Den Maltas myndighed for finansielle tjenesteydelser (MFSA) has announced updates to the regulatory framework governing Company Service Providers (CSPs), specifically concerning individuals providing directorship and company secretary services. These changes follow a public consultation and aim to enhance oversight while maintaining a proportionate regulatory approach.
The deadline for the MFSA Notification for Certain Company Service Providers is July 16, 2025
MFSA introduces Comprehensive Reform to Align with International Standards
In 2019, the MFSA launched a comprehensive reform of the CSP sector to align with international standards set by bodies such as FATF og MONEYVAL. The reform eliminated various exemptions, bringing professionals such as lawyers and accountants under the scope of CSP regulation. These measures were designed to improve governance, risk management, and the overall integrity of Malta’s financial system.
New Notification Requirement
Under the revised framework, individuals acting as directors or company secretaries for no more than two entities must now submit a notification to the MFSA. This change addresses a regulatory gap and enables the Authority to conduct risk assessments and adopt any necessary mitigating measures.
Notifications must be submitted by 16 July 2025 via the MFSA’s dedicated portal: www.mfsa.mt/notifications.
Streamlined Process for Limited CSPs
The MFSA has also introduced a simplified regime for individuals offering CSP services to a limited number of clients (not exceeding ten involvements). For this category, certain application requirements have been relaxed, and a single annual return will be accepted to meet the reporting obligations of both the MFSA and the Financial Intelligence Analysis Unit (FIAU).
Clarification on Definition of a Serviced Offices under CPS Framework
Entities operating serviced offices or business centres are advised to consider their obligations under the CSP framework. Where the service provided is limited to office leasing, and remuneration is restricted to rent as stipulated in the lease agreement, no CSP authorisation is required.
However, where additional services such as mail handling (including opening correspondence), reception, or telephone answering are provided, this will constitute CSP activity, and the relevant authorisation must be obtained.
Who is Exempt?
Under the Exemption Regulations, the following are not required to obtain authorisation, register, or submit a notification under the Act:
- Individuals authorised to act as trustees or fiduciaries under the Trusts and Trustees Act;
- Individuals acting solely as director or company secretary for companies licensed or registered by the MFSA or a recognised overseas regulatory authority, including their holding companies;
- Individuals acting solely as director or secretary for companies listed on a regulated market in Malta or an equivalent overseas market.
In addition to the above, individuals are not required to submit a notification in the following scenarios:
- Where the role of director or company secretary is undertaken pursuant to a contract of employment;
- Where the individual holds a beneficial interest in the company in which they serve as director or secretary;
- Where the individual’s appointment arises exclusively due to a family relationship.
If none of the above exemptions apply, individuals holding directorships or company secretary roles are required to submit a notification to the MFSA by the stated deadline. This obligation forms part of the Authority’s broader efforts to strengthen oversight and ensure transparency within the sector.
How do I registered with the MFSA as an holding directorships or company secretary role?
If you’re not exempt, and you are acting as a director or company secretary in one or two entities, you do not need to apply for full authorisation as a CSP — but you must submit a notification to the MFSA.
Here’s what you need to do:
Step 1: Determine Eligibility
Confirm that you are not exempt under the Exemption Regulations and that you are acting as a director or company secretary in no more than two entities. If so, you fall under the notification requirement rather than full CSP registration or authorisation.
Step 2: Access the MFSA Notification Portal
Visit the MFSA’s dedicated webpage:
🔗 www.mfsa.mt/notifications
Step 3: Complete the Notification Form
Fill in the form provided by the MFSA. This typically includes:
- Personal identification details
- Company names and registration numbers
- Nature of your involvement (director and/or company secretary)
- Any other information required for risk assessment purposes
Step 4: Pay the Required Fee
A fee is applicable for the notification. The MFSA will not process your notification unless the fee is paid in full at the time of submission. Details on the fee and payment method are available on the portal.
Step 5: Submit Before the Deadline
Ensure that your completed form and payment are submitted by 16 July 2025. Late submissions may result in regulatory consequences or follow-up from the MFSA.
Step 6: Keep a Record
Retain confirmation of submission and payment for your records, in case further documentation is requested.
Note: If you hold such roles in more than two entities, you may fall under the requirement to register or obtain authorisation as a CSP, which involves a more comprehensive regulatory process.
MFSA Mission: To Enhance Company Transparency and Accountability
Commenting on the latest developments, Alison Cortis, Head of CSP Supervision at the MFSA, stated:
“These amendments support our ongoing efforts to enhance transparency and accountability within the sector, while preserving a proportionate approach to regulation. The notification requirement and simplified process for limited CSPs will strengthen risk oversight without imposing undue administrative burdens. We encourage all impacted individuals to refer to the available guidance and FAQs on our website.”
For further information and detailed guidance, please visit www.mfsa.mt/notifications. And remember that the MFSA Notification Deadline for Certain Company Service Providers is 16th July, 2025
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