Apply for a Licence

Insurance Intermediaries


The purpose of this page is to make sure that the application process is fully understood.

This section sets out:

  • What are Insurance and Reinsurance Intermediaries?
  • What would this Licence allow you to do?
  • Guidance
  • Capital Requirements
  • What do you need to submit?

Insurance and Reinsurance Intermediaries

Insurance and Reinsurance Mediation refers to any activity involving the advising on, proposing or undertaking of preparatory work for entering into insurance contracts, including administration and performance of insurance contracts. Insurance intermediaries are brokers or agents who represent consumers in insurance transactions.

The licencing and regulation of these services fall within the scope of the Financial Services (Investment and Fiduciary Services) Act 1989 (the Act). All requirements for the licencing of Intermediaries can be found under the Financial Services (Licencing) Regulations 1991. Intermediaries should ensure that they comply with all subsidiary legislation to the Act.

What would this Licence allow you to do?

There are two types of licence you can apply for:

  • General/Non-Life Business
  • Life Business

For ancillary insurance intermediary applications contact

General/Non-Life Business

This encompasses a wide variety of insurance lines of business that include but is not limited to:

  • Motor Insurance
  • Household insurance
  • Marine Insurance
  • Commercial Insurance
  • Liability insurance

Life Business

This term is used for all forms of insurance cover that is linked to a person's life. These include:

  • Term Insurance: protects your dependants in the event of your death during a specified short period of time. The sum assured is payable only if death occurs within the defined period.
  • Whole Life: protection for your loved ones to ensure they receive a sum of money upon your death.
  • Endowment: protection with an element of savings because it not only pays your dependants upon your death but it also pays you a sum of money if you survive to a certain age.
  • Unit Linked: An investment policy with an element of insurance protection.


There are prescribed minimum requirements established under the Act as to the premises, capital, solvency, management, staff and resources which have to be attained in order to be licenced. Under the Act, Insurance and Reinsurance Intermediaries are required to have on a permanent basis;

  • Professional Indemnity Insurance covering the whole territory of the Union, guaranteeing against liability arising from professional negligence, for at least €1,250,000 (or sterling equivalent) applying to each claim and in aggregate €1,850,000 (or sterling equivalent) per year for all claims.
  • Ensuring that money paid by the policyholder to the Intermediary is treated as having already been paid to the Insurance Company, whereas money paid by the Insurance Company to the Intermediary is not treated as having been paid to the policyholder until the customer actually receives it.
  • Ensuring that policyholders’ money is only transferred via strictly segregated client accounts and that these accounts shall not be used to reimburse other creditors in the event of bankruptcy.
  • Ensuring they have adequate mechanisms for receiving and dealing with Complaints.
  • Life Insurance and Life  Reinsurance Intermediaries must comply with the GFSC’s Anti money laundering Guidance Notes.

Capital Requirements

An Insurance or Reinsurance Intermediary is required to hold an initial and ongoing capital of:

  • €18,750; or
  • 4% of the sum of annual premiums received or as projected at application,
    whichever is the greater.
  • Subject to the above, the GFSC will expect firms to hold a minimum level of financial resources equivalent to 3 months’ worth of operating expenses (or as projected at application).

Firms holding multiple licences may be required to hold the aggregate of the capital required for each licence prior to being permitted to conduct the proposed activity, and on an ongoing basis. The level of capital in these cases will be considered by the GFSC. It is advised that this is discussed with the GFSC ahead of the application.

What do you need to submit?

An application pack is required to be submitted with all the relevant documents.

An application will not be considered complete if there are any outstanding documents.

The application pack must consist of:

  • Application Fee
  • Application Form
  • Business Plan
  • Financial projections for the next 3 years
    • Profit and loss account
    • Balance sheet
    • Returns (these need to be on a quarterly basis for the first year and then annually for the following 2 years)
  • Individual Questionnaire (for each individual holding a notifiable position)
  • Body Corporate Questionnaire (for each entity holding a notifiable position)
  • Trust Questionnaire (if applicable)
  • Mapping assessment of how the application meets the relevant legislative threshold requirements (i.e. statutory/regulatory criteria for licensing under relevant Act/s)

Any other document that the applicant considers would be useful for the consideration of the application.

Business Plan

The business plan should clearly and comprehensively set out:

  • How the firm proposes to conduct activities
  • How the firm will ensure that consumers are protected and their suitable needs are met
  • An assessment of the firm’s main risks and how these are to be mitigated
  • The resources that are to be made available and the systems that the applicant intends to employ
  • How clients will be sourced
  • How records will be maintained
  • How, and by whom, any significant decisions will be made
  • Compliance with AML requirements (if applicable)
  • What reporting lines the firm will establish
  • Business Continuity Plan
  • If the applicant forms part of a larger group, details should be provided of the activities of the group and a description of its structure

The GFSC will be seeking evidence that the firm has considered the risk, compliance and operational issues associated with the proposed activities, as well as evidence that these have been documented and implemented.

Applicants should ensure that the business plan is coherent with the firm's risk appetite and capacity.

Applications can be sent to us via our Cloud. Contact to arrange issuance of credentials.

Application Forms

Should you get an error when opening any of the forms, please check the FAQ tab for guidance on how to override this.


Application Form

Documents referred to in the application form must be clearly referenced to help us process the application swiftly.


RGP Vetting Form

Please note that an 'Individual Questionnaire' or a 'Notifiable Document' MUST be accompanied by a Royal Gibraltar Police Vetting Application Form in accordance with Section 30C of the Proceeds of Crime Act 2015.  The form must be submitted to the Gibraltar Financial Services Commission, who will liaise with the RGP in order to make the relevant enquiries.

For any applicant that is not a Gibraltarian, or has not lived in Gibraltar for the last 10 years, in addition to the RGP vetting form, he/she must also provide the GFSC with a report of their criminal record from the relevant authority in the jurisdiction/s in which they have been ordinarily resident for the last 10 years and/or from any other jurisdiction where the applicant has spent a considerable amount of years resident in the past.  If the report is not in English, this must be accompanied by a translation from a certified Translator.


Notes for completion of the Royal Gibraltar Police Vetting Application Form:

1.     The RGP Vetting Form must be completed by the applicant in full. Should any section be incomplete, this cannot be accepted. 

Note that the section in the form that states ‘To be completed by agency or organisation requiring vet’ should be left blank as this section is to be completed by the GFSC only. 

2.     All RGP Vetting Forms MUST be submitted together with the applicable Individual Questionnaire or Notifiable Document to which it relates. 

Please note that all applications/fit and proper assessments will be kept on hold and not be processed until the original RGP Vetting Form and fee is submitted together with the applicable Individual Questionnaire or Notifiable Document. The same will apply to any incorrect forms submitted.

Should exceptional circumstances apply, please contact 

3.     The RGP and Individual Questionnaire or Notifiable Document cannot be accepted without any of the following:

a)    Payment of the £10 applicable fee by bank transfer only; and

In order to obtain the relevant bank details, please liaise with the member of staff at the GFSC who is processing the application and they will provide you with the required information. Should you be unsure of the contact details, then please refer your query to 

b)    APPLICATION Reference number. 

Please quote the following payment reference for any bank transfer:

For an individual: “RGPNAMEOFAPPLICANT” 

For payments to settle for more than one applicant: i.e. If the firm is submitting an application for five individuals, the reference should be as follows: “RGPNAMEOFFIRMX5” 

For any further queries, please contact and a member of staff will be happy to assist. 

 Individual Questionnaire
 Body Corporate Questionnaire

Body Corporate Questionnaire Warranty

A warranty signature page is required to be submitted with all applications. Please use the reference number quoted on the form.


Individual Questionnaire Directors Declaration

Directors declaration form is required to be signed and submitted with the individual questionnaires. Please use the reference number quoted on the form.


Individual Questionnaire Warranty

A warranty signature page is required to be submitted with all applications. Please use the reference number quoted on the form.

 Trust Questionnaire

Where a trust is proposed as part of the shareholding structure of an applicant, the FSC will need sight of a comprehensive explanation setting out the rationale for the use of such a vehicle within the structure.


Furthermore, the following is required to be submitted together with the Questionnaire


  1. Copy of the trust deed
  2. A written undertaking from the respective trustees to the effect that:
    • the provisions of the trust(s) in respect of beneficiaries, trustee(s) and terms of settlement are as contained in the relevant deed(s) dated [xxx],
    • the resignation of any trustee and, where appropriate, protector will be notified to the Commission forthwith,
    • no other trustee(s) or any additional or different protector(s) will be appointed, without the prior approval in writing of the Commission,
    • any proposed changes to the beneficiaries must be notified in writing to the Commission,
    • any proposed distribution or transfer for value or otherwise of any of the trust assets related to the applicant firm must receive the prior approval in writing of the Commission.
  3. Confirmation from the trustee(s) that they understand that failure to adhere to their undertaking may result in regulatory action against the applicant/regulated firm.

In addition to the Trust Questionnaire and the above listed information, the Applicant is also required to submit Individual Questionnaires for the settlor(s) and any named beneficiaries. This will not apply in cases where the beneficiary is a minor. In these cases, details of the individual will suffice i.e. name, DOB, address, nationality & passport number. When the trust is for example a discretionary family trust where not all beneficiaries are named (i.e. refers to spouse and children/issue of Mr X but does not actually name these individuals) a copy of the ‘letter of wishes’ of the Settlor, if any, will also be required.

In principle, the FSC does not favour the use of nominee shareholdings for the purposes of holding shares, directly or indirectly, in a regulated firm. The Commission will therefore require that the applicant submit a paper setting out the rationale for the use of these structures in each instance where this is being proposed. This should include comprehensive details as to why it is necessary to hold the shares in this way.


** All forms are accepted electronically so long as they are submitted from a valid email address pertaining to the firm **



 Insurance and Reinsurance Intermediaries Supervisory Returns

Application Fees

The application fee must accompany your application. Please note, if you are applying for more than one licence, aggregate fees will apply.

TypeNature of ApplicationApplication Fee
General Insurance IntermediaryApplication to be licensed£4,200
General Insurance IntermediaryApplication to extend permitted activities£2,000
Life Insurance IntermediariesApplication to be licensed£4,500
Life Insurance IntermediariesApplication to extend permitted activities£2,000

The annual fee is not payable until your application is approved. For details of these please refer to the current Fee Regulations.

Under the GFSC’s annual fee methodology you pay a minimum base fee which is dependent on the set fee block assigned to your regulated sector. In addition to the base fee, you are also required to pay an additional amount that will be calculated based upon a range of factors including activity and income. To calculate the additional part of your annual fee the GFSC will need to review audited financial data and/or supervisory returns. At licensing stage, you will not yet have the requisite audited financial data or supervisory returns available for the GFSC to calculate the additional part of your annual fee. On this basis, the GFSC will only require you to pay the base fee at this stage and, towards the end of the GFSC’s financial year end (31 March), you will then be invoiced for the remainder of the annual fee which will be calculated based upon the financial data and/or supervisory returns provided by you up until that date.

Details on the payment methods can be requested from the Accounts team.

Service Level Standards

The current service level standards are:

  • To provide initial feedback to an application within 5 weeks of a complete application being received.
  • Once all of the information has been received from an applicant and the application is therefore considered to be complete, we aim to provide an in principle decision within 4 weeks.

Please be advised that the above service level standards refer to the period of time in which the GFSC holds applications for consideration. Where we require further information or documents from an applicant the service level standards will be suspended until we receive the requested information. The period of time an application is pending because of factors outside the control of the GFSC will not be accounted for under the service level standards.

Please note that should we be unlikely to meet our SLS’s, we will advise you as soon as possible.

The purpose of this page is to set out:

  • What is an extension?
  • What do you need to submit?
  • Guidance

What is an extension?

Firms or individuals that are already licensed by the FSC may apply to extend their authorisation/licence to provide additional financial or professional services.

If you are seeking a licence, authorisation or registration under a separate Act, please contact the Authorisation team so that we can determine what documents you are required to submit.

What do you need to submit?

An application pack is required to be submitted with all the relevant documents.

An application will not be considered complete if there are any outstanding documents.

The application pack must consist of:

  • Application Fee (if applicable)
  • Revised Business Plan
  • Financial projections for the the next 3 years, clearly identifying the impact of the additional business
    • Profit and loss account
    • Balance sheet
    • Returns (these need to be on a quarterly basis for the first year and then annually for the following 2 years)
  • Individual Questionnaires (for any new individual holding a notifiable position)
  • Body Corporate Questionnaires (for any new entity within the structure)
  • Trust Questionnaire (if applicable)

Any other document the applicant considers the FSC should take into consideration as part of the application.


The licensee should consider and provide information on the following:

  • What new licence/authorisation it requires
  • The type of new business/activity
  • Where the business will be sourced
  • Resources to deal with the additional business
  • The impact of the additional business on its capital requirements
  • What changes are being effected to its systems and controls.