Gibraltar Corporate & Compliance Services for Fintech & Payments Businesses

Resilience Group supports fintech companies, payment institutions and e-money businesses with company administration, regulatory compliance and accounting services in Gibraltar. We help regulated firms establish genuine operational substance in Gibraltar, manage their GFSC authorisation obligations and maintain the governance standards required to retain UK market access under the Gibraltar Authorisation Regime.

Why Fintech & Payments Businesses Choose Gibraltar

Unique UK Market Access via the GAR

Gibraltar is the only jurisdiction in the world — including EU member states, Crown Dependencies and Overseas Territories — from which financial services firms can access the UK market as authorised persons without requiring full UK FCA authorisation. The Gibraltar Authorisation Regime (GAR), embedded in the UK Financial Services Act 2021 and mirrored in Gibraltar's Financial Services Act 2019 (as amended in January 2025), provides Gibraltar-based payment institutions, e-money institutions, banks and investment firms with a structured pathway to conduct UK regulated activities. Over 90% of Gibraltar's financial services business is directed at the UK market.

GAR Alignment Requirements

The GAR requires that Gibraltar's regulatory law and practice remain sufficiently aligned with the UK's — not just in text, but in practical effect and supervisory standards. The GFSC and FCA maintain close cooperation and formal information-sharing protocols. For fintech firms, this means that the GFSC's expectations around governance, AML/CTF, safeguarding and Consumer Duty are materially equivalent to FCA standards. Firms cannot treat Gibraltar as a lighter-touch alternative to UK authorisation.

Proportionate, Accessible Regulation

The GFSC is a proportionate regulator that engages substantively with applicants at the pre-application stage. For fintech businesses with innovative or complex business models, the ability to hold structured pre-application meetings with senior GFSC staff — and receive meaningful feedback before committing to a full application — is a material advantage over the FCA's more process-heavy approach.

Competitive Cost Base

Gibraltar's 15% territorial corporation tax, absence of VAT and absence of employer social security contributions at UK levels give fintech businesses operating in Gibraltar a competitive cost base compared to London or Dublin. Combined with the UK market access privilege, Gibraltar represents a compelling operational location for fintech businesses targeting the UK and beyond.

What We Do for Fintech & Payments Businesses

Company Establishment & Administration

Resilience Group handles the full lifecycle of Gibraltar company administration for fintech businesses — incorporation, registered office, company secretarial services, statutory filings and board governance support. We ensure the mind-and-management substance that both the GFSC and the GAR framework require is demonstrably present in Gibraltar from day one.

GFSC Authorisation Support

We assist payment institutions and e-money institutions with GFSC Part 7 permission applications, including the preparation of business plans, financial projections, governance frameworks, risk management policies and AML/CTF documentation. We advise on the complexity assessment process and manage the application timeline, including pre-application engagement with the GFSC.

Ongoing Regulatory Compliance

Post-authorisation, fintech businesses face continuous compliance obligations — regulatory capital monitoring, safeguarding audits, AML/CTF reviews, GFSC reporting and UK market access notification obligations. Resilience Group provides ongoing compliance support, including MLRO and compliance officer functions, ensuring firms maintain their GFSC authorisation and GAR permissions without diverting management bandwidth from product and growth.

Accounting & Financial Reporting

We prepare statutory accounts, management accounts and GFSC regulatory returns for Gibraltar fintech entities, coordinating with external auditors and ensuring timely submission of all required filings. For businesses that also have UK branches or entities, we coordinate across jurisdictions to ensure a consistent and accurate financial picture.

The Gibraltar Authorisation Regime & UK Market Access

The GAR is the permanent legal framework governing how Gibraltar-based financial services firms access the UK market. It was embedded in UK law by the Financial Services Act 2021 (Chapter 22) and in Gibraltar law by amendments to the Financial Services Act 2019 that took effect in January 2025. The transitional passporting arrangements that have maintained market access since Brexit have been extended to 31 December 2026, with the expectation of a further extension as the permanent GAR framework becomes fully operational.

For a Gibraltar firm to carry on an approved UK regulated activity under the GAR, it must already hold GFSC permission for the corresponding Gibraltar activity. HM Treasury designates approved activities and matching corresponding activities; a firm must maintain continuous compliance with both Gibraltar and UK regulatory standards to retain market access permission.

Critically, the FCA retains its own-initiative intervention powers even where the GFSC is the home regulator. Firms must understand and proactively meet FCA standards — particularly around AML/CTF, safeguarding, financial promotions and Consumer Duty — and cannot treat GFSC supervision as a proxy for FCA compliance. Resilience Group's compliance team is experienced in managing this dual-regulatory environment.

Frequently asked questions

• Is the Gibraltar Authorisation Regime operational now?

  The GAR framework is embedded in both UK and Gibraltar law. The transitional passporting arrangements have been extended to 31 December 2026 to allow the permanent GAR framework to become fully operational. New firms establishing in Gibraltar with a view to UK market access should engage with the GFSC and structure their applications with the permanent GAR requirements in mind.

• Does a Gibraltar payment institution need a UK entity to serve UK customers?

  No. Under the GAR, a Gibraltar-licensed payment institution can carry on UK regulated activities either on a cross-border services basis or through a UK branch, without establishing a separate UK-incorporated entity. This is a unique structural advantage not available to firms authorised in any other third country or overseas territory.

• What safeguarding requirements apply to Gibraltar payment institutions?

  Gibraltar payment institutions must safeguard relevant funds received from payment service users in accordance with Gibraltar's Payment Services Regulations, which align closely with the UK Payment Services Regulations 2017. Safeguarded funds must be held in designated accounts with approved credit institutions or invested in approved low-risk assets. We assist clients with safeguarding policy design and the GFSC's annual safeguarding audit requirements.

• What is the regulatory capital requirement for a Gibraltar EMI?

  Initial capital requirements for Gibraltar e-money institutions are set under Gibraltar's e-money regulations and are based on the type of activities carried on. Ongoing capital requirements are calculated based on outstanding e-money liability or average monthly payment volume, subject to a minimum floor. We assist clients in calculating and monitoring their regulatory capital position on an ongoing basis.

• Can a Gibraltar fintech business be managed remotely?

  Only to a limited extent. The GFSC requires regulated firms to have genuine operational substance in Gibraltar — the mind and management of the business, including decision-making by senior approved persons, must be demonstrably present in Gibraltar. Remote working arrangements and outsourcing are permissible within limits, but the overall governance of the firm must be centred in Gibraltar.

• What Consumer Duty obligations apply to Gibraltar firms serving UK retail customers?

  The FCA's Consumer Duty applies to UK-regulated activities, including those carried on by Gibraltar firms under the GAR. Firms accessing the UK retail market must ensure their products and services deliver good outcomes for retail customers across the four outcome areas — products and services, price and value, consumer understanding and consumer support. The GFSC expects firms to meet these standards as part of the GAR alignment requirement.