GIBRALTAR Law and Practice Contributed by: Adrian Pilcher, Stuart Dalmedo and Louise Anne Turnock, ISOLAS LLP
• an auditor shall have a right of access at all times to the books and accounts and vouchers of the company; • an auditor shall be entitled to require from the directors and officers of the company any such information and explanation as may be necessary for the performance of the duties of the auditors; and • an auditor of the company shall be entitled to attend any general meetings of the company at which any accounts that have been examined or reported on by them are to be laid out before the company, and to make any statement or explana - tion they desire with respect to the accounts. 6.2 Risk Management and Internal Controls Under the Companies Act, the directors’ report must contain a description of the principal risks and uncer - tainties facing the company. In addition, it must also contain a description of the principal risks relating to the non-financial information discussed in 7.1 ESG Requirements arising in connection with the com - pany’s operations and, where relevant and propor - tionate: • a description of its business relationships, prod - ucts and services which are likely to cause adverse impacts on those areas of risk; and • a description of how it manages the principal risks.
The statement must also provide brief details of the company’s business model. 7.2 ESG Developments The most concrete ESG developments in Gibraltar are driven primarily by government policy rather than corporate regulation. Key developments include: • the 25-Year Environment Plan (2025); • reaffirmed climate commitments (net-zero ambi - tions, emissions reduction); and • incentives for renewable energy, green transport and sustainable buildings. These developments shape expectations, but do not impose direct corporate reporting duties outside regu - lated sectors.
8. Artificial Intelligence 8.1 Board Oversight of AI
Gibraltar does not currently have AI-specific legisla - tion or a dedicated regulatory regime equivalent to the EU AI Act. As of early 2026, there is no Gibraltar AI Act, no statutory board-level AI mandate, and no
mandatory AI committees. 8.2 AI Use-Related Risks
7. Environmental, Social and Governance 7.1 ESG Requirements
Gibraltar currently has no AI-specific legislation and no equivalent to the EU AI Act. AI-related risks are therefore governed indirectly through existing legal and regulatory frameworks, most notably: • the Companies Act 2014 (directors’ duties and oversight); • GFSC sectoral regulation (for regulated entities); • data protection and financial crime regimes; and • corporate governance frameworks developed for technology, distributed ledger technology (DLT) and outsourcing. 8.3 Liability Exposures Arising From AI Use Gibraltar has no AI-specific liability statute and no equivalent to the EU AI Act. Liability exposure for
Under the Companies Act, a large company (as defined in the Companies Act) which is a public-interest entity is required to issue a non-financial information state - ment within the directors’ report. The information required by the statement must include information relating to: • environmental matters (including the impact of the company’s business on the environment); • the company’s employees; • social matters;
• respect for human rights; and • anti-corruption and anti-bribery.
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