The Financial Services (DLT Providers and VAA Providers) Regulations 2020 are Gibraltar’s in-force regulatory framework for distributed ledger technology provider business and, following later amendments, virtual asset arrangement provider business. The consolidated instrument is identified as LN.2020/012, commenced on 15 January 2020, and is made under the Financial Services Act 2019. The current title reflects the 2025 amendments that changed the original title from Financial Services (Distributed Ledger Technology Providers) Regulations 2020 to Financial Services (DLT Providers and VAA Providers) Regulations 2020.
Scope of the Gibraltar DLT provider regulations
The regulations operate through Part 7 permission under the Financial Services Act 2019. The current text defines a DLT Provider as a person with Part 7 permission to carry out DLT Provider’s business and a VAA Provider as a person with Part 7 permission to carry out VAA Provider’s business. DLT Provider’s business is tied to paragraph 139 of Schedule 2 to the Act, while VAA Provider’s business is tied to paragraph 139A.
The 2025 regulated-activities amendment expanded the framework by making the provision of virtual asset arrangements a regulated activity. It describes that activity as, by way of business, exchanging or arranging the exchange of virtual assets for money, money for virtual assets, or one virtual asset for another. The amendment also provides exclusions for certain own-account dealing by collective investment schemes, pension funds, and related depositaries or managers.
Authorisation and GFSC supervision
An application for Part 7 permission to carry on DLT Provider’s business or VAA Provider’s business must be made in the form and manner directed by the Gibraltar Financial Services Commission, include the documents or information required by the GFSC, be accompanied by the prescribed fee, and comply with requirements imposed by the Act or the regulations.
The GFSC may not grant Part 7 permission unless satisfied that the applicant will comply with the regulatory principles. The regulator is also required to publish guidance on how it applies those principles, including criteria used to assess whether a person will comply, is complying, or has complied with them. GFSC materials list guidance notes for the principle areas, including customer care, resources, risk management, protection of client assets, systems and security access, financial crime, resilience, and market integrity.
Regulatory principles and ongoing obligations
The schedule sets out ten regulatory principles. They address honesty and integrity, fair and clear customer communications, adequate financial and non-financial resources, effective management and risk controls, customer asset and money protection, corporate governance, systems and security access standards, financial crime controls, orderly and solvent wind-down planning, and market integrity.
Relevant providers must comply with the regulatory principles on an ongoing basis. They must also promptly inform the GFSC of events they know or reasonably suspect may affect compliance with those principles. Auditors have a separate notification duty where matters identified during audit work are likely to be materially significant to fit-and-proper assessments or to the exercise of protective powers under the Financial Services Act 2019.
Regulatory powers, register, and dividend restriction
The regulations give the GFSC power to issue directions where it appears that a person is not fit and proper to carry out functions in relation to DLT Provider’s business or VAA Provider’s business. Administrative penalties for contraventions connected to the regulations are capped by reference to the benefit derived, a fixed monetary limit, or a turnover-based measure, depending on the person involved.
The GFSC Register must include at least a list of DLT Providers and a list of VAA Providers, and must include details of variations or cancellations of a relevant provider’s Part 7 permission. A 2026 amendment added a dividend non-objection mechanism: a relevant provider may make a dividend or comparable capital distribution only after notifying the GFSC and where the GFSC has not objected.
Status and timeline
As of 15 July 2026, the regulations are treated as in force in Gibraltar based on the current Laws of Gibraltar consolidated version last updated on 26 March 2026. The main historical milestones are the 15 January 2020 commencement, the April 2022 addition of the market integrity principle, the April 2025 application-process change, the October 2025 VAA provider amendments and transition rules, and the March 2026 dividend non-objection amendment.