The Government of Gibraltar has published the new residency criteria designed to ensure that applicants demonstrate a genuine economic connection to the jurisdiction, while safeguarding public resources and promoting sustainable growth.

1. Core Eligibility Requirements
Individuals applying for a residence permit must satisfy the following criteria:

• Employment: Applicants must hold a valid employment contract with a Gibraltar-based business, which has been trading for at least a year and is properly established, registered, licensed, and compliant with its regulatory and tax obligations.
• Minimum Earnings: The contract must generally reflect earnings aligned with the average gross annual salary in Gibraltar (currently indicated at approximately £37,500, subject to annual updates).
• Minimum Salary Waiver: If the applicant is below 30 years of age, the requirement to have a minimum annual salary aligned with the average gross annual salary of Gibraltar (£37,500 subject to annual updates) may be waived if the employer pays the tax and social insurance contributions as if the employee’s salary were the gross annual earnings in Gibraltar as per the Employment Survey of that year.
• Accommodation: Applicants must evidence suitable accommodation in Gibraltar, either through ownership or a long-term rental (minimum 12 months), which must serve as their primary residence. If the primary residence/property is purchased, it cannot be let during the duration of the residence permit and must be legitimately available for the applicant’s exclusive use during that period.
• Age Requirement: Applicants are generally required to be aged 55 or under, subject to limited discretion.
• Vetting: A formal vetting process from the applicant’s country of origin is required.

2. Additional Requirements for Businesses operating for less than a year or self-employed Individuals

Where an applicant is connected to a newer business or is self-employed, the following requirements will apply:

• An advanced payment will be required equivalent to the following:
a. Total employee and employer social insurance contributions for the first year of employment; and
b. The total tax payable on the equivalent of the average gross annual earnings in Gibraltar, taxable at 25%.

3. Business Registration Requirements

• For a business to obtain registration under the Business, Trades and Professions (Registration) Act and licensed under the Fair-Trading Act, the CEO of the Department of Business may have regard to factors which may include:

o The creation of full time or part time employment in Gibraltar;
o The provision of in-demand skills required in the jurisdiction;
o The rental of suitable office or commercial space in Gibraltar;
o A positive tax filing history; and
o The future generation of economic activity in Gibraltar.

4. Anti-Avoidance and Monitoring Measures

The proposed regime includes the following safeguarding measures:

• Employment terms will be monitored to ensure that salary levels are not reduced after a permit is granted without reasonable justification.
• Authorities will verify that employers remain compliant with all financial and regulatory obligations.

5. Renewal and Ongoing Conditions

Residence permits are not indefinite and are subject to continued compliance:

• Permits will be renewable annually, requiring confirmation that all eligibility criteria continue to be met.
• A permit may lapse automatically 8 weeks after the filing of a Notice of Termination of Terms of Engagement, unless a new employment contract has been filed.
• If payments of tax or social insurance are stopped, unless the employee can produce evidence that payments have been deducted from their salary but not paid by the employer, their residence permit will automatically lapse.

6. Benefits of Residence

Gibraltar residence provides limited but important entitlements:

• Healthcare

• Schooling in Gibraltar for any children under the age of 18, unless in full time education

• A scholarship for any dependent child after 10 years of continuous lawful residence and uninterrupted payment of tax and social insurance

7. Restrictions on Social Benefits

Residents will not generally be entitled to:

• Public housing or affordable housing
• Elderly residential care or domiciliary care
• Berths in the Small Boats Marina (or any other Government Berthing Scheme)
• Other wider social benefits

Only residents who are British Citizens and have a period of 20 years of residence will then be able to apply for Gibraltarian Status and access all services.

8. Partners of Individuals

Unmarried partners of an individual with Gibraltarian Status shall be permitted to reside in Gibraltar where evidence is provided of a relationship of a minimum period of 2 years.

Additionally, any individual who is applying for residence in Gibraltar wishes for their spouse to reside with them shall pay an amount equivalent to the maximum employee’s social insurance contributions to the Government of Gibraltar on behalf of their spouse.

Individuals applying for residence may only be accompanied by their spouse and/or children.

9. Transitional Provisions

• Individuals already resident in Gibraltar prior to 6 October 2025 will remain subject to the current regime.
• The new criteria will primarily affect new applicants.

10. Fines

Individuals residing in Gibraltar without a Permit of Residence may be imposed a fine of up to £2,500.

11. Category 2 Status and High Executive Possessing Specialist Skills (HEPSS)

It should be noted that the above residency criteria do not apply to individuals holding, or applying under, Category 2 Status or HEPSS. These regimes remain unchanged and, as we understand it, the existing residence requirements applicable to Category 2 and HEPSS individuals continue to apply independently of the new rules.

Partner Emma Lejeune attended the 3rd Annual Private Client Advisory & Litigation Forum in Versailles, a leading international forum for advisers, litigators, trustees and family office professionals in the private wealth sector.

The forum addressed key themes in international private wealth, including succession planning, governance, cross-border structuring and developments affecting complex private client matters.

Emma’s engagement reflects her continued focus on cross-border private client matters, including issues relating to families, governance, trusts, estates and fiduciary structures.

Commenting on the event, Emma said:
“The value of this forum lies not only in the topics discussed at each panel session but more generally, in the quality of discussion with practitioners from different jurisdictions. Many of the issues affecting private clients are inherently cross-border, and these conversations provide important insight into emerging risks and approaches.”

ISOLAS continues to engage actively in leading international discussions on private client and wealth structuring matters.

ISOLAS LLP is pleased to have advised Cheyne SVC Hybrid Credit Fund Investments SCA, Cheyne European Special Situations Fund Investments SCA and the Barings Group, as Arrangers/Lenders, together with Global Loan Agency Services Limited and GLAS Trust Corporation Limited, as Agent/Security Agent, on the Gibraltar-specific financing aspects of Balaena Group’s acquisition of APCL Group.

APCL Group is a leading British marine engineering company with operations across Birkenhead, Falmouth and Tyneside. The acquisition marks an important milestone for Balaena Group, owner of Gibdock, and further strengthens its position in the maritime engineering and shipbuilding sector. The transaction also reinforces Gibraltar’s strategic role as a gateway to the Mediterranean, with the enlarged group bringing together facilities across Gibraltar, Padstow, Tyneside, Birkenhead and Falmouth, creating a network of 12 dry docks serving both defence and commercial ship repair and refit work.

The ISOLAS LLP team was led by Partner Christian Hernandez, with key assistance from Associates Shakira Marsh-Finch and Anna Hernandez, and Legal Assistant Michelle Morgan.

Christian Hernandez commented:
“We are delighted to have supported Cheyne, Barings and the GLAS entities on this strategic financing. This transaction highlights the team’s depth of experience and expertise in complex, multi-jurisdictional financings, and our ability to deliver commercially focused Gibraltar legal advice at the very highest level.”

This transaction further reinforces ISOLAS LLP’s standing as a leading Gibraltar law firm for finance, corporate and transactional work.

 

We are delighted to once again support the KPMG Gibraltar eSummit. Now in its 15th year, the eSummit remains a key event in Gibraltar’s business calendar.

As a longstanding supporter of the event, ISOLAS contributed to a day of insightful discussions exploring the opportunities and challenges shaping the future of the gaming sector and Gibraltar’s wider digital economy.

Senior Partner Albert Isola CBE hosted Andrew Lyman, Gibraltar’s Gambling Commissioner, in a fireside chat covering current topics of interest, including the Gambling Act, the regulatory approach, the Treaty, UK tax, and recent developments.

Partner Steven Caetano joined the M&A panel, discussing investment trends and strategic opportunities within the industry whilst Partner James Montado joined the AI Futures panel, exploring the transformative impact of artificial intelligence and the practical considerations businesses need to address.

Thank you to KPMG Gibraltar for another outstanding event, and congratulations on hosting the 15th eSummit. We look forward to continuing these conversations for many years to come.

UK v Secretary of State for the Home Department [2026] UKUT 00081 (IAC),

The decision in UK v Secretary of State for the Home Department represents an important judicial intervention into the use of artificial intelligence (“AI”) in legal practice, highlighting the risks such tools pose to core professional duties, particularly client confidentiality and legal professional privilege. Although arising in an immigration context, the Tribunal’s observations are of general application across all areas of legal practice.

The Tribunal clearly recognised the limitations of generative AI, particularly freely available, non-specialist tools, which may produce superficially persuasive but entirely inaccurate outputs, including fabricated authorities and incorrect citations. Such “hallucinations” are not treated as novel or excusable errors but as foreseeable risks which legal professionals are under a positive duty to guard against. Lawyers remain under an absolute obligation to ensure that all authorities cited are accurate, verifiable, and properly support the propositions advanced, irrespective of whether AI has been used.

Importantly, the decision makes clear that the use of AI does not dilute or displace traditional principles of professional responsibility. Even where work is delegated to junior fee-earners or produced with the assistance of technological tools, the supervising solicitor retains full responsibility for its accuracy. The Tribunal went so far as to state that a failure to supervise and verify work which contains AI-generated errors may render the supervising lawyer more culpable than the individual who initially introduced those errors. In that sense, the case underscores the continuing relevance of established principles of supervision and accountability, whilst adapting them to the realities of modern legal practice.

Most notably, the judgment provides unequivocal guidance on confidentiality and privilege. The Tribunal stated that uploading client documents or correspondence into open-source AI tools (such as free versions of Chat GPT) may place such material in the public domain, thereby breaching confidentiality and thus waiving legal professional privilege. Given that privilege is contingent upon confidentiality, any such loss is potentially irreversible, regardless of the practitioner’s intention.

The Tribunal further situated this risk within the broader regulatory and data protection framework, noting that such conduct may give rise to reporting obligations to professional regulators and the Information Commissioner’s Office. However, it drew an important distinction between open-source AI tools and secure, closed enterprise systems, indicating that the latter may be used more safely where appropriate safeguards are in place.

In conclusion, UK v Secretary of State for the Home Department stands as a landmark decision in the emerging jurisprudence on AI in legal practice. Its importance lies in its clear articulation of a principle which will undoubtedly shape future conduct, whilst ensuring the preservation of legal privilege remains paramount, and any use of technology which jeopardises that protection will undoubtedly offer consequences. The case therefore serves as both a warning and a guide, reminding practitioners that whilst the tools of legal practice may evolve, the core duties which underpin it remain unchanged.

HM Government of Gibraltar has today published confirmation that Spain’s Ministry of Finance has issued a draft Ministerial Order to remove Gibraltar from its list of non-cooperative jurisdictions, marking a significant and long-awaited milestone.

If implemented following the short 7 day public consultation period, this will bring to an end a designation that has remained in place since 1991, despite Gibraltar’s long established record as a transparent and internationally cooperative Jurisdiction.

The proposal recognises that Gibraltar now satisfies Spain’s domestic criteria for fiscal transparency and tax fairness, aligning Spain’s position with Gibraltar’s standing internationally, including its OECD “white list” status for many years.

Beyond the symbolism, the practical implications are important. Gibraltar’s inclusion on the Spanish blacklist has historically triggered a range of adverse domestic tax consequences, particularly affecting individuals and businesses with cross-border connections. Its removal should therefore reduce friction, provide greater certainty in residency and structuring considerations, and remove a number of technical barriers that have persisted notwithstanding the Gibraltar-Spain Tax Agreement.

It is also noteworthy that this step fulfils a commitment given by Spain when the Gibraltar-Spain Tax Agreement entered into force in March 2021, albeit later than originally envisaged. The publication of the draft Order suggests that Spain is now moving to honour that undertaking.

From a broader perspective, this development reflects Gibraltar’s continued alignment with evolving international tax standards and its positioning as a credible, well-regulated financial services jurisdiction.

Importantly, this announcement comes at a time when agreement has been reached on the future UK–EU treaty in respect of Gibraltar, with implementation expected shortly. That treaty is expected to remove the physical border between Gibraltar and Spain, fundamentally reshaping the movement of people, goods and services across the frontier.

Taken together, these developments point to a clear and very positive shift in the cross-border dynamic, moving away from historic friction and toward greater cooperation, legal certainty and economic alignment.

Overall, this represents a genuinely significant moment for Gibraltar, with meaningful implications for its international positioning and for businesses and individuals operating across the region, aligning itself to the stated ambition of the European Union, Spain, the United Kingdom and Gibraltar of a shared prosperity for the region.

 

 

 

 

ISOLAS’ Property Litigation team, led by Partner Mark Isola KC and assisted by Partner Nicholas Isola and Trainee Solomon Kench, represented its landlord client in relation to an application by the tenant to the Supreme Court of Gibraltar for a renewal of its tenancy for the minimum prescribed term of five years under Part IV of the Landlord and Tenant Act 1983 (LTA 1983), and which was not opposed by the landlord. The landlord was seeking to insert a new term in the new tenancy, to allow it to break the new lease within that minimum prescribed period of five years and which the tenant opposed.  The Supreme Court of Gibraltar determined that a break clause within the minimum prescribed term of five years should be included in the new lease.

This decision confirmed an earlier decision of the Supreme Court of Gibraltar in Amro Bank NV v Sanguinetti [1999-2000] Gib LR 326, where the tenant itself was seeking the insertion of a break clause within the minimum term of five years prescribed under the LTA 1983, and provides helpful guidance on the exercise of the Court’s discretion under the LTA 1983 as to whether to insert a landlord’s break clause as a new term.

Background

The tenant operated its business from the premises under a lease that was granted for a term of five years in 2016 and which it held over on when it expired, and subsequently continued under the LTA 1983 when notice was served by the landlord terminating the existing tenancy.

Whilst the parties agreed on the duration of the new tenancy to be granted under the LTA 1983 to be for five years and at an agreed annual rent, the central issue in dispute was whether the Supreme Court had the power to insert a landlord’s break clause to permit the landlord to determine the tenancy on 30 June 2029 on giving six months’ prior written notice, and if so, whether the Supreme Court should exercise its discretion to do so on the facts and circumstances of this case.

Legal touchpoints

The issues for the Supreme Court were:

1. whether the insertion of such a break clause contravened the requirements of s. 52 of the LTA 1983, which requires that the minimum term for a new Part IV tenancy granted by the Supreme Court under LTA 1983 should be for a minimum of five years (First Issue); and

2. if a break clause could be inserted within the minimum prescribed period of five years, whether the Supreme Court should include a new term comprising of the break clause in the new tenancy to be granted by it (Second Issue).

Judgment

On the First Issue, the Supreme Court held that the insertion of a break clause within the minimum term of five years prescribed by s. 52 of the LTA 1983 did not conflict with the requirements of s. 52 of the LTA 1983, and could be included by the Supreme Court in exercise of its powers under s. 54 of the LTA 1983. The Supreme Court decided in line with the decision in ABN Amro Bank NV that a break clause was not a term going to the duration of a tenancy. Moreover, such a break clause granted an option to terminate a tenancy, but it did not impose an obligation to do so, and if it was not exercised, then absent other relevant circumstances such as forfeiture, the tenancy could only be terminated at the end of its term.

On the Second Issue, the Supreme Court considered a two-stage test. Firstly, whether there was a real prospect of the landlord developing the premises on obtaining possession from the tenant on exercise of the break clause. Secondly, if so, whether the landlord should be permitted an opportunity to seek to redevelop the building earlier than the minimum term of five years prescribed by s. 52 of the LTA 1983, which required an assessment of what was a fair and reasonable balance of the landlord’s and tenant’s competing interests in the light of all relevant circumstances.

The Supreme Court “had no doubt that there [was] a real possibility that the premises [would] be required for reconstruction” noting in particular that (a) the landlord had purchased the premises specifically for redevelopment and to occupy it for its own business purposes; (b) planning permission for redevelopment had been granted and but for the tenant’s premises the building was vacant; and (c) the landlord had revised its plans to carry out the works in two phases, with the first phase not requiring vacant possession of the tenant’s premises, and the second phase to be undertaken once the tenant had vacated the premises.

The Supreme Court held that there were no “countervailing major facts or factors” that prevented it from ordering the insertion of a break clause. The tenant’s position was not akin to a case of “significant financial and logistical prejudice” with the tenant’s evidence indicating that its business relied on regular customers and recommendations (not walk-ins), that its precise location was not crucial to its success, and that it had considered moving to alternative premises on termination of the tenancy. Any disruption involved with such a move would not create unsurmountable difficulties.

The Supreme Court held that the facts and circumstances supported the insertion of a break clause having evaluated the parties’ competing interests so as to strike as fair and reasonable a balance between them as the circumstances permitted.

The judgment is available here: Miss Shapes Limited v Breccia Limited, 2026/GSC/022

 

Why sophisticated families are rethinking how they hold assets, and what they are choosing instead. For summary Q&A click here.

Most wealthy families hold their assets the way they accumulated them: one at a time. Property in one jurisdiction, a portfolio in another, a business interest somewhere else. Each structure made sense when it was created. Together, they form something nobody designed and nobody governs. Accountants speak to lawyers who speak to custodians, and the family’s actual strategy gets lost in the middle.

This is the problem that Gibraltar private funds solve. Not partially. Structurally.

A Gibraltar private fund consolidates a family’s assets into a single, coherent vehicle. The fund holds the assets. The family holds units in the fund. That single shift changes almost everything: fragmented ownership becomes unified, reporting is centralised, and transfers of wealth occur at the unit level rather than requiring the restructuring of underlying assets across multiple jurisdictions.

The structure is deliberately private. It operates by private placement, not public offering, and is capped at fifty investors. This keeps it out of the regulatory framework applied to ‘commercially’ operating funds while still meeting international standards in full, including CRS, FATCA, AML requirements, and UBO registration. The result is a vehicle that is professionally governed and internationally credible, without the overhead of a fully regulated fund.

It is also worth being clear about what a private fund is not. It complements a family office; it does not replace one. But it can sit at the centre of a family’s financial ecosystem, providing the holding architecture around which everything else is organised.

Private funds impose no mandatory diversification rules, no prescribed asset classes, no forced limitations. The family defines the strategy. For some, the fund holds real estate. For others, private equity, operating businesses, or a global liquid portfolio. Many use it to consolidate worldwide holdings into a single vehicle for the first time. Others use it as a supervised environment for introducing the next generation to investment decision-making in a practical rather than theoretical way.

The structure scales as the family grows. And if the family eventually wants to open the vehicle to external capital, Gibraltar offers a clear conversion pathway into a regulated Experienced Investor Fund. Few structures provide this kind of forward optionality from the outset.

The era of structures designed primarily to obscure is over. International reporting frameworks have seen to that. But privacy, properly understood, was never about evasion. It is about discretion: organising significant wealth professionally without entering the public sphere.

Gibraltar private funds are not advertised, not listed, and not open to outside investors. They meet international standards in full, including UBO registration and beneficial ownership disclosure. This is not a constraint to work around. It reflects a regulatory environment calibrated to distinguish between legitimate private wealth structures and arrangements designed to obscure ownership. For international families, operating within that framework, rather than despite it, is precisely what makes the structure credible.

Wealth erodes fastest at the point of transition. Disputes between heirs, fragmented inheritance, governance vacuums, forced asset sales: these are the classic failure modes, and they tend to occur precisely because the structure was never designed to survive the generation that built it.

A private fund addresses this directly. Because the fund owns the assets and family members hold units, inheritance is straightforward. Heirs receive units, not a scattered collection of properties and accounts across different legal systems. The governance framework survives the transition intact. The strategy continues. For families that want their values embedded in how their wealth is managed, whether through philanthropy, impact investing, or specific investment principles, the fund provides a governed platform for that too.

Private funds are not a universal answer. Families with assets in certain jurisdictions, Spain being a prominent example, need careful advice before proceeding. Cross-border tax treaties can create complications that require expert navigation, and the lighter regulatory regime places real responsibility on families and their advisers to implement and maintain the structure properly.

The point is not that private funds are simple. It is that they are the right structure for a growing number of sophisticated families who have outgrown the patchwork of arrangements that got them here. The fragmented approach has reached its limits. A single, governed, flexible vehicle represents the direction of travel.

Published in the Gibraltar Gazette, the Protected Cell Companies (Amendment) Bill 2026 (the “Bill”) marks a significant evolution in the jurisdiction’s digital asset landscape. It enables PCCs specifically those authorised as Experienced Investor Funds (“EIFs”) to issue cell shares as share tokens recorded on a distributed ledger.

The legislation is meticulously constructed and the legal architecture is robust. However, before the market succumbs to the tokenisation hype, it is vital to distinguish between what this Bill achieves and what it intentionally avoids. This is not the sudden arrival of a rampant secondary market for tokenised securities; it is the laying of critical foundations, and in financial services, foundations matter.

Targeted Efficiency: The Problem Being Solved

To appreciate the Bill’s value, one must look at the administrative pain points it targets rather than the technology it deploys.

Currently, PCCs utilised as EIFs carry genuine operational friction. Share transfers often require physical documentation; registers are maintained manually or on disparate proprietary systems; and subscription processing involves laborious rounds of reconciliation between the PCC and its administrator. While the system isn’t broken, it is undoubtedly slow, costly, and more prone to error than modern finance should tolerate.

The Bill addresses this directly. By permitting share registers to be maintained on a distributed ledger (DLT share registers) and allowing transfers via smart contracts, it creates the conditions for:

• Faster settlement times.
• Automated corporate actions.
• Real-time register accuracy.
• Reduced reconciliation overhead.

For cells with frequent subscriptions and redemptions, these are tangible operational gains, unglamorous, perhaps, but commercially real.

Legal Equivalence: A Share is Still a Share

The Bill’s most significant contribution is legal clarity. Under Section 18B(3), a share token is expressly declared a valid share certificate for the purposes of the Companies Act 2014. The holder of a token has identical rights and obligations to any other shareholder of the same class.

Tokenisation here changes the form, not the substance. This resolves a question that has plagued other markets: what exactly does a token represent? In Gibraltar, the answer is now unambiguous.

Furthermore, the Bill provides solutions to complex jurisdictional hurdles:

• A DLT register is treated in law as being kept at the company’s registered office, regardless of where its network nodes actually sit.
• Execution via smart contract constitutes the delivery of a “proper instrument of transfer,” satisfying the Companies Act.
• Cryptographic signatures carry a rebuttable presumption of genuineness, providing the legal infrastructure necessary to make the system workable in practice.

Managing Expectations: Not a Secondary Market

Honest assessment requires acknowledging the Bill’s limits. Transfers still require company consent. Recipients must be verified, “allow-listed,” and meet strict investor eligibility requirements. By design, the token cannot move freely.

The common argument that tokenisation automatically unlocks limitless liquidity does not apply here, at least not yet. This is a permissioned, consent-gated system. While the technology has changed, the fundamental transfer controls of an EIF remain intact. This is not a criticism; EIFs are not intended to be freely tradeable instruments. A Bill that attempted to force secondary market liquidity would be solving the wrong problem.

Positioning vs. Plumbing

Beyond the operational case, there is the matter of competitive positioning. Competing fund jurisdictions are moving toward frameworks that accommodate tokenised structures. Gibraltar does not need to be first, but it must be ready. A jurisdiction that lacks the legal infrastructure to support tokenised shares is a jurisdiction that will eventually lose mandates.

This Bill fits a coherent pattern. Building on the 2018 DLT Regulatory Framework, this legislation extends that logic into the funds space. This incremental approach, moving quickly enough to lead, but carefully enough to ensure legal certainty, remains Gibraltar’s primary strength.

What it Means in Practice

For fund managers, this is a development to monitor closely. The Gibraltar Financial Services Commission (“GFSC”) will require a substantive assessment of competence and capability before granting consent for tokenised issuance. Infrastructure, not just intent, will be the benchmark.

For practitioners, the immediate work lies in documentation. Articles of association, offering documents, and custody arrangements must be reviewed. The disclosure obligations under Section 18C: covering cybersecurity risks, DLT infrastructure, and contingency plans, will require bespoke drafting rather than boilerplate templates.

Conclusion

The Protected Cell Companies (Amendment) Bill 2026 is best understood as infrastructure legislation. It builds the framework upon which more can be constructed, whether that is immediate operational efficiency or, in the longer term, more fluid liquidity models. It avoids over-promising, a rare and welcome restraint in the blockchain space. Gibraltar has provided the tools; it is now up to the market to determine the appetite for using them.

ISOLAS hosted another successful quarterly briefing in partnership with Women in Enterprise, bringing together professionals to explore workplace conversations and communication challenges.

Today’s session was jointly led by ISOLAS Partner Samantha Grimes and Fiona Young, Head of Employment at Ramparts, focusing on workplace conversations and the risks that can arise from poor communication.

Sam drew on over 20 years’ experience advising businesses on employment law, highlighting how miscommunication and poorly handled conversations can escalate into grievances, allegations of bullying, and wider workplace challenges.

Fiona complemented this by focusing on intention and approach how to build rapport, maintain relationships, strengthen trust, and encourage collaboration. She also shared practical tools to help structure conversations, avoid common pitfalls, and achieve more constructive outcomes.

The session was very well attended, with strong engagement throughout and excellent feedback from participants.