Citizenship by Merit: A New Path to Maltese Citizenship

In April 2025, the Court of Justice of the European Union (CJEU) ruled that Malta’s citizenship-by-investment framework was incompatible with EU law. The Court concluded that citizenship could not be granted through a system based primarily on predetermined financial contributions, describing such arrangements as a form of “commercialisation” of EU citizenship. As a result, Malta was required to bring its citizenship framework in line with the principles outlined in the judgment.

Following these developments, Malta introduced a new legal framework centred on merit rather than investment. Instead of focusing on an applicant’s financial contribution, the new route allows citizenship to be granted to individuals whose achievements, expertise or contributions are considered exceptional and of significant value to Malta or humanity.

The legal basis for this route is found in Article 10(9) of the Maltese Citizenship Act, which allows the Minister responsible for citizenship to grant naturalisation to foreign nationals who have rendered exceptional services or contributions to Malta or humanity, or whose naturalisation is considered to be of exceptional interest to the Republic of Malta.

This represents a significant shift in approach. The focus is no longer on investment thresholds or prescribed contributions, but on the individual, their achievements, and the value they may bring to Malta. Entrepreneurs, researchers, innovators, academics, athletes, artists and philanthropists may all potentially fall within scope, provided they can demonstrate a truly exceptional record of accomplishment and a meaningful connection to Malta.

Importantly, citizenship by merit is not a programme available to the general public and should not be viewed as a replacement for Malta’s former citizenship-by-investment route. Each application is assessed individually, with approval remaining entirely discretionary and subject to extensive due diligence and government review.

Who May Qualify for Citizenship by Merit?

While there is no definitive list of eligible professions or industries, the legislation and official guidance indicate that applicants are generally expected to demonstrate exceptional achievement or contribution in one or more recognised fields.

Potential candidates may include:

1. Science and Research (internationally recognised scientists, researchers, inventors, academics or medical professionals whose work contributes to scientific advancement, innovation, healthcare or public benefit).
2. Technology and Innovation (entrepreneurs, founders, engineers or technology leaders developing innovative solutions in areas such as artificial intelligence, cybersecurity, digital infrastructure, fintech, life sciences or emerging technologies).
3. Entrepreneurship and Job Creation (business founders and investors whose activities create employment, attract investment, transfer knowledge, strengthen key industries or contribute significantly to Malta’s economic development).
4. Sport (elite athletes, coaches and sports professionals whose achievements enhance Malta’s sporting profile or contribute to the development of local sporting talent and infrastructure).
5. Culture and the Arts (artists, performers, musicians, writers, filmmakers and cultural leaders whose work has achieved notable recognition or enriches Malta’s cultural landscape).
6. Philanthropy and Public Benefit (individuals with a proven record of charitable, humanitarian, educational or social impact initiatives that deliver measurable benefits to communities or society at large).
7. Education and Academic Excellence (educators, professors and academic leaders whose contributions to teaching, research or educational development are considered exceptional and of national importance).
8. Environmental and Sustainability Initiatives (individuals driving significant projects or innovations in environmental protection, renewable energy, climate action or sustainable development).
9. Exceptional Service to Malta (individuals who have rendered outstanding service to the Republic of Malta, its institutions, international standing, economic development or strategic interests).

The common denominator is not wealth, but merit. Applicants must demonstrate a genuine record of excellence, achievement or contribution that can be objectively verified through evidence and recognised by competent authorities.

Citizenship by Merit Is Not Citizenship by Investment

One of the most important distinctions to understand is that citizenship by merit is not a replacement for Malta’s former citizenship-by-investment framework.

There is:

• No prescribed investment amount.
• No mandatory contribution fund.
• No guaranteed approval.
• No automatic right to citizenship.
• No fast-track route based solely on wealth.

Instead, applicants are assessed on the quality and significance of their achievements, their contribution to Malta or humanity, their reputation, their future plans and the overall benefit their naturalisation may bring to the Republic of Malta.

The Importance of Due Diligence

As with other citizenship routes, due diligence plays a central role throughout the process. Malta places significant emphasis on integrity, transparency and reputation, meaning applicants should expect detailed checks into their personal, professional and financial background.

This scrutiny extends beyond criminal record checks. The authorities may review business interests, public reputation, source of wealth, regulatory compliance and any matters that could affect the applicant’s suitability for Maltese citizenship. A strong professional profile can be undermined if there are concerns regarding credibility, transparency or ethical conduct.

For this reason, applicants should ensure that all information provided is accurate, properly documented and capable of independent verification.

How to Apply for Malta Citizenship by Merit

Unlike other naturalisation routes, citizenship by merit does not begin with a standard application form. Instead, applicants must first submit a detailed proposal letter to Community Malta Agency outlining their achievements, contribution and the reasons why their naturalisation would be of exceptional interest to Malta.

The process generally involves:

Applicants are expected to provide substantial evidence supporting their achievements, reputation and contribution to Malta. Depending on the nature of the application, the authorities may request additional information, endorsements or documentation before reaching a final decision.

As citizenship by merit is entirely discretionary, there is no guarantee of approval, even where an applicant has an exceptional professional or personal background.

Timeline, Residency and Family Considerations

The process is not a quick one. From the initial proposal letter to the final Oath of Allegiance, applicants should generally expect the procedure to take a minimum twelve months, and often longer, depending on the complexity of the case and the pace of due diligence and Evaluation Board review. Unlike Malta’s former investment-based route, there is no fixed processing fee schedule published for citizenship by merit, as costs are assessed individually based on the due diligence required and the nature of the application.

A genuine connection to Malta is also a practical requirement, not just a formality. Before the formal naturalisation application can be submitted, applicants are expected to establish actual residence in Malta and demonstrate real ties to the country, which may include property, business activity or other forms of physical and economic presence. This is consistent with the underlying principle of the framework: citizenship is granted to those who intend to genuinely contribute to and engage with Malta, not simply hold a passport from a distance.

Family members are not automatically included in the same way they were under the former investment programme. Each case is reviewed individually, and while spouses and dependent children may, in certain circumstances, be considered as part of the same application or a related process, this is not guaranteed and depends on the specific merits of the case presented.

It is also worth noting that an unsuccessful application does not necessarily close the door permanently. Because each case is assessed on its individual facts, applicants who are initially refused may, in some circumstances, strengthen their proposal, provide additional evidence or wait until their professional circumstances have developed further before reapplying. The discretionary nature of the route means that a refusal reflects the strength of the case presented at that point in time, rather than a final judgment on the applicant’s eligibility going forward.

To better understand how the process works in practice, we invite you to read our interview with entrepreneur Alen Osman, who successfully obtained Maltese citizenship through the citizenship by merit route after an earlier unsuccessful application. His experience offers valuable insight into the level of preparation, persistence and evidence required when pursuing one of Malta’s most selective citizenship pathways.

If you would like to discuss your own circumstances or explore whether citizenship by merit may be a suitable option, our team is available to assist with an initial assessment and professional guidance throughout the process.