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.

ISOLAS & Fiduciary have once again been recognised as an Accredited Employer Partner by STEP (The Society of Trust and Estate Practitioners). This reaccreditation reflects our ongoing commitment to fostering professional excellence across our teams.

What is the STEP Employer Partnership Programme?

The STEP Employer Partnership Programme recognises organisations that actively support their employees in developing their skills within the Private Client sector. Employer Partners are required to demonstrate a strong commitment to learning, development, and the ongoing professional growth of their people in line with STEP’s global standards.

Our commitment to development

Investing in our people is central to our culture. We actively encourage our employees to pursue relevant professional qualifications and provide both financial support and study leave to help them succeed. We currently have six employees who hold full TEP membership. We have one associate member progressing towards full TEP qualification, and two partners who are affiliate members.

Building expertise for our clients

We believe that developing our people directly enhances the quality of service we provide. By supporting our teams in building their knowledge and expertise, we ensure we continue to deliver forward-thinking advice to our clients across generations. We are incredibly proud of our colleagues for their dedication, whether they have already achieved their qualifications or are working towards them, and we are delighted to celebrate their ongoing success.

STEP is widely regarded as a benchmark for excellence within the industry and we are delighted that we have once again been recognised through this accreditation.

Hayley Xerri MBPsS (Chartered MCIPD) Chief Operating Officer

Fiduciary HR Solutions – Should you wish to learn more about our HR solutions, including payroll services, please contact the team at HR@fid.gi or telephone +350 200076651.

After some years in the making the new Gambling Bill proposes an Act (“New Act”) providing a modernised framework for the licensing and regulation of the Gibraltar gambling industry. It has been published today. Below is a summary of the key changes.

KEY CHANGES

Under the New Act “regulated activities” are prescribed by Sections 17 – 19.

The New Act will introduce regulations to underpin new fees for all licence types and verticals prescribed.

There are currently no plans to change gambling duty rates for B2Cs nor to impose gambling duty on B2B operators who will remain exempt to duty under the New Act.

The supply of betting data on its own will not be licensable under the New Act.

Marketing will become a licensable activity (subject to narrow exceptions) and is widely defined under the New Act.

APPLICATION PROCESS AND FEES

The licensing bar will remain a high one and maintaining the reputation of Gibraltar will be a statutory objective under the New Act. The licensing process will continue as present with applicants required to undergo a pre-licensing engagement (draft application) and assessment exercise ahead of an “in principle” decision by the Licensing Authority in order to proceed with the final formal licence application.

Key changes to the licence process are that application fees will be payable in two stages, as follows:

(a) 50% at the start of the pre licensing stage; and

(b) 50% on submission of the final (formal) licence application.

Under the New Act the Licensing Authority may at its discretion reduce application fees in respect of simultaneous applications which relate to more than one type of licence or vertical (i.e. B2B, B2C and Gambling Support Services). All application fees are non-refundable. Below is a table of relevant application fees:

Licence Type	Licence Application Fee
B2C	£30,000
B2B Content Aggregator	£20,000
B2B Direct Content Provider	£10,000
Gambling Operator’s Support Services	£8,000

CHANGE OF CONTROL (“COC”)

CoC fees will be chargeable on submission of a CoC application, a fee of £7,500 (“Base Fee”) and following 21 days from submission the Regulator may charge an additional CoC fee of up to £22,500 (“Additional Fee”) commensurate to the complexity and extent of CoC exercise and related due diligence required to consider the CoC application. The Additional Fee is payable to the Licensing Authority within 7 days of the amount being prescribed.

ANNUAL LICENSING FEES: B2C

Separate B2C annual fees will be charged for distinct verticals such as: betting, gaming and lottery.

Licensing fees for start-up and small operators will be tired based on gross gaming/ betting yield. Please see annual fees table below. For example, a B2C operator that offered a betting vertical (with GGY greater than £300M), and a gaming vertical (with less than £300M GGY, but more than £20M) would pay £300,000 as an annual fee.

A B2C licence includes “white labelling” services to third parties in the categories covered by the relevant B2C licence.

B2C LOTTERY

A special licence for operating an online lottery, regardless of size and whether or not operated for charitable purposes will be introduced by the New Act. Please see table below.

BETTING AGENT

A special licence for betting agents will be introduced by the New Act. Please see table below.

ANNUAL LICENSING FEES: B2B

The New Act provides that eligible externally based suppliers of content should be licensed on the basis that they are supplying Gibraltar licence holders regardless of where the supplier is based or the location of the servers hosting the content.

Gaming and betting software suppliers can supply Gibraltar based B2Cs (or other B2Bs) either through an aggregator or directly as a licensee. All content providers must be approved by the Licensing Authority whether they are servicing an aggregation platform or directly supplying content.

The supply of live gaming content by B2Bs will be considered to be a separate B2B vertical to server-based gaming supply (see table below). Gaming generally will be treated as a single vertical for B2C licences.

APPROVAL OF CONTENT PROVIDERS

A fee of £1,000 will be payable for the approval of any aggregation or direct content provider. Payment should be made before the approval process is commenced, upon seeking approval from the Regulator.

B2B AGGREGATORS

B2B aggregators will be charged a Basic Fee of £85,000 and an Additional Basic Fee of £15,000 per additional B2B vertical under the New Act. Please see table of annual fees below.

DIRECT SOFTWARE SUPPLIERS

A tiered licence fee system (per annum) will be introduced by the New Act for Direct Software Suppliers as follows:

Tier 1	Will authorise unrestricted direct integrations to Gibraltar B2C’s approved.
Tier 2	Is tailored for suppliers with less than £550,000 gross sales to Gibraltar licensed B2Cs or limited to no more than (3) three approved integrations with Gibraltar licensed B2C’s.
Tier 3	Is tailored for suppliers with gross sales of less than £200,000 to Gibraltar licensed B2C’s or no more than (2) two approved integrations with Gibraltar licensed B2C’s.

Please note that “Gross Sales” will be treated as the amount of money a software supplier earns from selling its products and services under its Gibraltar B2B licence. Please see annual fees table below for further details.

B2B PLATFORM SUPPLIERS

This B2B licence would not apply to an operator’s proprietary platform or intra group supply, but relates to B2B businesses who supply a partial or full service platform to Gibraltar licensed B2Cs considered “critical” to that business. The location of the platform is irrelevant. This also applies to any business that engages in platform supply in or from Gibraltar (to other B2C operators operating outside Gibraltar) under the New Act.

Where a B2B business supplies a platform for either betting or gaming purposes it will fall within the scope of licensing. A licensed B2B content aggregator will not be required to separately licence the platform from which its approved content is served. All providers to the platform of in licensable services (i.e. supply of gaming and betting software/ platform) will need to be either licensed or approved by the Regulator. Please see table below.

MANAGED TRADING SERVICES, TRADING RISK MANAGEMENT AND VIRTUAL/SIMULATED CONTENT

Data supply on its own is not licensable under the New Act. In addition to the supply of data, some businesses also provide managed trading services/betting risk management services. Where such services are provided to Gibraltar licensed B2Cs, then a B2B licence will be required by that business to conduct such activity.

Where betting data suppliers (or others) supply virtual/ simulated content for the purposes of gambling they will be required to hold a B2B licence, see table below for details. The platform, managed trading services and provision of virtual and simulated content will be subject to one B2B licence and one annual licence fee – authorised under one licence. Please see table below.

OTHER B2B REGULATED ACTIVITIES

Section 19(2) of the New Act will apply to those who supply certain other support services to licence holders or carry out certain functions on an outsourced basis. This licence would not be required when such services are performed for a licence holder intra group/ internally.

Genuine third-party suppliers of consultancy services and suppliers of regulatory technology for AML/CFT/CPF purposes will not fall within scope of licensing under the New Act, on a case by case basis.

The test for licensing “other B2B regulated activities” will turn on whether the supplier of fraud, risk management or compliance services controls or processes customer data which is capable of identifying an individual and whether or not such functions are outsourced or treated as an integral part of the B2Cs own risk management processes. Please see table below for relevant annual fees.

MARKETING

Marketing is widely defined by S17(vi)(a) of the New Act as: conducting, managing, arranging, booking, facilitating or providing advertising or marketing services for gambling wherever in the world gambling takes place. Whilst gambling-related marketing will be a regulated activity under the New Act, a relatively restrictive approach will be taken limiting the issue of such Licences.

Under the New Act, Gibraltar B2C licensed operators will be able to conduct group marketing activity in Gibraltar under their existing Remote Gambling Licence. Gibraltar B2Bs will need a separate Marketing Licence to promote their B2B products but these will be considered favourably and won’t attract an additional licence fee.

There will be a presumption against the grant of such marketing licence, unless the Minister (as licensing authority) exercises its discretion on grounds that the public interest, including the good reputation of Gibraltar would not be prejudiced or threatened by the giving of such a licence. The effect of this is that even having substance and management control of the marketing activity in Gibraltar will not in itself create a right to the grant of a marketing licence but the level of substance and real economic activity in Gibraltar will be critical to convincing the Minister, as licensing authority, that such a licence should be granted.

HOLDING ENTITIES

The New Act defines what constitutes a “gambling group holding entity”. Authorisation will be required whenever a holding entity (legally or beneficially) owns shares in a gambling company outside Gibraltar which, if it carried on its business in Gibraltar, would be licensed in Gibraltar. This applies regardless of where in the ownership structure the Gibraltar-linked holding entity features (whether the interest is held directly or indirectly). Please see table for annual fees.

HOLDING OR MANAGING CUSTOMER FUNDS

Holding or managing customer funds will not require a separate licence when done by a gambling licence holder or by a licensed financial institution under the New Act. When done by a person that is not the holder of a B2B or B2C licence it will require a Gambling Support Services Licence. Please see table.

REGULATED INDIVIDUALS

Sections 57-77 of the New Act govern “Regulated Individuals”, their functions and licensing. A key individual will be approved to carry out one or more regulated functions at a particular operator. Whilst a regulated individual’s licence will attach to the individual and that individual’s role within the licensed operator it is not transferable automatically by the individual to another licensed operator. Where an individual acquires new and different regulated functions within the same operator, such new functions become notifiable and subject to additional approval. Please see table below.

LICENCES AND ANNUAL FEES

B2C Gambling Operator’s Licence (Bookmaker) (Real event betting, fixed odds betting on the outcome of a lottery, betting, e‑sports and pool betting)	Annual Gross Betting Yield over £300 million: £200,000 Annual Gross Betting Yield over £20 million: £100,000 Annual Gross Betting Yield under £20 million: £50,000
B2C Gambling Operator’s Licence (Gaming) (Server‑based gaming, live gaming, slots, numbers betting and bingo)	Annual Gross Gaming Yield over £300 million: £200,000 Annual Gross Gaming Yield over £20 million: £100,000 Annual Gross Gaming Yield under £20 million: £50,000
B2C Betting Intermediary, Betting Exchange and/or Betting Agent	£100,000
B2C Remote Lottery Operator	£100,000
Betting Agent	£50,000
B2B Gaming Aggregator – Single Vertical Note: For additional vertical under the same licensed entity: (i.e. live event betting, live gaming, server based gaming, lottery, lottery betting, virtual/simulated betting content, e-sports)	£85,000 (“Basic Fee”) plus £15,000 (“additional basic fee” per additional vertical)
B2B Direct Software Suppliers Tier 1 Licence Tier 2 Licence Tier 3 Licence	£85,000 £50,000 £20,000
B2B Platform (Third Party)	Single vertical: £85,000
Covering betting, e-sports, virtual or simulated content, managed trading services or supply of real event data, event content or odds. Note: Each additional vertical under the same licensed entity: (i.e. live event betting, live gaming, server-based gaming, lottery, lottery betting, virtual/simulated betting content, e-sports)	£15,000 per additional vertical
B2B Supply of Managed Trading Services, Virtual and Simulated Content	£85,000
B2B Other Regulated Activities Provision of fraud prevention, risk management, customer due diligence or compliance, customer identification verification and/or customer relationship functions or services (but not consultancy or advisory services)	£50,000
Gambling Marketing Services (including gambling affiliate and CRM services) conducted in or from Gibraltar (where entity is not otherwise licensed)	Over £200k invoiced per annum: £50,000 Under £200k invoiced per annum: £25,000
Gibraltar‑Related Holding Entity (For gambling carrying on business elsewhere)	£5,000
Holding or Managing Customer Funds (Other than licence holder or financial institution)	£50,000
Regulated Individual – First Approval (Licence to run for 5 years)	£500 one‑off fee for five years
Regulated Individual – Material Changes (To a particular 5‑year approval)	£200 per material change

Note:
1. The contents of this note does not constitute advice. It is provided for information purposes only strictly on a non-reliance basis.
2. The transitioning between the current law and new Act in relation to both licensing and licensing fees payable will run from 1st April 2026-1st October 2026. Transitioning between the current law and New Act in relation to both licensing and licensing fees payable.

Should you have any specific queries please feel free to contact Steven Caetano below.

ISOLAS has once again been recognised in the Legal 500 EMEA 2026 rankings, with 21 lawyers ranked across a range of practice areas. The results reflect senior ranking advancements and continued individual recognition across the firm.

Senior Partner The Hon Albert Isola CBE welcomed the review “These results are a strong reflection of the quality, expertise and dedication of our lawyers across the firm. We are delighted to see continued individual recognition at all levels, which is a testament to the strength and depth of our team. We thank our clients for their continued trust and support.”

ISOLAS continues to be recognised across its core practice areas in Gibraltar, reinforcing its position as one of the jurisdiction’s leading full-service law firms.

Senior Partners Peter Isola and The Hon Albert Isola CBE together with Partner Christian Hernandez are recognised as ‘Hall of Fame’, Legal 500’s highest accolade, in Corporate, Commercial and M&A, FinTech and Shipping respectively, reflecting their longstanding contribution to the market and continued excellence in their respective fields.

In addition to the above, Christian Hernandez is also awarded ‘Hall of Fame’ status in recognition of his many years practice and expertise in Banking & Finance.

The firm has also seen promotions to ‘Leading Partner’, including Mark Isola KC and Samantha Grimes in Dispute Resolution, Christian Caetano in Corporate / Commercial and M&A, James Montado in Banking & Finance, Jonathan Garcia in TMT and Sarah Bray in Real Estate & Construction.

They join Leading Partners Neil F Costa, Dispute Resolution, Steven Caetano Corporate, Commercial and M&A and Gaming, Adrian Pilcher, Emma Lejeune, both in Private Client and Sarah Bray in Real Estate & Construction.

Both James Montado and Jonathan Garcia also maintain their ranking as Leading Partner in Dispute Resolution and Fintech respectively.

In addition, Stuart Dalmedo, Private Client and Nicholas Isola, Real Estate & Construction, are recognised as ‘Next Generation Partners’, highlighting the strength of the firm’s next generation of leadership. Nicholas Isola is also recognised as ‘Next Generation Partner’ in Corporate, Commercial and M&A.

Senior Associates Danielle Victor, Dispute Resolution, Katrina Isola, Real Estate & Construction along with Associates Louise Anne Turnock, Tax, are recognised as ‘Leading Associates’, reflecting their strong reputations and contributions across key practice areas.

Associate Louise Anne Turnock has also been recognised this year and made Leading Associate in Private Client.

Further individual recognition includes Senior Associate James Castle, with Associates Giovanni Origo and Shakira March-Finch are acknowledged by Legal 500 for their contributions across Dispute Resolution, Commercial, Corporate and M&A, and Banking & Finance, respectively.

As a lawyer who practises in ship arrest and admiralty matters, I look at the current crisis involving Iran, the disruption to the Strait of Hormuz and soaring oil prices through a slightly different lens from most commentators. Important though the geopolitical and military dimensions plainly are, my immediate instinct is to consider the commercial consequences for shipowners, operators, charterers, suppliers, lenders and insurers. In shipping, geopolitical shock rarely stays geopolitical for long. It very quickly turns into cash-flow strain, delayed payments, contested liabilities and, in some cases, urgent applications to arrest ships.

That is particularly true where the shock affects energy flows. The present conflict has severely disrupted traffic through the Strait of Hormuz, a waterway through which roughly a fifth of global oil and LNG normally passes, while Brent crude has moved above $100 a barrel. Refined fuel markets have also tightened, with diesel and bunker costs coming under particular pressure, and major operators such as Maersk have responded by introducing emergency bunker surcharges.

History teaches that sea power is often as much about threat as about actual destruction. One of the enduring lessons of naval warfare is that a credible threat to a chokepoint can have market consequences out of all proportion to the number of ships actually attacked. That is one of the clearest features of the present situation. Even where capability is uncertain or uneven, the mere prospect of drones, missiles, mines, rising war-risk premiums and the absence of secure escort arrangements is enough to force owners, charterers and underwriters to reprice risk immediately.

From the perspective of a ship arrest lawyer, this is relevant because these added costs do not fall evenly across the market. Stronger operators may absorb them. Weaker or more thinly capitalised players may not. When bunker costs rise sharply, war-risk insurance becomes materially more expensive, schedules are disrupted and freight economics deteriorate, the legal fallout tends to appear in familiar forms,  unpaid bunkers, unpaid port charges, unpaid hire, unpaid necessaries, crew claims, disputes with mortgagees and increasing pressure from creditors who no longer trust promises of payment tomorrow. In a stressed market, ship arrest ceases to be a technical procedural device and becomes what it has always really been, one of the most effective ways of obtaining security when the risk of non-payment is no longer theoretical.

All of this brings Gibraltar firmly into the picture. Gibraltar’s location at the gateway to the Mediterranean has always given it strategic maritime importance, but in times of shipping stress that geography becomes commercially and legally significant. The Port of Gibraltar is the largest bunkering port in the Mediterranean, and it sits on one of the busiest maritime corridors in the world, with more than 100,000 vessels transiting the Strait of Gibraltar annually. It is exactly the sort of jurisdiction in which the consequences of upstream disruption in the Gulf may begin to show themselves through defaults, claims and security actions against vessels calling to bunker, change crew or await orders.

In my view, Gibraltar has very real advantages as a ship arrest jurisdiction. One of its principal strengths is speed. If full instructions and supporting documents are available and the writ and affidavit are in order, an arrest can in practice be effected within hours. The Admiralty Marshal is available 24 hours a day, 365 days a year, so in urgent cases an arrest can be carried out at any time. That is no small advantage in a port where vessel calls are often short and commercially driven. Gibraltar is also commercially pragmatic from the owner’s perspective: once satisfactory security is provided, often by way of a P&I Club letter of undertaking or a first-class bank guarantee, release can usually be obtained very quickly.

Another practical advantage is that admiralty matters in Gibraltar are treated with priority by the Supreme Court. In a volatile market, creditors do not just want theoretical rights, they want a forum in which those rights can be exercised swiftly and effectively. Equally, owners and clubs want to know that if security is offered, release can be arranged without unnecessary delay. Gibraltar’s arrest jurisdiction works because it recognises both sides of that commercial reality.

None of this is to suggest that every shipping company calling at Gibraltar is about to default, or that every period of market stress will produce a wave of arrests. But if the present Iran crisis continues to keep oil prices elevated, insurance costs high and trading conditions unstable, I would expect an increase in payment pressure across parts of the shipping market. And where payment pressure rises, ship arrests tend to follow. For maritime creditors, lenders, bunker suppliers and others exposed to shipping counterparties, Gibraltar may prove to be one of the most effective points in the Mediterranean at which to convert concern into security.

Christian is a Partner at ISOLAS LLP, the oldest and one of the largest law firms in Gibraltar. He is acknowledged as one of the leading lawyers in Gibraltar in the fields of admiralty and shipping law.

He has been named as a leading individual  by Chambers and Partners, the European Legal 500 and Global Counsel 3000, amongst others. Among others he represents major banks, the International Transport Workers’ Federation, P&I Clubs, bunker suppliers and shipowners.

“He is noted for expertise in non-contentious and disputes work in the admiralty area.” CHAMBERS & PARTNERS

“Hernandez is well known for his expertise in ship arrest and has a strong track record for his handling of shipping cases.” THE LEGAL 500

“Clients describe Christian Hernandez as “brilliant in shipping law and large commercial transactions,” adding: “He’s a commercial lawyer and is pragmatic in his advice.” CHAMBERS & PARTNERS

“ISOLAS remains a leading player in the shipping sector under the leadership of Christian Hernandez. His practice counts ship owners, banks, P&I clubs, and International Transport Workers’ federation among his clients.” THE LEGAL 500

For more information or for any enquiries, please don’t hesitate to contact Christian on christian.hernandez@isolas.gi

 

ISOLAS LLP Partner, Christian Caetano, has contributed the 2026 Gibraltar Insurance Chapter on the Thomson Reuters Regulatory Intelligence platform. The updated Gibraltar Chapter reviews the most recent regulatory and legislative developments affecting Gibraltar’s insurance and wider financial services sector. In particular, it considers the ongoing progress made on the Gibraltar Authorisation Regime (GAR), which will govern market access arrangements for Gibraltar-based insurers and other regulated firms to operate in the United Kingdom, once fully implemented. In addition, the Chapter outlines key regulatory requirements applicable to prospective insurers seeking authorisation from the Gibraltar Financial Services Commission (GFSC), including licensing procedures, applicable regulatory fees and capital requirements.

Commenting on the publication, Christian said:

“I am delighted to have again been invited to contribute the Gibraltar Insurance Chapter for the Thomson Reuters Regulatory Intelligence Insurance Guide. This Guide will be a helpful tool for those prospective applicants interested in learning more about Gibraltar or as a point of reference for existing stakeholders. Gibraltar’s insurance sector continues to demonstrate strong growth and resilience despite facing several sector-specific challenges, as well as those of a macro-economic and geopolitical nature. Industry reports continue to estimate that more than 35% of all UK motor insurance premiums are underwritten by Gibraltar-based insurers, with total gross written premiums reportedly exceeding £7 billion.

We are also pleased to continue supporting clients on corporate and commercial transactions across the sector, including on Part 23 insurance business transfers, as well as reorganisations, mergers and acquisitions involving both underwriters and intermediaries. Gibraltar’s speed to market, robust regulatory framework and unique market access arrangements with the United Kingdom continue to position the jurisdiction as a highly attractive location for insurance businesses.”

Thomson Reuters Regulatory Intelligence guides provide exclusive news, analysis, and practical guidance from a global team of regulatory compliance experts and journalists. The guide is available for subscribers only but Christian may be reached directly on christian.caetano@isolas.gi.

This recognition by Chambers and Partners in their General Business Law rankings reaffirms our longstanding market leadership and depth of expertise across key practice areas, including Corporate/Commercial, Financial Services, Dispute Resolution, Gaming, and Shipping.

ISOLAS also counts on a number of highly ranked leading individuals in all sectors, and this year, one notable individual achievement is that of The Hon Neil Costa who has risen in short time to Band 2 in Dispute Resolution, reflecting his growing influence, client confidence, and consistent delivery on high‑value, complex matters.

Of the Firm, Chambers Review states “ISOLAS enjoys a longstanding reputation as one of the top full-service law firms in the Gibraltar market. It covers a wide remit of legal areas, ranging from finance and corporate transactions to licensing and insurance matters. Its lawyers frequently advise clients from both the public and private sectors. The firm possesses expertise in large real estate development projects and regularly advises on financial regulatory issues, including those related to cryptocurrencies, as well as on gaming matters. Additionally, ISOLAS operates a successful disputes practice, covering various litigation matters with a strong focus on employment and property disputes. The firm further assists with shipping mandates, such as ship arrests.”

Senior Partner The Hon Albert Isola CBE said “We are incredibly proud of our Team who, year after year, maintain our Band 1 ranking. Their commitment to our clients is exemplary and I am delighted by this recognition. Congratulations to all.”