Malta Citizenship by Merit

There is no capital threshold, and what matters is that the absence is now provable three ways rather than asserted in a sentence. First, read the substantive test, which sits in article 10(9) of the Maltese Citizenship Act.

Notwithstanding the provisions of that Act or any other Act, the Minister may grant a certificate of naturalisation by merit to an alien or stateless person.

Three groups are named: a person who renders exceptional services; a person who makes an exceptional contribution, including through job creation, to the Republic of Malta or to humanity; and a person whose naturalisation is of exceptional interest to the Republic of Malta.

That same article defines the three key terms, so nothing here needs to be inferred. "Exceptional" means manifestly superior or adding value.

"Exceptional services" and "exceptional contributions" refer to services rendered and contributions made by scientists, researchers, athletes, sports persons, artists, cultural performers, entrepreneurs, philanthropists and technologists, amongst other persons of interest to the Republic of Malta from time to time.

And "exceptional interest" refers to any person the Minister deems to possess the necessary skills, profile, qualities, talents and expertise considered to significantly advance or benefit the national interest of Malta.

Second, look at how the provisions that once carried money disappeared: in Subsidiary Legislation 188.06, regulation 21, entitled "Non-refundable fees and investment", was deleted by Legal Notice 159 of 2025.

Regulation 30, "Fees", was deleted; and the whole of part iv on naturalisation for exceptional services by direct investment — regulations 15, 16, 17, 18 and 19, where regulation 18 was "First five years" and regulation 19 "Maximum number of admissions" — was deleted by that same notice.

The threshold was therefore not left unpublished; it was removed from the instrument, and removed regulation by numbered regulation. Third, the text itself: the Regulations name no sum of money at all, in euro or in any other unit.

In place of a figure the framework sets up an endorsement mechanism:

A designated competent body, a locally registered entity in Malta designated by the Agency from time to time, capable of determining whether an individual is recognised in a particular field as a leading talent, or has demonstrated exceptional promise and is likely to become a leading talent.

The Third Schedule to the Regulations, which used to list those very bodies, has itself been deleted — so the list now sits with the Agency rather than in the text.

The outcome is Maltese citizenship, but what it is called is the most important part of this cell.

The Community Malta Agency, the entity responsible for the implementation of legislation relating to citizenship matters, states in terms that Citizenship by Merit is neither a programme, nor a scheme, pathway, continuation or alternative to Malta's former citizenship by investment framework.

That former framework was repealed following the judgment of the Court of Justice of the European Union of 29 April 2025.

On the nature of the decision the agency is explicit: decisions on the granting of citizenship by merit are discretionary, and applications are assessed strictly and diligently on a case-by-case basis.

One further sentence belongs with it: the agency states that it has become aware of social media posts and other forms of communication that inaccurately portray Citizenship by Merit, and that it does not permit any marketing or promotion of this legislation.

One point must be made plain about instrument numbers, because two notices from this same agency name two different instruments.

The notice of 5 February 2026, the source of this cell, says that following the judgment the pre-existing legislation, subsidiary legislation 188.04 of 2017, was publicly revisited through transparent statutory processes.

But the notice of 2 September 2025 from the same agency says that subsidiary legislation 188.06 was the instrument amended in order to provide for processes and requirements to regulate the granting of citizenship by naturalisation on the basis of merit, and points to three addresses:

Act XXI of 2025, Legal Notice 159 of 2025, and S.L. 188.06 as amended.

Opening that instrument confirms it. Its formal title is the Granting of Citizenship by Naturalisation on the basis of Merit Regulations, made by Legal Notice 437 of 2020 and substituted by Legal Notice 159 of 2025.

Its own regulation 2 states that its scope is to prescribe the requirements and to regulate the granting of citizenship under article 10(9) of the Act.

This table must therefore be read on two levels: the agency publishes no programme, while the legislation does publish requirements — which is why the remaining cells cite S.L. 188.06 and article 10(9).

The number 188.04 is not a typing slip in the February notice: it is the number of the former investment framework, and regulation 31 of S.L. 188.06, the repeal and savings provision that cross-referred to S.L. 188.03 and S.L. 188.04, was itself deleted by Legal Notice 159 of 2025.

The Regulations set no processing deadline for the Agency or the Minister, but they do fix a sequence and three countable clocks, so the real elapsed time is read off the sequence rather than off any published target. The sequence has two rounds and cannot be reordered.

Round one: the individual first submits a comprehensive proposal letter to the Evaluation Board through the Agency.

The Agency must be satisfied as to its completeness and, before passing it to the Board, must have four-tier or higher due diligence controls performed, have all information independently verified, ensure a risk assessment has been carried out, and request payment of non-refundable administrative fees.

The Board then evaluates and recommends; the Agency puts the recommendation to the Minister. The Minister approves or rejects and is not obliged to give any reason, the decision being final.

On approval the Agency issues a letter of approval in principle. Round two: only an applicant holding that letter is eligible to file the application for a certificate of naturalisation.

The Agency updates its due diligence and may request further documents and further fees. The Board evaluates again, and at this step the instrument says only that it shall be performed within a reasonable period, without naming days.

Then the Minister again, again with no reasons owed, again final.

Three countable clocks.

The first runs before the right to file arises: the eight months of residence that round two requires must fall wholly within the stretch immediately before the filing date.

The detail of that condition belongs to the residence cell, and what matters here is that a clock is already running while the person may not yet file anything at all.

The second is six months from the issuance of the letter of approval in which to take the oath of allegiance, extendable by the Minister in exceptional circumstances; the certificate issues only once the oath has been taken, and under article 10(9) of the Act the oath is taken in Malta.

The third is not a processing clock but a term of office, and should be flagged so it is not misread: the Chairperson and appointed panel members of the Evaluation Board hold office for three years and are eligible for reappointment — that is the term of those who decide, not the time taken to decide a file.

Two things can stop the clock outright. First, the Agency may suspend or terminate the process at any point before the Minister issues the certificate, if the applicant fails to satisfy all conditions or if the Minister is no longer satisfied that the applicant is worthy.

Second, a false statement or an omission of material information, by the applicant or by any dependant, may see the application suspended or treated as inadmissible.

There is a residence condition, and it is a number: the application for naturalisation must be accompanied by proof of residence in Malta for a period of at least eight months in the period preceding the date of application — regulation 11B(1)(a) of the Regulations.

It comes paired with an accommodation condition readers easily miss because it is not a money condition: the same subregulation, paragraph (b), requires proof of title to adequate residential property in Malta.

Two reliefs exist. An applicant who is a minor is excepted from the property condition.

And where the person who submitted the proposal letter is not the main applicant and is still a member of the household of his family, the Minister may waive the requirement if satisfied that the person is not in a position to purchase or take on lease such property.

Two further conditions sit in the same place and also concern tying oneself to Malta: a confirmation of adequate knowledge of Maltese or English, and proof of all other ties created with the Republic of Malta as at that stage, as proposed in the proposal letter.

The part that follows the grant is the heavy part, and it shows that citizenship on this route is not an end point.

Before taking the oath, the applicant must undertake and confirm in writing that he will continue to observe and fulfil all continuing obligations and such other commitments arising from his application, from the Regulations, or as stipulated by the Minister in the letter of approval.

The Agency is charged with ensuring the ongoing fulfilment of those commitments, and may request proof and make its own verifications.

The letter of approval may itself carry additional continuing obligations.

And regulation 24 empowers the Minister to deprive a person of Maltese citizenship granted under these Regulations in three cases:

Failure to comply with any material obligation or other commitment established by the Regulations or stipulated in the letter of approval; becoming a threat to national security; or involvement in conduct seriously prejudicial to the interests of the Republic of Malta.

The deprivation procedure then follows article 14 of the Maltese Citizenship Act.

There is a dependant regime, and it is defined in detail in regulation 3 of Subsidiary Legislation 188.06 rather than left open. Four classes.

First, the spouse in a monogamous marriage, or a partner in another relationship having the same or similar status to a monogamous marriage, including a civil union, domestic partnership or common law marriage.

The term "spouse" is construed as gender neutral, and the Minister retains discretion to authorise, case by case, other relationships of similar status.

Second, a child of the main applicant or of a first-class dependant, including an adopted child, who has not yet attained 18 years.

Third, a child who has attained 18 but has not yet attained 29 years, who is not married, and who proves to the satisfaction of the Minister that he is wholly maintained or otherwise largely supported by the main applicant — an eleven-year band few citizenship frameworks extend to.

Fourth, a child who has attained 18, is wholly maintained or otherwise largely supported, and is a qualified person with a disability as defined in the Equal Opportunities (Persons with Disability) Act; where such a child lacks legal capacity, article 21(3) of the Act applies.

One timing detail governs all four classes and matters more than it looks: age is fixed at the moment the main applicant submits a proposal letter which is accepted by the Agency, not at the round-two application — so a child close to an age limit has that limit held from round one.

Procedurally, for dependants under 18 the forms must be signed by both parents; where one parent has sole custody, or another person has legal guardianship, appropriate legal documentation must be produced showing that custody or guardianship was awarded by a court of law or other relevant authority.

And the heaviest point in this cell: all of the disqualification grounds that apply to the applicant apply equally to each dependant.

The first group covers having been indicted or arraigned before an International Criminal Court even where acquitted for any reason, being listed with Interpol or Europol, and being named in international sanctions.

The second covers having at any time been charged with or found guilty of terrorism, money laundering, funding of terrorism, crimes against humanity, war crimes, or crimes infringing the rights protected by the European Convention on Human Rights.

It also covers offences that disturb the good order of the family, and any criminal offence punishable with more than one year imprisonment other than an involuntary offence.

The last is having been denied a visa by a country with which Malta has visa-free travel arrangements. The file, in other words, travels only as far as its weakest member.

A person granted citizenship under this programme receives the Malta passport, so the figure in this cell is the figure for that passport itself.

According to the Passport Index of Prosperous Intelligence, on data dated 27 September 2026, the Malta passport reaches 202 destinations without applying for a consular visa in advance. The figure combines three forms of entry and does not count an e-Visa that must be obtained beforehand:

It is therefore a measure of how easily the holder travels, not a count of visa-free countries in the narrow sense.

For comparison, on the same source and the same method of counting, the Vietnamese passport reaches 43 destinations. The two lists of destinations do not nest inside one another, so the difference is an indication rather than a list of places newly opened.

Prosperous Intelligence dates its data and advises checking with the destination’s official authorities before travelling.

The Regulations set no tax regime and impose no tax obligation as a condition: S.L. 188.06 does not mention tax, and the instrument names no sum of money either.

That is consistent with the shape of the framework: a route whose test is contribution rather than a payment carries no tax regime to advertise.

But the text does mention the revenue authority, only in a provision on sharing information, and it points the opposite way from what readers tend to expect.

Regulation 27(3) provides that notwithstanding the other subregulations of that regulation or any other law, the Agency shall have the power to furnish information obtained by it for any of the purposes of these Regulations.

The recipients are the Commissioner for Revenue, the Financial Intelligence Analysis Unit, the Malta Financial Services Authority, the Malta Business Registry and the Commissioner of Police.

In this framework the tax authority is therefore a recipient of information about the file, not the grantor of a concession. Two accompanying provisions show how that flow is fenced.

Regulation 28 requires that all information obtained through the due diligence process and its sources be kept secret.

Regulation 29 allows any person to make a protected disclosure to the Agency, provided it is made in good faith, not for purposes of personal gain, and on the grounds of bribery, corrupt practices or improper practice of a main applicant or any dependant.

One limit of scope must be stated so nothing absent is added in: a person naturalised on this route becomes a Maltese citizen, so their tax position is thereafter governed by Malta's general tax law — which lies outside these Regulations and outside every publication the agency issues for this route.

There are fees, but there is no schedule of fees, and both are true for a very specific reason: the two provisions that once carried the schedule have been deleted.

Legal Notice 159 of 2025 deleted both: regulation 21, whose title was "Non-refundable fees and investment", and regulation 30, whose title was "Fees".

What replaced them is an open formula. The Agency requests the applicant to pay any applicable non-refundable administrative fees as may be established by the Agency from time to time, and such other fees as the case may be.

That request appears in both rounds, once at regulation 11A(2)(f) when the proposal letter is examined, and again at regulation 11B(2)(c) when the application is examined.

The instrument names no sum of money anywhere, in euro or in any other unit. The real cost, meaning the work the instrument requires to be paid for, is set out far more clearly.

Before the proposal letter reaches the Board, the Agency must cause due diligence controls of a four-tier nature or more to be performed, also by third parties, including one or more internationally recognised specialised due diligence service providers, in respect of the applicant and of each dependant.

Must have all information provided by the applicant verified by one or more independent due diligence service providers. Must have the background of the applicant and dependants verified; and must ensure an appropriate risk assessment has been carried out.

In round two all of that is updated rather than taken as done once. The documentary cost is specified to the same level of detail.

Every document must be an original or a certified true copy, certified by a duly warranted lawyer, a notary public, a commissioner for oaths, or a Maltese consular or diplomatic officer; the certifier must give full name, the capacity in which the person is acting, residential or business address, telephone number and email address.

A copy certified by a lawyer, notary public or commissioner for oaths must further be authenticated:

By an apostille under the Hague Convention of 5 October 1961 where the jurisdiction is a party to it; and where it is not, by a validation from the appropriate government department plus a validation by a Maltese consular or diplomatic representation.

Any document not in Maltese or English must be accompanied by an authenticated translation made by a recognised translator. And one outlay the Regulations require without pricing, set out in full in the residence cell: housing in Malta must be backed by documented title, so it is money to be arranged rather than a form to be filed.