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Understanding the 2025 CSP Amendment: What Changed on May 16?
If you’re involved with companies registered in Malta or are just curious about business regulations, there’s an important update you need to know. On May 16, 2025, Malta introduced a key amendment to its Company Service Provider (CSP) regulations, especially concerning Directors and Company Secretaries.
Before you yawn at the thought of compliance talk – stick with us! This update might affect you more than you think.
The Malta Financial Services Authority (MFSA) has made it mandatory for certain individuals who are acting as Directors or Secretaries of Malta-registered companies – and not doing so as their main business activity – to submit a notification through the MFSA licensed portal. It’s a straightforward process, but the rules about who needs to notify (and who doesn’t) are where things get a little more interesting.
Let’s untangle it all in the friendliest way possible.
Who Needs to Notify the MFSA – and Who’s Exempt?
Not everyone has to notify the MFSA, and thankfully, they’ve made the list of exceptions very clear. Here’s a simple breakdown of who is off the hook:
You’re EXEMPT from MFSA Notification if:
- You work for a licensed CSP and act as a Director or Secretary under their name.
- You own shares (i.e., are a shareholder or UBO) in the same company you serve.
- You are employed (or about to be employed) by the company.
- You’re a family member of the company’s UBO.
- You’re a professional director/secretary by way of business, even if based abroad (but note: such individuals now need a limited CSP authorisation in Malta).
- You serve on a listed company’s board.
❗ You DO NEED to Notify if:
- You are not doing this as your main business and don’t fall under the exemptions listed above.
- Even if it’s just one appointment, notification is still required.
So, if you’re acting casually as a company Director or Secretary in Malta and none of the exemptions apply to you, it’s time to log in to the MFSA portal and register your position.
Deadlines, Process – What to Expect
Let’s talk deadlines and logistics, because missing them could mean trouble down the line.
🗓️ Deadlines:
- Existing Companies: Must notify by July 16, 2025.
- New Companies: Must notify within 14 days of registration.
The great news? If you’re working with a CSP like us, we can submit this notification on your behalf using our MFSA license holder portal.
Also, note that if you are a foreign service provider, like some of our South African partners, and you’re appointing directors to Maltese companies without a CSP license in Malta, you still need to notify.
What’s the CSP’s Role in This Update?
The MFSA has made one thing very clear: licensed CSPs have a duty to inform their current and future clients about this rule – but we are not liable if clients fail to comply.
Here’s what we’re doing:
- Reviewing our client list to identify companies with directors/secretaries who must notify.
- Providing guidance and support to help with the notification process.
- Making sure our team alerts clients during consultations – especially when new directors/secretaries are being considered who aren’t UBOs or their relatives.
You can think of us as your friendly compliance buddy – giving you the heads-up so you don’t run into regulatory surprises.
FAQ – Your Top Questions Answered
I’m only a secretary for one Maltese company. Do I still need to notify?
Yes, even one appointment requires notification unless you fall under the exemptions.
My brother is the UBO of the company I’m a director for. Do I need to notify?
No, close family members of UBOs are exempt.
Can the CSP handle this for me?
Absolutely! If you’re our client, we can submit the notification through our licensed MFSA portal.
I’m based outside Malta. Do these rules still apply?
Yes! If you act as a Director or Secretary for a Malta-registered company, the location doesn’t exempt you from compliance.
A Little Rule That Carries a Big Responsibility
The new MFSA rule might seem like just another piece of red tape, but it’s really about ensuring transparency and responsibility in Malta’s corporate sector. Whether you’re running a local business or managing overseas operations, if your company has Directors or Secretaries, you’ll want to review this rule carefully.
Remember: inform, notify, and comply – and if you’re ever unsure, your trusted CSP (like us!) is just a call or email away.
Need Help Staying Compliant? Contact Us!
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