Message from the Chairman


This is my second report as Chair of the GIA, and looking back on events since my last report it has been a busy and eventful year.

In the motor market we have seen an unprecedented level of pricing activity as insurers have put through price increases to combat inflationary pressures arising from increasing energy costs, parts costs and credit hire costs, this has been compounded by a noticeable change in the availability of underwriting capacity in a backdrop of rising reinsurance costs. Some market reports have highlighted motor pricing continuing to remain at record highs in Q4 2023 with average motor insurance costs increasing by anywhere between 25% and 58% in the last year depending on which report you read. With Gibraltar insurers, based on 2022 SFCRs, accounting for circa £5.7billion of motor premiums, 2023 should see another year of growth in premiums for Gibraltar underwriters.

During 2023, two new insurers were established as One Insurance Limited re-domiciled to Gibraltar and UWI Limited was authorised and became the first new insurance licence to be issued since 2020 and of equal importance represented a diversification away from motor insurance that accounts for approximately 80% of gross written premiums underwritten in Gibraltar.

We continue to work closely with the GFSC as the jurisdiction looks for closer regulatory alignment with the UK in the run up to the UK implementation of the Gibraltar Authorisations Regime. The aim of this process is to achieve what is referred to as equivalence of outcomes. Most notably we have seen the implementation of local Consumer Duty Regulations which seeks to align Gibraltar’s Consumer Duty regime to that of the UK, along with Guidance Notes in the areas of Operational Resilience, Outsourcing & Third-Party Risk Management and Liquidity Risk Management that are largely consistent the UK supervisory approaches.

As an association, the GIA Executive will continue to work closely with the Gibraltar Finance Centre Council to engage with Government and the GFSC, with the aim of making sure Gibraltar is aligned with the UK whilst continuing to have a proportionate and pragmatic approach that promotes a business-friendly environment for existing and new firms, whilst maintaining a high standard of regulation and policyholder protection.

In October the Gibraltar Day London Insurance Breakfast was hosted in the City of London. I am pleased to report that the event was well attended by over 140 insurance professionals, a significant increase over prior year attendance.

I am pleased to report that following recent discussions with the Director of General Insurance Policy at the ABI, we continue to explore the possibility of the Gibraltar Insurance Association entering into a Memorandum of Understanding with the ABI as a way of opening up engagement and participation between the ABI and the GIA membership.

Paul Cole
16 February 2024


Following the New Year’s Eve agreement announced in 2020, discussions continue in respect of a Treaty agreement between the EU and the UK in respect of Gibraltar, with target dates for an agreement not yet announced but seemingly closer. Despite the uncertainty around future border arrangements the number of frontier workers, accordingly to HM GoG published statistics, has remained largely unchanged in 2023 at 15,000 of which 10,000 are Spanish nationals, but notably the number of British nationals crossing the border to work has fallen by 7% in the last year. Such uncertainties will continue to exacerbate challenges within the local employment market where the availability of suitably qualified and experienced staff to meet the increasing regulatory requirements for local substance remains a challenge.

Regulation and Legislation

As expected, regulatory alignment remains high on the agenda in the run-up to implementation of the GAR.

In the last year the GIA, in conjunction of the GFCC, have worked hard with the GFSC to ensure Guidance Notes were published in respect of Section 83(a) of the Financial Services Act in order to provide some clarity to Boards as to how this section of the regulation will operate in practice in a manner that is not too cumbersome for stakeholders. Both the GIA and the GFSC will monitor how this works in practice and whether further changes/additional guidance may be needed.

Consumer duty will be an ongoing and growing area of focus for firms, with firms having to have been compliant with the Duty in July 2023 for open products and for closed products by July this year. Alongside this Operational Resilience regulations came into effect in 2023 in the UK and will come into effect in Gibraltar in 2025.

During 2022, there was much engagement with the GFSC in respect of the interpretation of when premium debtors fell due and how counterparty default charges would be applied in such circumstances. The view of the GFSC appeared to differ to the approach being adopted in the UK. I am pleased to report that the outcome of our discussions was a local approach that was both risk based and pragmatic. An example of Gibraltar leading the way.

This report would not be complete without mention of Gibraltar being placed onto the FATF Grey List. At the time of writing, it has been confirmed by the FATF President that Gibraltar has satisfied it’s action plan and we now await the outcome of the Plenary session that is scheduled to take place 21-23 February 2024 to see if Gibraltar will be removed from the Grey list.

Consistent with the theme of regulatory alignment, on 31 December 2023 the Financial Services (Insurance and Reinsurance) (Prudential Requirements) Regulations 2023 came into operation, with these regulations amending the risk margin calculations for insurers to reduce the cost of capital from 6% to 4%. This was following similar changes that had been made to the UK regulations. On behalf of the GIA I would like to thank both the Government of Gibraltar and the GFSC for their support in making these changes in a relatively short time frame.

I am pleased to see engagement with the recently elected Minister for Justice, Trade & Industry, the Honourable Nigel Feetham KC MP, who has been a key stakeholder and individual within the insurance sector for many years prior to his appointment. Most recently, key stakeholders have engaged with the Minister as he seeks to implement a Dual Captive regime to increase the jurisdiction’s appeal for Captive insurers.

Insurance Management

Gibraltar continues to have an insurance manager regime. Whilst the regulatory focus on local substance and the legislative change around the regulated individuals requirements can be seen as a challenge for the insurance management sector, the regulator remains supportive and continues to allow firms to outsource certain functions and roles. There are numerous firms that continue to adopt an insurance manager model.

Given the difficulty in attracting experienced insurance professionals to the jurisdiction the outsourcing model of an insurance manager remains important particularly if the sector wishes to grow. Insurance managers will continue to be the primary source of new business opportunities for Gibraltar given their understanding of process and practice. In addition to on-going management, the insurance manager remains a key advisor in helping new firms establish in Gibraltar evidenced by activity in 2023, where both companies that set up in the jurisdiction used and continue to use the services of local insurance managers.


As with insurance companies, intermediaries also face the challenges of consumer duty and the requirements to protect vulnerable customers. Previously, the Government has sought to make Gibraltar more attractive to MGA’s looking to set up, by allowing such firms to use the services of an insurance manager. To date no new MGA’s have set up in Gibraltar. Given the headwinds facing the insurance sector alongside rising reinsurance costs, the MGA model appears to remain challenged as we move into 2024, especially given available underwriting capacity.

Membership and Finances

An update with be provided by the Treasurer during the AGM.


Last but not least, once again I would like to thank everyone within the GIA, including members of the executive, sub-committees and wider membership for their contribution and support.