Insight into the Gibraltar Financial Services Commission’s Strategic Plan 2023-2026

16/08/2023 Christian Caetano

The Gibraltar Financial Services Commission (GFSC) has recently outlined its strategic plan for 2023 to 2026, accessible here, GFSC Strategic Plan, in which the GFSC has reiterated its commitment to the fair and proportionate regulation of Gibraltar’s financial services industry.

The Strategic Plan acknowledges both successes and challenges faced by the GFSC over the last few years, particularly in response to the COVID-19 pandemic. The GFSC has however remained adaptable to changing market conditions and evolving risks, including by improving on its processes to reflect the ever-evolving needs of its firms (as well as of prospective applicants). In this regard, the GFSC acknowledges the need for enhanced capacity, technology, and resources to effectively respond to challenges, including competing priorities, operational risks and external dependencies.

By way of summary, the GFSC’s Strategic Plan’s core focus revolves around four high-level strategic goals for the period 2023 to 2026:

  1. Supporting Implementation of the Gibraltar Authorisation Regime (GAR):
    The GFSC is actively involved in assisting the Government of Gibraltar and the financial services industry in implementing the GAR. This permanent market access regime aims to establish mutual market access between Gibraltar and the UK, ensuring regulatory alignment and close cooperation. The GFSC will contribute to this effort through supervisory plans, policies, and procedures, as well as collaborative engagements with industry associations, regulatory authorities, and government bodies.
  2. Strengthening Regulatory Effectiveness and Risk-Based Approach:
    The GFSC will further enhance its risk-based approach to regulation, focusing on maintaining fairness and proportionality. The commission will implement a Digital Transformation Strategy (DTS) to streamline processes and support regulators with tailored technology solutions. Strengthening project management capabilities, improving internal decision-making processes, and developing sector-specific guidance are among the initiatives to enhance regulatory effectiveness.
  3. Fostering Collaboration and Stakeholder Engagement:
    Collaboration and engagement with stakeholders are central to the GFSC’s strategic goals. The Commission aims to maintain strong relationships with industry stakeholders, enhance consumer awareness through initiatives like the Moneywise program, and conduct regular meetings with regulatory counterparts in the UK. The GFSC will seek to involve stakeholders in the development of Service Level Agreements (SLAs) to ensure meaningful and efficient interactions.
  4. Building a Skilled and Motivated Workforce:
    To ensure operational efficiency, the GFSC will focus on recruiting, developing, and retaining a highly skilled and motivated workforce. The Commission plans to implement an employee engagement strategy, enhance appraisal and salary frameworks, allocate resources effectively, and invest in comprehensive training and development programs to foster regulatory expertise.

Partner, Christian Caetano, commented on the GFSC’s Strategic Plan as follows:

The GFSC continues to form an integral part of Gibraltar’s growing financial services ecosystem by virtue of its proportionate, effective and collaborative approach to regulation and supervision of firms in line with the highest international standards. The Strategic Plan will provide stakeholders with valuable insight into the regulator’s key strategic goals over the next three-year period, which includes the successful implementation of the Gibraltar Authorisation Regime (GAR).

Extensive preparatory work has, to date, been undertaken by the GFSC together with HM Government of Gibraltar on securing permanent market access between Gibraltar and the UK, meaning that the GAR understandably features as one of the GFSC’s four high-level strategic goals.

In addition, the GFSC highlights the continued strengthening of its stakeholder relationships via enhanced collaboration as another of its main strategic goals. As part of this, the GFSC has recently launched a Consultation Paper titled ‘Staged Application for Authorisation Approach’ whereby it has set out its proposals for a more structured approach to the authorisation application process and sought feedback from the wider industry.

Speed to market is widely recognised as one of Gibraltar’s competitive advantages over larger jurisdictions and the GFSC’s consultation on its Authorisations Approach will undoubtedly serve to further streamline the jurisdiction’s response times.”

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