Category 2 (Cat 2) and HEPSS are Gibraltar’s best-known specialist tax residency routes for high-net-worth individuals and senior executives.
Category 2 is generally aimed at high-net-worth individuals who do not intend to work locally, while HEPSS is designed for senior executives and specialists employed by qualifying Gibraltar companies. Both offer capped, more predictable tax exposure, but the eligibility rules, employment position, and application routes are different.
If you're purchasing ahead of a Category 2 application, our guide to buying property in Gibraltar without residency explains how ownership and the accommodation requirement fit together.
Category 2 Gibraltar & HEPSS — At a glance
- Category 2 tax position: assessable income capped at £118,000 per annum under the Allowance Based System.
- Category 2 annual tax liability: minimum £37,000, maximum £42,380.
- Category 2 government charges: £5,000 application fee (non-refundable) plus a £42,380 deposit, which is refundable.
- HEPSS tax position: gross assessable employment income capped at £160,000 per annum under the Gross Income Based System.
- HEPSS annual tax liability: £39,940 at current published rates.
- Best fit: Category 2 is generally for high-net-worth non-working residents; HEPSS is for senior executives working for qualifying Gibraltar employers.
- Both routes: require approved accommodation, formal approval, and ongoing compliance to keep the status.
Category 2 Gibraltar offers a minimum annual tax of £37,000 and a maximum of £42,380, with assessable income capped at £118,000. HEPSS offers a capped tax position on employment income up to £160,000, typically resulting in an annual liability of £39,940 at current rates.
2026 Category 2 Update: What the £5 Million Threshold Means
Gibraltar has increased the minimum net-worth requirement for new Category 2 applicants from £2 million to £5 million. The application fee has also increased from £1,233 to £5,000.
The change has attracted significant international media attention and prompted many prospective applicants to review whether they still qualify for Category 2 status. It does not mean Gibraltar has closed its doors to high-net-worth individuals. Rather, it positions the Category 2 route towards a smaller group of applicants who meet the revised financial threshold and wider eligibility requirements.
Existing Category 2 holders are fully grandfathered and are not affected by the new £5 million threshold. The Category 2 tax figures outlined in this guide remain unchanged by the announcement.
The 18 June 2026 changes also confirmed that a person who does not maintain Category 2 status will not have a right to continue to be resident in Gibraltar — making the ongoing conditions of the status, not just the application itself, worth planning around from the outset.
This guide is for general information only. Professional legal, tax and immigration advice should always be obtained for individual circumstances.
Category 2 and HEPSS sit within the wider process of moving to Gibraltar, alongside employment, retirement, and Gibraltar residency planning.
What Is Category 2 Gibraltar?
Category 2 and HEPSS are not the same thing. They are separate Gibraltar tax residency routes created for different applicant profiles.
Category 2 is generally intended for high-net-worth individuals who establish residence in Gibraltar and want a predictable, capped personal tax exposure, while not taking up ordinary local employment.
What Is HEPSS in Gibraltar?
HEPSS (High Executive Possessing Specialist Skills) is a Gibraltar tax status designed for senior executives or specialists employed by qualifying Gibraltar companies, with a capped tax exposure on employment income.
In simple terms, Category 2 is usually the route associated with private wealth and lifestyle relocation, while HEPSS is linked to executive employment in Gibraltar.
Category 2 Gibraltar Requirements (2026)
Category 2 status is generally intended for high-net-worth individuals establishing Gibraltar as their principal place of residence. The commonly referenced requirements include the following:
Eligibility Criteria
- Minimum net worth of £5 million for new applicants (raised from £2 million on 18 June 2026; existing Category 2 holders are grandfathered on the previous threshold), commonly referenced excluding Gibraltar property
- Approved accommodation in Gibraltar, whether by purchase or rental
- No Gibraltar residence in the preceding 5 years
- No ordinary local employment in Gibraltar, although investment activity may be permitted subject to the rules and approval
- The conditions continue for as long as the certificate is held — under the June 2026 changes, a person who does not maintain Category 2 status will not have a right to continue to be resident in Gibraltar
Official Government update: On 18 June 2026 the Government of Gibraltar confirmed the increase in the minimum net-worth requirement for new Category 2 applicants to £5 million, together with a revised application fee of £5,000. Existing Category 2 holders remain fully grandfathered under the previous rules. Further details are available from the Government of Gibraltar.
Minimum Tax for Category 2 Gibraltar
The point most applicants search for first is usually the tax position.
Under the current published position, Category 2 individuals are taxed under the Allowance Based System (ABS), with assessable income capped at £118,000 per annum.
- Minimum annual tax liability: £37,000, accruing at £3,083.33 for each complete or part month the certificate is in force
- Maximum annual tax liability: £42,380
This is one of the main reasons Category 2 continues to attract internationally mobile individuals seeking more predictable personal tax exposure.
Beyond the tax itself, Category 2 also carries government charges to budget for: a £5,000 non-refundable application fee, and a £42,380 refundable deposit payable on application.
Gibraltar is also generally known for having no capital gains tax and no estate duty, based on Gibraltar government information. Broader tax planning, however, still depends on residence, source of income, and interaction with other jurisdictions. A Category 2 certificate does not, of itself, prevent you becoming tax resident in another country, so cross-border positions need their own advice.
For a broader understanding of how these caps sit within the overall framework, see our Gibraltar tax system guide.
Category 2 and the Residency Regulations 2026
The Residency Regulations 2026 came into operation on 14 July 2026, introducing a new portal-based residence process for Gibraltar generally, run through the Government's Residency Portal. How Category 2 applications will be routed through this new portal has not yet been officially detailed, and the underlying Category 2 framework — the Qualifying (Category 2) Individuals Rules 2004 — is unaffected by it.
In practice, this means the eligibility criteria and tax figures set out above remain the reference point, while the procedural side of submitting an application is confirmed with the authorities at the time of application. Applicants should expect this detail to be clarified as the new regime beds in.
HEPSS Gibraltar: Requirements and Tax Position
HEPSS is designed for executives and specialists employed by qualifying Gibraltar companies. Unlike Category 2, employment is central to the structure.
Key Requirements
- Senior management or technical position
- Skills considered essential to the company’s operations
- Employment contract with a qualifying Gibraltar company
- Approved accommodation and formal status approval
Tax Benefits (Current Position)
- HEPSS individuals are taxed under the Gross Income Based System (GIBS)
- Gross assessable employment income covered by the HEPSS certificate is capped at £160,000 per annum
- Annual total tax liability: £39,940 at current published rates
- Relocation and benefits packages may apply, depending on employer policy and taxation treatment
HEPSS is therefore usually relevant where a business is bringing a senior executive or specialist to Gibraltar, rather than for a private wealth relocation without local employment.
Cat 2 vs HEPSS: Key Differences
| Feature | Category 2 Status | HEPSS Status |
|---|---|---|
| Target applicant | High-net-worth individuals | Senior executives / specialists |
| Employment in Gibraltar | Not generally permitted | Required with qualifying employer |
| Assessable income cap | £118,000 | £160,000 |
| Tax liability | Minimum £37,000 / Maximum £42,380 | £39,940 annual total tax liability |
| Government charges | £5,000 application fee (non-refundable) + £42,380 deposit (refundable) | Not applicable |
| Main use case | Private wealth and lifestyle relocation | Executive employment relocation |
Which Route Is Better: Category 2 or HEPSS?
Category 2 is usually the better fit where the applicant is relocating private wealth, does not intend to take up ordinary local employment, and wants a capped, more predictable personal tax outcome.
HEPSS is usually the better fit where the move to Gibraltar is driven by a senior executive or specialist employment role with a qualifying company.
For many applicants, the correct route depends less on preference and more on facts: wealth profile, employment plans, accommodation, family structure, and tax residence elsewhere.
How to Apply for Category 2 Status in Gibraltar
- Review whether Category 2 or HEPSS is the appropriate route for your circumstances
- Prepare financial, identity, and supporting eligibility documents
- Secure approved accommodation in Gibraltar
- Submit the application through an authorised adviser or agent, together with the application fee and refundable deposit
- Await decision and complete any follow-up compliance requirements, including maintaining the conditions each year the status is held
Timelines vary depending on the route, documentation, and the specifics of the application.
Looking for Category 2-approved accommodation?
Securing approved accommodation in Gibraltar is an important part of the Category 2 application process. Applicants may purchase or rent, provided the property is suitable and approved for their residency arrangements.
With the revised Category 2 framework attracting renewed international attention, our team can help prospective residents identify appropriate accommodation based on their preferred location, lifestyle and property requirements.
Browse our current Category 2-eligible properties for sale or explore available Category 2-eligible properties for rent across Gibraltar.
Application support, alongside your accommodation search
We work alongside Ed le Feuvre, Director at Cornwalls Lane Services Limited, a Gibraltar-licensed trust and company services provider, on the application side of Category 2: eligibility review, the net-worth evidence pack, and submission through to certificate. We handle the accommodation search that has to be in place before the application can progress.
If you're weighing up Category 2 alongside the employment route, or want the practical sequence explained in full, our team can put you in touch.
Frequently Asked Questions
Has Gibraltar closed the door on millionaires below £5 million?
No. Recent changes relate specifically to the Category 2 High Net Worth Individual (HNWI) residency route. Gibraltar has increased the minimum net-worth requirement for new Category 2 applicants from £2 million to £5 million. This change applies specifically to the Category 2 high-net-worth tax residency route and does not mean that every person wishing to live in Gibraltar must have a net worth of £5 million. Existing Category 2 holders are grandfathered and unaffected, while other residency routes may remain available depending on the applicant’s employment, nationality, financial position and personal circumstances.
What is the minimum net worth for Category 2 status in Gibraltar?
From 18 June 2026, new applicants must demonstrate a minimum net worth of £5 million (increased from £2 million), commonly referenced excluding Gibraltar property. Existing Category 2 holders are fully grandfathered on the previous £2 million threshold.
What is the minimum tax for Category 2 Gibraltar?
Under the current published position, the minimum annual tax liability for Category 2 is £37,000, with a maximum of £42,380, and assessable income capped at £118,000.
Is there a deposit for Category 2 status, on top of the application fee?
Yes. Alongside the £5,000 non-refundable application fee, applicants also pay a £42,380 deposit, which is refundable. Both are government charges, separate from any professional fees for application support.
What happens if I don't maintain Category 2 status once granted?
Under the changes confirmed on 18 June 2026, a person who does not maintain their Category 2 status — for example, by no longer meeting the accommodation or tax conditions — will not have a right to continue to be resident in Gibraltar. The conditions of the status apply for as long as the certificate is held, not just at the point of application.
How do you apply for Category 2 status in Gibraltar?
You generally apply through an authorised adviser or agent, prepare identity and financial documents, secure approved accommodation in Gibraltar, and submit the application for formal approval. Timelines vary depending on the complexity of the case.
Can I work in Gibraltar with Category 2 status?
Category 2 is generally intended for individuals who do not take up ordinary local employment in Gibraltar, although investment activity may be permitted subject to the rules and approval.
What does HEPSS mean in Gibraltar?
HEPSS stands for High Executive Possessing Specialist Skills. It is a Gibraltar tax status designed for senior executives or specialists employed by qualifying Gibraltar companies.
Can HEPSS applicants bring family members?
Immediate family members, including a spouse and dependent children, can generally be included in both Category 2 and HEPSS applications, subject to the applicable requirements.
Speak to Century 21 Gibraltar
Where approved accommodation is part of the wider relocation plan, our team can help you identify suitable property options and guide you through the practical side of relocating to Gibraltar.
Author: Century 21 Gibraltar
Information correct at time of publication. Professional advice should always be obtained.
