Act X of 2025 (the ‘Act’), enacted on the 16th of May, 2025, introduced changes to Malta's Corporate Service Providers (‘CSPs’) regime, especially for those offering directorship and company secretarial services – particularly Class B CSPs. This article summarises the main changes introduced by the Act.
Act X of 2025 (the ‘Act’), enacted on the 16th of May, 2025, introduced changes to Malta's Corporate Service Providers (‘CSPs’) regime, especially for those offering directorship and company secretarial services – particularly Class B CSPs. This article summarises the main changes introduced by the Act.
As noted by the Malta Financial Services Authority (‘MFSA’), the updates to the current Company Service Providers (‘CSPs’) regulatory framework with the introduction of the amendments to the Company Service Providers Act (Chapter 529 of the Laws of Malta) (the ‘CSP Act’), is part of an “ongoing initiative to enhance proportionality within the regulatory framework applicable” to such CSPs.
Under the newly introduced Article 3A of the CSP Act, individuals who wish to act as limited company service providers in Malta must now register with the MFSA. Limited CSPs (or ‘Registered Persons’), defined as those with ten or fewer involvements (i.e. acting as a director or company secretary), can register using the new form provided by the MFSA.
Pursuant to Article 3B(1) of the CSP Act, there is a notification requirement for Restricted Company Service Providers (or ‘Notified Persons’). These are defined as individuals who maintain up to five (5) involvements across no more than two (2) corporate groups, without presenting themselves as CSPs and thereby not providing their services ‘by way of business’. Restricted CSPs are required to submit this notification through the new form available on the MFSA’s LH Portal. Individuals currently operating as Restricted CSPs must notify the MFSA by 16 July 2025 to remain in compliance with the regulations.
Legal Notice 89 of 2025has amended the Company Service Providers Act (Fees) Regulations (S.L. 529.01 of the Laws of Malta),introducing notification fees, and revising certain existing fees.
Furthermore, Legal Notice 90 of 2025has amended the Company Service Providers (Exemption) Regulations (S.L. 529.02 of the Laws of Malta),expanding existing exemptions. Directors or company secretaries serving in the immediate holding company (holding at least 25%) of licensed entities are now exempt, offering more flexibility for group structures. Additionally, the exemption for Virtual Financial Asset Agents has been repealed following the repeal of the Virtual Financial Assets Act.
The existing Company Service Providers Rulebook (the ‘CSP Rulebook’) has been revised to incorporate amendments made to the CSP Act, thus accommodating the newly introduced classifications of Limited CSPs and Registered CSPs. Additionally, in consideration of these new categories, the definition of an Under Threshold Class B CSP has been modified, increasing the allowable aggregate involvements from no more than ten (10) involvements to no more than twenty (20) involvements. It has further been clarified that the CSP Rulebook does not apply to Limited CSPs.
A separate Rulebook Applicable to Limited Company Service Providers (the ‘Limited CSPs Rulebook’) has been issued by the MFSA. The Limited CSPs Rulebook has been specifically designed to address the limited scope of activities of this category of CSPs. It establishes obligations to ensure compliance in their service provision and to promote a thorough understanding of the risks involved.
The MFSA has revised its Guidance Note on the Application of the Company Service Providers Act, reflecting the abovementioned changes to the CSP Act. Most notably, the MFSA has provided a more detailed interpretation of the term “by way of business”, offering enhanced clarity for individuals uncertain about whether their activities fall within the scope of the Act.
The legislative reforms significantly enhance Malta's CSP framework, ensuring regulatory clarity, proportionality and governance within Malta’s corporate services sector. To ensure regulatory compliance, CSPs and corporate governance individuals should review their current structures and roles.
Should advice be needed on the Updated Maltese Corporate Services Laws, please contact us.
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