Gibraltar Funds Update 2025: What Changed and How TAG Has You Covered

Problem: Need a Gibraltar-based fund administrator to stay compliant?

Good news: You don’t have to figure it out alone, TAG Consultancy’s Fund administration services can help you through the whole process, end-to-end.

What changed (May 2025)

In May 2025, the Financial Services (Alternative Investment Fund Managers) (Amendment) Regulations 2025 introduced an important change for certain Gibraltar funds. The new rules insert Sections 18B and 18C into the AIFM Regulations, requiring some self-managed funds to strengthen their administration and custody arrangements.

This marks a significant shift for smaller funds that previously operated entirely on a self-managed basis, and it reflects Gibraltar’s commitment to align with evolving international standards.

Who is affected by the change?

The update applies specifically to funds classified as self-managed small AIFMs. These are funds that:

• Are internally managed by their governing body (i.e. no external AIFM is appointed),
  
• Have assets under management within the “small AIFM” thresholds in Regulation 8(1),
  
• Have no more than 50 participants, and are not Experienced Investor Funds (EIFs)

If a fund meets all four conditions, it now falls under the new requirements.

What to do now (practical steps)

1. Confirm scope: Check if you meet the “self-managed small AIFM” definition.
   
2. Appointing a local administrator: Typically responsible for books and records, investor/regulatory reporting, and AML/KYC oversight.
   
3. Putting custody arrangements in place: Establishing a relationship with an “appropriate person,” such as a bank, credit institution, or equivalent supervised entity.
4. Engaging with the GFSC: Where an exemption may be appropriate, an application must be made and formally approved.

Need a Local fund administrator fast?

TAG Consultancy offers a professional, transparent, and all-encompassing Fund Administration service:

• Assess your fund’s status against the rules and map the fastest compliant route.
• Coordinate the appointment of a Gibraltar-licensed fund administrator, such as TAG Consultancy. 
• Set up custody/banking solutions appropriate to your asset mix (including digital assets).
• Align your documentation and processes (PPM, AML/KYC, reporting cadence) with regulator expectations.
• Keep you moving to launch while reducing operational and compliance risk.

Why TAG Consultancy

• Local Gibraltar know-how: On-the-ground team that understands timelines, providers, and regulator expectations.
  
• End-to-end orchestration: Structure, PPM support, administrator services, custody/banking setup, filings calendar.
  
• Crypto-aware, custody-ready: Practical experience aligning digital-asset strategies with oversight and safekeeping.
  
• Compliance built-in: AML/KYC frameworks, record-keeping, and reporting rhythms that withstand scrutiny.
• Clear, outcome-led delivery: A single plan from “confirm structure” → “launch” → “ongoing compliance.”

Next steps

• Assess: Confirm whether your fund meets the definition of a self-managed small AIFM.
  
• Appoint: Engage TAG Consultancy as your licensed local administrator.
  
• Arrange custody: Let us help you put in place banking or custodian relationships with an “appropriate person.”
• Align documentation: Work with our team to ensure your PPM, AML/KYC policies, and reporting cadence meet regulator expectations.

At TAG Consultancy, our mission is to make fund formation and administration in Gibraltar efficient, transparent, and future-ready.

Contact us today to learn how TAG Consultancy can be your trusted partner in local fund administration.