for executives and staff to live in Spain and work in Gibraltar. Read more in the UK–EU treaty explained for business or return to the licensed sectors hub.