Estonia and Gibraltar prepare to rival Malta through fresh iGaming rules

While the European iGaming landscape is often defined by tightening regulations and rising taxes, two jurisdictions are making bold, strategic plays to capture a larger share of the global market. Estonia is betting on a radical tax-cutting agenda to lure operators, while Gibraltar is completing a comprehensive regulatory overhaul to cement its reputation for quality.

Both moves are a direct challenge to the established hegemony of hubs like Malta, signalling a significant shift in the competitive dynamics of the industry.

Estonia’s calculated tax gamble 

In a contrarian move, Estonia’s government, led by the ruling coalition of the Reform Party and Eesti 200, is preparing to roll the dice on a bold economic strategy: slashing gambling taxes to transform the Baltic nation into a global iGaming magnet.

Lawmakers in Tallinn are drafting a bill that would gradually lower the Remote Gambling Tax by half a percent annually, reaching a highly competitive 4 per cent by 2028. This would position Estonia with one of the lowest gambling tax rates in the EU – a clear invitation for operators seeking a new, fiscally attractive base in a post-Brexit Europe.

Supporters envision Estonia carving out a niche akin to Malta’s, arguing that reduced tax pressure will draw companies away from higher-tax jurisdictions like Spain and France, funnelling corporate profits and high-value jobs into the Estonian economy.

Crucially, the government is linking this initiative to national priorities to counter criticism. A portion of the future tax income is earmarked for a national sports infrastructure fund, a long-held goal of the Estonian Olympic Committee. Another mechanism would blend gambling-derived donations with government and private sponsorship for large-scale cultural and sporting projects.

However, the plan faces scepticism. The opposition Centre Party questions the underlying economic modelling, pointing out the lack of independent analysis to prove the tax cuts will trigger the envisioned influx of operators. Concerns also linger about tethering public projects to an industry known for its volatility and social footprint, especially after Estonia itself enacted strict rules banning high-risk marketing tactics.

For Prime Minister Kaja Kallas, it seems the the move is a test of Estonia’s economic model, a bet that a lighter tax burden and digital-first reputation can draw the world’s online casinos to Tallinn.

Gibraltar’s new era: the 2025 Gambling Act 

While Estonia looks to compete on price, Gibraltar is doubling down on its premium, credibility-focused brand. The introduction of the Gambling Act 2025 marks the most biggest regulatory reform in two decades, designed to modernise the territory’s framework and solidify its status as a top-tier hub after its recent removal from the EU’s list of high-risk jurisdictions.

Effective from 1st October 2025, the new act replaces the 2005 legislation and introduces a suite of measures aimed at increasing compliance and awarding the regulator with enhanced powers.

Key innovations include: 

1. Substantive presence requirements: A direct move to eliminate “brass plate” operations. Licensees cannot just use Gibraltar as a mere address but must now demonstrate real economic substance in Gibraltar through local staff, offices, and infrastructure.
   
2. Expanded licensing perimeter: Distinct licences are now required for B2C, B2B, and “Gaming Operator Support Services,” bringing activities like marketing, CRM, and managed trading directly under regulatory scope.
   
3. Approved persons regime: Most pressingly, the new rules call for more accountability. Mirroring the UK’s system, senior decision-makers now face personal vetting and licensing, enhancing individual accountability.
   
4. A new gambling appeals tribunal: This independent body adds a layer of oversight and fairness, allowing for appeals against the Gambling Commissioner’s decisions.

The act has been broadly welcomed as a necessary evolution.

“Gibraltar had to double down on reputation and substance after Brexit, and the new act is designed to do exactly that,” says Victoria Reed, founder of regulatory consultancy Better Change.

That being said, stakeholders have flagged areas requiring clarification. Uncertainty remains around the precise boundaries of the new licensing categories, particularly for marketing activities conducted “in or from Gibraltar” and for intra-group support services. As Steven Caetano, partner at Isolas law firm, notes, “some hybrid or cross-border models may require further guidance.”

With the iGaming sector contributing 20 per cent of Gibraltar’s GDP and employing over 3,200 people, the message is clear. 

As Andrew Lyman, head of the Gambling Division, stated, “If we drive business away, it will be business we don’t want.” 

The territory is betting that enhanced credibility, not just more convenience, will ensure its future prosperity.

The new competitive landscape

The simultaneous moves by Estonia and Gibraltar create a fascinating dichotomy for operators considering their European footing. Estonia offers a low-tax, growth-oriented model, while Gibraltar provides a robust, high-compliance environment for established, reputable brands.

Both strategies present a clear challenge to Malta, which has long dominated as Europe’s iGaming capital. Malta’s own indusrty accounts for around 7 per cent of the country’s GDP, generating €1.37 billion in gross value added in 2024, according to the Malta Gaming Authority. The island employs some 18,000 people in Gaming.

The industry is now presented with a wider spectrum of choices: the aggressive fiscal appeal of Estonia, the reinforced premium standing of Gibraltar, or the established flexibility of Malta.

For operators, this jurisdictional competition is a welcome development, offering more tailored options for their business models and risk appetites. 

The race to be Europe’s premier iGaming hub has just intensified.