John Gill: Titus 3:5 does not teach baptismal regeneration

"...by the washing of regeneration, and renewing of the Holy Ghost; by the former is meant, not the ordinance of water baptism; for that is never expressed by washing, nor is it the cause or means of regeneration; the cause being the Spirit of God, and the means the word of God: and besides, persons ought to be regenerated before they are baptized; and they may be baptized, and yet not regenerated, as Simon Magus; nor is it a saving ordinance, or a point of salvation; nor can it be opposed to works of righteousness, as this washing is; for that itself is a work of righteousness; see Matthew 3:15 and if persons were saved by that, they would be saved by a work of righteousness, contrary to the text itself: but regenerating grace is meant, or a being born of water, and of the Spirit; that is, of the grace of the Spirit, comparable to water for its purity and cleansing virtue: hence such who are regenerated and sanctified, are said to be washed and cleansed, having their hearts purified by faith, and their consciences purged from sin by the blood of Christ..." (John Gill, Exposition of the Old and New Testaments)