Gibraltar Customs Guarantees, T1GI/T2GI and Importer Cash Flow

Operational Update — 8 August 2026

Gibraltar’s new customs arrangements are now operating and, as businesses begin using the T1GI and T2GI transit procedures in practice, further detail is emerging around the financial guarantees required to support these movements.

Gibraltar.com has received information from a local importer showing that a customs representative in La Línea may require customers to provide advance financial cover before processing a T1GI or T2GI movement using the representative’s guarantee facility.

In the case reported to us, the financial cover requested could amount to approximately 21% of the value of the goods, with the funds intended to be released following successful completion and discharge of the customs transit.

The underlying requirement for an appropriate transit guarantee is part of the formal customs procedure. However, the requirement for an importer to provide cash or other collateral directly to a customs representative is a separate commercial arrangement and may vary between representatives.

For the wider import, customs-clearance, Transaction Tax and NIF/EORI process, see our Gibraltar Customs Clearance Guide.

This update explains the guarantee requirement, the reported deposit arrangements, the potential implications for Gibraltar importers and the current published position surrounding HM Government’s announced Global Guarantor.

Gibraltar T1GI and T2GI Customs Guarantee Requirements

Commercial movements between Spain and Gibraltar using the new T1GI and T2GI procedures must be appropriately guaranteed while the customs transit remains open.

Published Spanish Customs guidance places responsibility for the guarantee on the holder of the transit procedure.

The purpose of the guarantee is to protect against the potential tax liability that could arise if goods do not reach their declared destination or if the transit procedure is not completed and formally discharged.

Depending on the movement and status of the goods, this exposure may include Spanish VAT and excise liabilities, together with applicable Gibraltar Transaction Tax and excise liabilities.

The requirement for the customs transit to be guaranteed is therefore a formal part of the procedure.

Businesses should establish in advance who will act as holder of the transit procedure, whose guarantee will support the movement and what financial security will be required. Where appropriate, these arrangements should be confirmed with the customs representative or Freight Agents and Forwarders handling the movement.

Importer Deposits and Customs Representative Guarantees

The formal customs guarantee should be distinguished from any financial security requested from an importer by its customs representative.

A customs representative processing a T1GI or T2GI movement may use its own guarantee facility.

While that transit remains open, the representative may carry financial exposure if the movement is not correctly discharged or if a discrepancy or subsequent liability arises.

A representative may therefore require its customer to provide:

• advance funds;
• a refundable deposit;
• other financial security; or
• sufficient commercial cover

before agreeing to process the transit using its guarantee. This is the basis of the written notice supplied to Gibraltar.com by a Gibraltar importer.

The customs representative concerned states that this approach is being applied on a preventive and provisional basis while the practical operation of the new Gibraltar customs framework continues to develop.

Businesses should therefore confirm the guarantee, financial-security and clearance arrangements directly with the representative handling the movement before committing a consignment to transit.

Reported 21% Customs Deposit and How It May Be Calculated

In the case reported to Gibraltar.com, the importer was advised that the financial cover required could amount to approximately 21% of the value of the goods.

The figure is significant because 21% is the standard rate of Spanish VAT.

However, Gibraltar businesses should not assume that every customs guarantee or customer deposit will automatically equal 21% of the invoice value.

The amount required may depend on factors including:

• the customs value of the goods;
• transport and insurance costs;
• the customs status of the goods;
• potential VAT exposure;
• excise liabilities where applicable;
• Transaction Tax exposure; and
• the guarantee arrangements being used for the individual movement.

Gibraltar.com has not identified a published provision requiring every Gibraltar importer to pay a universal 21% cash deposit directly to its customs representative.

Businesses should therefore obtain the amount, calculation basis, charges and repayment arrangements in writing before dispatch.

Where the calculation could materially affect margins, landed cost or working capital, businesses should consider discussing the financial implications with an Accountant and, where specialist tax interpretation is required, a Tax Consultant.

Cash-Flow Implications for Gibraltar Importers

For occasional low-value consignments, the temporary provision of financial security may be manageable.

For businesses importing regularly or moving higher-value goods, the position could be considerably more significant.

If a customs representative requires financial cover for each transit and previous deposits remain outstanding until those movements are formally discharged, an importer could potentially have funds committed across several consignments at the same time.

For small and medium-sized businesses in particular, this can become more than an administrative customs issue. An unexpected requirement for substantial financial cover can affect:

• day-to-day working capital;
• supplier payments;
• stock purchasing;
• credit arrangements;
• margins and landed costs;
• the timing of subsequent orders; and
• the business’s ability to fund several consignments simultaneously.

Even where deposits are ultimately released in full, the period during which those funds are unavailable can be commercially important.

Businesses undertaking regular or higher-value imports should therefore model the potential cash-flow effect in advance rather than treating the guarantee solely as a clearance cost.

Customs Representatives and Guarantee Exposure

The guarantee issue is also significant for customs representatives operating in the Campo de Gibraltar.

Customs-sector representatives have raised concerns about the scale of the financial exposure that could arise from guaranteeing Gibraltar transit movements and about the extent to which customs agents should carry commercial risk on behalf of importers.

This provides important context for the introduction of customer deposits or other forms of financial security.

Individual customs representatives may adopt different commercial arrangements according to their guarantee capacity, customer relationships and assessment of risk.

Gibraltar importers should therefore compare guarantee arrangements as part of their overall customs and freight planning rather than assuming identical terms will apply across all providers.

HM Government’s Global Guarantor for Gibraltar Traders

Concerns over customs guarantees were identified before the new system became operational.

In April 2026, Gibraltar business organisations, including the Gibraltar Chamber of Commerce, Gibraltar Federation of Small Businesses and logistics representatives, sought further clarification on the proposed guarantee arrangements and their possible effect on businesses undertaking regular movements.

On 26 May 2026, HM Government announced measures intended to address those concerns.

Government specifically referred to:

“the establishment of a company acting as a Global Guarantor for all traders in Gibraltar”

with the stated intention of ensuring that guarantee requirements would not become a barrier to businesses participating in the new Treaty customs procedures.

The announcement represented an important commitment to addressing one of the practical financial issues identified by Gibraltar’s trading community.

Global Guarantor: Current Published Position

The Global Guarantor should not be confused with the comprehensive or global guarantees referred to within Spanish and EU customs legislation.

A comprehensive customs guarantee is an established customs mechanism that can cover multiple customs operations.

HM Government’s Global Guarantor is a separate Gibraltar initiative announced specifically to support Gibraltar traders.

As at 8 August 2026, detailed published operational information has not yet been identified by Gibraltar.com setting out:

• the entity providing the Global Guarantor facility;
• the date from which businesses can use it;
• eligibility requirements;
• the process for accessing the guarantee;
• the guarantee capacity available;
• whether collateral will be required;
• any fees or commercial charges;
• the treatment of T1GI and T2GI movements;
• how Spanish customs representatives will interact with the facility; or
• the precise liabilities that it will cover.

The Gibraltar Federation of Small Businesses previously noted that further detail was required on how the arrangement would operate in practice.

Spanish Customs has also continued to publish guidance dealing with the operation of T1GI and T2GI guarantees.

This includes a temporary administrative measure introduced on 1 July concerning the representation of guarantors in Gibraltar. The measure assists with the administration of qualifying guarantees but does not remove the underlying requirement for the transit movement itself to be guaranteed.

Gibraltar.com will continue to update this section as further operational information concerning the Global Guarantor becomes available.

Gibraltar Customs Guarantees: Practical Position for Businesses

The current position has three distinct elements:

The customs requirement:
T1GI and T2GI transit movements must have an appropriate guarantee.

The customs representative arrangement:
Where a representative uses its own guarantee, it may seek financial security from its customer to cover that exposure.

The Gibraltar Global Guarantor:
HM Government has announced a separate mechanism intended to help ensure guarantees do not become a barrier to Gibraltar traders. Further operational detail is required before businesses can determine precisely how it will interact with individual T1GI and T2GI movements.

These arrangements are not necessarily contradictory. They are different parts of a new customs framework that is continuing to settle into practical operation.

Professional Advice, Stock Planning and Working Capital

As the new customs system moves from published guidance into day-to-day operation, it is becoming increasingly important for businesses to consider not only the customs procedure itself, but the wider financial and operational implications of their import arrangements.

For a small or medium-sized business, a substantial unexpected deposit, an incorrectly calculated tax liability, a guarantee that remains open or a delay in releasing funds can have a critical effect on cash flow.

Businesses importing regularly may therefore need to reconsider aspects of their existing purchasing, stock and funding strategy, including:

• the level of stock normally held in Gibraltar;
• the size and frequency of individual orders;
• whether consignments should be consolidated or separated;
• supplier payment terms;
• the timing of repeat orders;
• available overdraft, credit or other working-capital facilities;
• the amount of liquidity retained within the business; and
• systems for monitoring outstanding guarantees and deposits.

There is unlikely to be one approach suitable for every importer.

Larger, less frequent consignments may create a greater single guarantee requirement, while smaller and more frequent movements could result in several guarantees or deposits being outstanding simultaneously.

Businesses should therefore consider their maximum potential cumulative exposure, rather than assessing the financial impact of one shipment in isolation.

This may require a broader review of stock levels, order cycles and existing borrowing facilities before a regular import pattern is established.

Accurate tracking may also become increasingly important.

Importers should consider maintaining a clear record of each T1GI or T2GI movement, including:

• the consignment or transit reference;
• the value of the goods;
• the guarantee or deposit provided;
• the date funds were provided;
• the date the transit was completed;
• confirmation of formal discharge;
• the amount due for release or refund; and
• the date the funds were actually returned.

This can help businesses identify overlapping financial exposure and follow up promptly where a transit has been discharged but the corresponding deposit has not yet been released.

The consequences of getting a movement, guarantee, tax calculation or contractual responsibility wrong may extend well beyond a delayed consignment.

Where the issue concerns contractual liability, the wording of a guarantee or indemnity, responsibility for non-discharge, recovery of a deposit or a dispute with another party, businesses may need advice from a Lawyer.

Professional advice does add cost to a transaction, but where the potential financial exposure is substantial, establishing the correct structure before goods move may be considerably less costly than resolving a problem afterwards.

Supporting Gibraltar’s Small and Medium-Sized Importers

The developing customs arrangements are also creating a potential need for a more joined-up advisory service for smaller businesses that may not have in-house finance, customs, logistics or procurement expertise.

Gibraltar.com would welcome contact from appropriately qualified professional advisers and service providers able to assist small and medium-sized Gibraltar businesses with the practical and financial implications of regular importing.

Relevant support could include:

• cash-flow modelling;
• stock and purchasing strategy;
• order-size and frequency planning;
• cumulative guarantee exposure;
• working-capital and finance requirements;
• accounting and tax implications;
• customs and freight coordination; and
• systems for tracking outstanding guarantees, discharge and release of deposits.

Providers should have relevant professional expertise and practical experience of supporting Gibraltar businesses.

Suitable services may be considered for inclusion within Gibraltar.com’s developing business information, professional-services and search-and-discovery routes.

Pre-Shipment Checklist for T1GI and T2GI Movements

Businesses should not wait until goods reach La Línea or another designated customs post to establish their guarantee arrangements.

Before goods are dispatched, confirm in writing:

1. Whether the movement will use T1GI or T2GI.
2. Who will act as holder of the transit procedure.
3. Who will prepare and lodge the transit declaration.
4. Whose customs guarantee will support the movement.
5. Whether the importer must provide a deposit, advance funds or another form of financial security.
6. The precise amount of that financial security.
7. How the amount has been calculated.
8. Whether transport and insurance costs are included.
9. Which VAT, Transaction Tax, excise or other potential liabilities are covered.
10. Whether any guarantee, administration, finance or processing charges apply.
11. What documentation must accompany the consignment.
12. Which customs post and route will be used.
13. What constitutes formal completion and discharge of the T1GI or T2GI.
14. How the importer will receive confirmation that discharge has taken place.
15. When any deposit or other financial security will be released or refunded.
16. What happens if discharge is delayed because of an administrative or systems issue.
17. Who carries the financial liability if there is an error, discrepancy or non-discharge.
18. Whether an alternative, comprehensive, account-based or continuing guarantee arrangement is available.

Businesses undertaking frequent movements should agree these arrangements before establishing their ongoing import structure and should consider the resulting customs, tax, accounting and working-capital implications in advance.

Gibraltar Customs Procedures Will Continue to Evolve

The new customs framework is now operating, but given the scale and complexity of the changes, its practical application will of necessity continue to evolve as Gibraltar businesses, customs representatives and the relevant authorities gain experience of the system.

At this early stage, it is simply not possible to predict every issue that will arise as the new rules are interpreted and implemented in day-to-day trading. Procedures may be refined, additional guidance may be issued and commercial practices may change as individual movements test how the new arrangements operate in practice.

Businesses will therefore need to remain vigilant, flexible and informed.

Keeping up to date should be regarded as an essential part of managing the transition, whether through Gibraltar.com, official Government and Customs information, professional advisers or other reliable sources.

Failure to keep informed carries two risks. Businesses may continue operating on the basis of procedures or assumptions that have changed, exposing themselves to avoidable delays, additional costs, financial liabilities or disruption to trade. Equally, they may fail to benefit from Government support, concessions, guarantee arrangements or other practical measures introduced to help businesses adapt where difficulties become apparent.

The Government-announced Global Guarantor is itself an example of the type of support mechanism that may develop as practical requirements become clearer.

Professional advice should therefore increasingly form part of prudent business planning. Where a change could affect customs liability, tax, guarantees, cash flow, contractual responsibility, stock management or the movement of goods, consulting the appropriate adviser before acting may prevent considerably greater cost later.

Mistakes can be expensive, but so can failing to recognise that the rules, procedures or available support have moved on.

The most effective approach during this transition is therefore to remain informed, review procedures regularly, maintain accurate records, retain sufficient flexibility within purchasing and cash-flow planning, and seek specialist advice where the financial, customs or legal implications justify it.

Gibraltar.com will continue to review:

• Spanish Customs guidance;
• HM Government and HM Customs updates;
• information from the Gibraltar Chamber of Commerce and GFSB;
• professional legal, tax and customs commentary;
• freight and customs-sector developments; and
• practical experience reported by Gibraltar businesses.

This page will be updated as material new information is verified.

Follow Gibraltar.com for Customs Updates

Gibraltar.com’s Customs guidance is being continually reviewed as the new arrangements develop in practice.

Important changes and additions will be announced on the Gibraltar.com Facebook page, including updates affecting:

• T1GI and T2GI procedures;
• customs guarantees;
• importer deposits and financial-security arrangements;
• HM Government’s Global Guarantor;
• Transaction Tax;
• NIF and EORI;
• customs representatives and freight procedures;
• documentation and declarations;
• customs clearance; and
• transit discharge.

Follow Gibraltar.com on Facebook to know when important Customs updates are added.

Share Your Gibraltar Customs Experience

Practical experience from Gibraltar businesses can help identify issues that may not yet be fully reflected in general published guidance.

If your business encounters a new customs requirement, guarantee arrangement, documentation issue, clearance procedure or other operational development that could affect Gibraltar traders, please contact the Gibraltar.com Editorial Team.

Relevant information will be researched and verified before being incorporated into Gibraltar.com’s published Customs guidance.

Sources and Further Information

This update has been prepared using current published information and guidance from:

• HM Government of Gibraltar;
• HM Customs Gibraltar;
• Agencia Estatal de Administración Tributaria — Spanish Tax Agency / Customs;
• Gibraltar Chamber of Commerce;
• Gibraltar Federation of Small Businesses;
• Gibraltar logistics and customs-sector representatives;
• Gibraltar legal and professional commentary;
• applicable EU customs provisions; and
• practical information supplied by businesses using the new customs arrangements.

Important Information and Professional Advice

Gibraltar.com researches and updates this content from official publications, professional sources and practical information supplied by businesses using the new arrangements. Customs procedures and their operational application are continuing to develop, and requirements may vary according to the origin, status and value of the goods, the transit route, the customs representative used and the circumstances of the individual transaction.

This guide is provided as general practical information only and is not a substitute for customs, tax, accounting, legal, financial or other professional advice. Businesses should confirm the requirements, costs, guarantee arrangements, responsibilities and potential financial exposure applying to each movement before goods are dispatched, and obtain appropriate professional advice where necessary.

This is particularly important for small and medium-sized businesses, where unexpected tax liabilities, substantial guarantee requirements, overlapping deposits or delays in the release of funds may have a material effect on working capital, stock purchasing and ongoing trading.