Euphrasia gibbsiae is one of the most widespread and common of the Euphrasia species. It is common in open alpine and subalpine places, but also occurs as a lowland plant in sedgeland near the south-west coast. The foliage ranges from quite glossy green to very hairy. It has typical eyebright leaves and flowers, but the leaves are closely packed in four obvious rows. Several varieties have been described, including plants that were previously described as E. kingii.